Study on certification and verification schemes in the forest sector and for wood-based products : report.
Date: 2021-08-10
Institutions: Directorate-General for Environment
Subjects: Community certification, EU market, auditing, biomass, forestry economics, forestry legislation, report, risk management, standard, sustainable development, wood product

Report: Study on Certification and 
Verification Schemes in the Forest 
Sector and for Wood-based 
Products 

Preferred by Nature 
[July 2021] 

Environment

EUROPEAN  COMMISSION 

Directorate-General for Environment 
Directorate F — Global Sustainable Development 
Unit F.3 — Multilateral Environmental Cooperation 

E-mail:  ENV-DEFORESTATION@ec.europa.eu 

European Commission 
B-1049 Brussels 

 REPORT : STUDY ON CERTIFICATION AND VERIFICATION SCHEMES IN THE FOREST 
SECTOR AND FOR WOOD-BASED PRODUCTS 

Report: Study on Certification and 
Verification Schemes in the Forest 
Sector and for Wood-based 
Products 

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PDF        ISBN 978-92-76-40787-4        doi:10.2779/126030        KH-02-21-994-EN-N 

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REPORT : STUDY ON CERTIFICATION AND VERIFICATION SCHEMES IN THE FOREST 
SECTOR AND FOR WOOD-BASED PRODUCTS 

Table of Contents 

Acronyms.................................................................................................................. 3 

Executive Summary ................................................................................................. 5 

Introduction ............................................................................................................... 7 

PART I: Background and methodology............................................................ 13 

1. History of forest certification .............................................................................. 13 

2. Key features of certification............................................................................ 14 

3. Certification Schemes and the EUTR ............................................................ 25 

4. Assessment methodology .............................................................................. 29 

PART II: Cross-cutting issues – findings and discussion............................. 33 

5. Coverage of applicable legislation by the specific certification schemes  .... 34 

6. Traceability and CoC ...................................................................................... 36 

7. Reclaimed material ......................................................................................... 44 

8. General requirements for certificate holders ................................................. 46 

9. Requirements for certification bodies ............................................................ 49 

10.

Scheme Governance .................................................................................. 50 

PART III: Summary of Forest Certification Scheme Assessments .............. 56 

11.

12.

13.

14.

15.

PEFC ........................................................................................................... 61

Forest Stewardship Council (FSC) ............................................................ 80 

Sustainable Biomass Program (SBP)...................................................... 100 

ISO 38200 ................................................................................................. 109 

OLB Bureau Veritas .................................................................................. 119 

PART IV: Evaluation of schemes related to other commodities ................ 133 

16. Methodology.............................................................................................. 133

17.

18.

19.

Overview of schemes ............................................................................... 135 

Findings  ..................................................................................................... 141 

Scheme Assessment Framework for agricultural commodities  ............. 147 

PART V: Recommendations ............................................................................. 150 

For Operators and Monitoring Organisations ..................................................... 150 

For Competent Authorities................................................................................... 152 

For the European Commission............................................................................ 153 

For forest certification schemes .......................................................................... 154 

Scheme Assessment Framework agricultural commodities  .............................. 156 

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Appendix 1: EUTR regulations and guidance on using certification schemes . 157 

Appendix 2: Requirements added to assessment of other commodities .......... 161 

Appendix 3: Glossary of terms ............................................................................ 168 

Appendix 4: References ...................................................................................... 171 

Annex 1: Forest-related certification schemes An overview.......................... 173 

Annex 2: Certification Scheme Assessment Procedure (SAP)  ...................... 241 

Annex 3: Certification Scheme Assessment Framework (SAF) ..................... 259 

Annex  4:  Scheme Assessment  Report Programme  for the Endorsement of 
Forest Certification (PEFC) .................................................................................. 287 

Annex 5: Sche me Assessment Report Forest Stewardship Council (FSC)  . 482 

Annex  6:  Scheme Assessment  Report Sustainable  Biomass  Program 
(SBP)….. .................................................................................................................. 707 

Annex 7: International Standard Assessment Report ISO 38200:2018 ......... 821 

Annex  8:  Scheme Assessment  Report Bureau Veritas Origine et Légalité des 
Bois (OLB)............................................................................................................... 891 

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Acronyms 

AB:  

ASI:  

BC: 

BV:  

CAR:    

CAs:    

Accreditation Body 

Accreditation Services International 

Book and Claim 

Bureau Veritas 

Corrective Action Request 

Competent Authorities 

CASCO:  

Committee on Conformity Assessment 

CB:  

CH: 

CITES:  

CoC:    

CSA:    

CSPO:  

CW:  

DD:  

DDS:    

DTS:    

EC:  

EIA:  

Certification Body 

Certificate Holder 

The  Convention  on  International  Trade  in  Endangered  Species of Wild 
Fauna and Flora 

Chain of Custody 

Canadian Standards Association 

Certified Sustainable Palm Oil 

Controlled Wood 

Due Diligence 

Due Diligence System 

Data Transfer System 

European Commission 

Environmental Investigation Agency 

ETTF:   

European Timber Trade Federation  

EU:  

European Union 

EUTR:  

European Timber Regulation 

FLEGT:  

Forest Law Enforcement Governance and Trade 

FM:  

FME:    

FMU:    

FPIC:    

FRA:    

FSC:    

GNSS:  

HCS:    

HCV:    

HCVF:  

HSCA:  

Forest Management 

Forest Management Enterprises 

Forest Management Units 

Free, Prior and Informed Consent  

Forest Resources Assessment 

Forest Stewardship Council 

Global Navigation Satellite System 

High Carbon Stock 

High Conservation Value 

High Conservation Value Forest 

High Carbon Stock Approach 

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IAF:  

ILO: 

IP:  

International Accreditation Forum 

International Labour Organization 

Identity Preserved 

ISEAL:  

International Social and Environmental Accreditation and Labelling 

ISO:  

IT:  

International Organisation for Standardisation 

Information Technology 

LUCA:   

Land Use Change Analysis 

MB: 

MOs:    

NAB:    

NCR:    

NCR:    

NFSS:   

NGB:    

NGO:    

NMRO: 

OLB:    

PACs:   

PEFC:   

Mass Balance 

Monitoring Organizations 

National Accreditation Body 

Non-Conformity Report 

Non-conformance Report 

National Forest Stewardship Standards 

National Governing Bodies 

Non-Governmental Organisations 

National Measurement and Regulation Office 

Origine et Légalité des Bois 

Product Advisory Committees 

Programme for the Endorsement of Forest Certification 

RSPO:  

Roundtable on Sustainable Palm Oil 

RTRS:  

SAF:    

SAP:    

SBE:    

SBP:    

SFI:  

SG:  

Round Table on Responsible Soy Standard 

Scheme Assessment Framework 

Scheme Assessment Procedure 

Supply Base Evaluation 

Sustainable Biomass Program 

Sustainable Forestry Initiative 

Segregated 

STD:    

Standard 

TIC:  

TLV:  

Testing, Inspection and Certification 

Timber Legality Verification 

WJP:    

World Justice Project 

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Executive Summary 

What is forest certification? What does it certify? How is it used? What can you tell from a 
certificate? 

The  answers  to  these  questions  are  fundamental  to  understanding  the  relationship 
between voluntary certification of forest products and the EU Timber Regulations. 

This  report presents the findings of a study conducted on the behalf of the Euro pean 
Commission, to provide a better overview of forest-related certification schemes and the 
differences between them. A better understanding of how well certification schemes align 
with the requirements of the EU Timber Regulation (EUTR), will benefit th e Operators of 
the timber industry, as defined by the regulation, as well as the authorities responsible for 
enforcing it. 

The  provisions  of  the  EUTR  and  related  implementing  guidelines  provide clarity that, 
although  certified  material  may  play  a  role  in  the  due  diligence  process,  it  is  not  an 
automatic “green lane” to meet the due diligence obligations. Rather than being exempted 
from the requirements of the regulation - like CITES or FLEGT licensed wood-products 
placed on the EU market  - Operators still must conduct a risk assessment of materials 
carrying a certification claim.  

The findings of this study can therefore be used in the following two ways:  

 

 

for certification schemes evaluated as part of the study, as a direct support to the 
risk assessment, adding detail to this process by providing information on where 
potential  strengths  as  well  as  gaps  may  exist  in  the  coverage  of  the  specific 
certification scheme, 

for other schemes not evaluated as part of the study, this summary report should 
provide guidance as to how the scheme should be evaluated, identifying both the 
strengths and gaps which are common to many certification schemes. 

Key findings 

Through  comprehensive  analysis  of  scheme  standards,  combined  with  a  review  of 
external  studies  and  reports,  several  findings  were  made  in  order  to  highlight 
recommendations for EU operators and competent authorities when dealing with certified 
timber products. 

The  overall  finding  of  the  study  is  that  certification  can  provide significant support to 
Operators in their efforts to meet EU Timber Regulation obligations for due diligence. T he 
certification of forest products provides both assessment and assurance of most aspects 
of  legality  and  also  provides  systems  to  control and manage fraud and corruption. In 
addition, the application of chain of custody systems on certified material claims, support 
the ability to access supply chain information and control the flow of material through the 
supply chain. It is concluded that certification is a key tool for Operators for meeting EUTR 
due diligence obligations. 

While being an important tool for Operators, the present study also identified several gaps 
and  weaknesses.  These  need  to  be  considered when buying certified materials. This 
study can serve as a guide to where such weaknesses are found in the schemes under 
assessment. 

The study indicates that certification schemes generally include requirements for certified 
materials to be harvested and traded in accordance with applicable legislation. However, 
the study also identifies the areas where the legal requirements applied by certification 
schemes  are  limited  in  scope  or  ambiguous  in  nature.  It  also  concludes      that  most 
scheme standards have gaps in their legality definitions, that poses risks in relation to 
them fully meeting the definition of applicable legislation as set out in the EUTR.  

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A  second  key  gap  to  certification schemes relates to the traditional model of chain of 
custody systems to track the claims of certification, from the forest to the end buyer. While 
they do provide a systematic approach to transferring claims throughout the supply chain, 
for  the  most  part,  they  do  not  include  the  systematic  ability to verify  – in real time or 
otherwise – transactions of volumes, species, and qualities between entities, thus leaving 
the systems vulnerable to manipulation and fraud. 

The  findings of the study also show that even if certification schemes on the first look 
appear relatively similar, there can be significant differences in what they cover, how they 
operate and how well they address risks of illegal harvesting and trade in certified supply 
chains. 

This  report  includes  the  detailed  analysis  of the normative frameworks of certification 
schemes against a Scheme Assessment Framework developed as part of the study. It 
also  includes  analysis  of  the  performance  of  certification  schemes  based  on  publicly 
available information or data which informs on the functioning of certification systems in 
practice.  Including  the performance-based information which is important because the 
scheme performance not only relies on the contents of normative standards, procedures 
and their application, but also on other factors that affect the effectiveness or integrity of 
schemes, such as corruption.  

Corruption  and fraud are key risks in  timber supply chains from many countries  – this 
problem is not limited to certified timber. A key finding of this study concerning how well 
certification schemes address corruption and fraud, is that although most schemes have 
requirements related to detection of corruption, these are often insufficient. In general, the 
following is applicable to all certification schemes: 

  given  the  clandestine  nature of corruption and the illegalities that stem from it, 

schemes are challenged to identify and effectively handle corruption issues.  

 

the systems in place to identify cases of corruption are relatively limited.  

In  addition,  the risk of fraud, e.g., in supply chains is generally poorly covered. There 
seems to be no approach to enable auditors to detect and act on fraudulent practices by 
forest managers or in the supply chain. So, while scheme do have systems in place to 
control and manage fraud, this is an area where improvement can be made.  

In summary, the findings show that none of these schemes are perfect or ca n provide 
complete control of supply chains, but at the same time they are an essential tool to meet 
EUTR requirements. Certification provides a range of safeguards that support legal trade 
in timber products and definitely safeguards a higher degree of assurance to operators, 
compared to non-certified material or supply chains. 

Operators are therefore recommended to use certified material and make the best use of 
this  certificate  schemes  assessment  in  this  study  to  identify  potential  gaps  in  the 
certification schemes and to compare this with their risk assessment of the supply chain. 

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Introduction 

Certification  of  forest  product  has  been  used  in  the  last  decades  to  improve  forest 
management, secure supply chain traceability and make markets claims to buyers about 
the  certified  status  of  the  material.  But  with  the  implementation  of  the  EU  Timber 
Regulation, market operators and buyers face new challenges in assuring that the timber 
has been legally harvested and transported. These challenges have raised  questions as 
to the effectiveness of certification systems to assure legality, especially as defined by the 
EUTR. 

Specifically, for operators implementing due diligence systems, as required by the EUT R 
as  well  as  for  the  Competent  Authorities  enforcing  the  Regulation,  questions  remain 
regarding  the  level  of  assurance  that  can  be  obtained  from  certified  material.  Also, 
questions are often raised about how the information on certificates can be linked to the 
legality and traceability of the product. 

So,  the  questions  emerging  for  the day-to-day implementation of the EUTR, focus on 
areas  such  as  how  well  a  certification  scheme  ensures  compliance  with  applicable 
legislation and how well the scheme assure that certified material is not mixed with non -
certified  materials.  Also,  how  the  certification  scheme,  in  general,  functions  to  avoid 
fraudulent practices such as corruption and misuse of certification claims.  

This report contains the findings from a study conducted by Preferred by Nature on behalf 
of the European Commission. Its findings provide insight to these questions and deliver 
recommendations  to  the  EC  on  how  a similar approach to assessing the efficiency of 
certification  schemes  could  be  used  to  evaluate  other  issues  for  other  types  of 
commodities. 

About  the study 

Preferred by Nature is contracted by the European Commission (EC) to carry out Study 
on  Certification  and  Verification  Schemes  in  the  Forest  Sector  and  for  Wood -based 
Products as part of the EU Communication on Deforestation.  

The Study was awarded to Preferred by Nature in March 2020 and planned to run for 12 
months. 

As stated in the call for tenders 1  to which this study is responding: 

“The  EUTR  (European  Timber  Regulation)  is  an  EU  legislative  instrument  to 
address the global problem of illegal logging by acting on the side of the demand 
for timber and timber products. While this instrument entered into application in 
2013,  more  recently,  in  2019,  the  European  Commission  adopted  an  EU 
Communication  on  Stepping  up  EU  Action  to  Protect  and Restore the World’s 
Forests.  The  Communication  proposes  actions  to  be  implemented  by  the 
European  Commission to meet these priorities among others to encourage the 
strengthening  of  standards  and  certification  schemes  that  help  to identify and 
promote deforestation-free commodities through, among other things, studies on 
their  benefits  and  shortcomings  and  by  developing  guidance,  including 
assessment based on certain criteria to demonstrate the credibility and solidity of 
different standards and schemes.” 

1 ENV/2019/OP/0013 

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SECTOR AND FOR WOOD-BASED PRODUCTS 

The European Timber Regulation (EUTR) was proposed in October 2008, adopted on 20 
October 2010 as Regulation (EU) No 995/2010 and came into force on 3 March 2013. The 
regulation prohibits the placement of illegal timber on the EU market and covers a wide 
range of products set out in its Annex I. 2  

The EUTR establishes the following three key obligations:   

1.  It  prohibits  the  placing  on  the  market  of  illegally  harvested  timber  or  timber 

products derived from such timber.   

2.  It requires operators who place timber products on the EU market for the first time 

to exercise ‘due diligence’ (“DD”) not to source timber from illegal sources.    

3.  It requires traders in timber and timber products, which have already been placed 

on the market, to keep records of their suppliers and customers.   

Due  Diligence  requirements  are  designed  to  ensure  that  operators  undertake  a  risk 
management exercise to minimize the risk of placing illegally harvested timber, or timber 
products containing illegally harvested timber, on the EU market. 3  

The challenge 

The timber and wood-based industry widely use certification to meet their sustainability 
commitments and as a tool in meeting the due diligence obligations of the EUTR.  

As stated in the tender: 

“The  EUTR  establishes  that  risk  assessment  procedures  in  the context of the 
application  of  the  DD  System  should  include relevant risk assessment criteria, 
including assurance of compliance with applicable legislation, which may include 
certification  or  other  third-party-verified  schemes  which  cover  compliance  with 
applicable legislation. Alongside forest certification systems, certifying bodies issue 
certificates as “third-party” verifying the legality of timber and wood-based e.g., on 
ISO  standards,  as  part  of  Corporate  Social  Responsibility,  or  manage ment 
systems.  But  the  EU  states  that  certification  of a product standard or chain of 
custody does not necessarily prove legality, as required by EUTR. It is therefore 
useful  to  describe  the  differences  in  certification  schemes  and  identify  the 
elements  relevant  under  EUTR.  Difficulties  in  understanding  certificates  and 
certification and lack of clear information by companies/entities and organizations 
issuing certificates may result in operators being in breach with legal requirements 
or at least paying for something with no or limited value. For authorities, the same 
problem might result in waste of enforcement resources or even drawing wrong 
legal conclusions during inspections.” 

Objectives 

The study aims to provide a clear methodology for the evaluation of certification schemes 
to facilitate alignment of the work by Operators and Competent Authorities regarding the 
different legality definitions, criteria behind the certification, and how they relate to legal 
obligations under the EUTR. 

Specific objectives of the Study are:  

2 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32010R0995  

3 https://ec.europa.eu/environment/forests/timber_regulation.htm#diligence  

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1.  Create an overview of certification and verification schemes and certificates being 

used for forest and wood-based products.   

2.  Develop and apply a framework for the evaluation of such certification and third 
part verification schemes, including their respective strengths and weaknesses, in 
relation to the EUTR. 

3.  Evaluate  the  applicability  of  the  framework  to  other  products  originating  from 

converted land.  

4.  Identify options for further work at the EU level/for the Commission. 

Key activities 

The key activities of the Study were: 

  Establish  the  participation  approach,  including  the  Stakeholder  Consultation 
Forum,  the  Peer  Review  Committee  and  other  stakeholders’  networks  and 
platforms and ensure continued participation. 

  Create an overview of certification and verification schemes and certificates being 

used to certify forest and wood-based products. 

  Develop an assessment framework. 

 

Implement the assessment framework to assess selected schemes. 

  Evaluate  the  applicability  of  the  framework  to  other  products  originating  from 

converted land. 

 

Identify options for further work at the EU level/for the Commission. 

Development of the Scheme Assessment  Framework 

To  evaluate  certification  scheme  documents  and  associated  standards,  a  Scheme 
Assessment Framework has been developed. This is described in detail in the section on 
methodology.  

The  Scheme  Assessment  Framework  contains  several  requirements  for  certificati on 
schemes  to  evaluate  how  well  they  address  legal  harvesting  and  trade  and  how  the 
scheme  audits  certificate  holders,  how they approve certification bodies, and how the 
scheme is managed. The framework is structured into a set of principles and criteria:  

A: Requirements for Certificate Holders 

  A.1 Legal Requirements at the forest level 

  A.2 Legal requirements for supply chain entities 

  A.3 Requirements for material control 

  A.4 General requirements for Certificate Holders 

  A.5 Quality and procedural requirements for Certificate Holders 

B: Requirements for Certification Bodies 

  B.1 General Certification Body requirements 

  B.2 Certification Body requirements for auditing and certification 

C: Requirements for Certification Schemes 

  C.1 Transparency 

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  C.2 Standard setting 

  C.3 Accreditation 

  C.4 Certification process 

Each scheme was assessed against all indicators for each of the criteria, according to the 
assessment  procedure also developed for this study. The assessment procedure was 
developed  as  one  of  the  first activities of the study and finalised through stakeholder 
consultation process. 

About  this report 

This report contains separate parts as below: 

PART I: Background and methodology 

in  this  part  of  the  report  the  background  to  certification  is  summarized  and  the 
methodology used for the study is presented. 

PART II: Cross cutting issues 

In this section general information and issues related to the performance of certification 
scheme is discussed. The report includes an evaluation of evidence relating to scheme 
performance, such as scientific articles, reports from civil society organisations and other 
sources.  There  does  not  exist  a  large  body  of  literature  addressing  impacts  and 
performance  of  certification  schemes.  However,  such  information  as  was  found  was 
evaluated, in order to provide examples of where certification schemes provide value, but 
also where examples may show weaknesses. 

Issues related to the performance of certification schemes include how chain of custody 
models  are  implemented  and  what  challenges  exist,  also  there  is  discussion  on  how 
schemes deal with differences in legality definitions and how scheme governance affect 
the performance on the ground.  

This summary report provides a synthesis of this information, drawing on evidence from 
external  performance data to further analyse strength and weaknesses of schemes in 
relation  to  their  real-world  performance,  and the use of certified material within a due 
diligence system. 

PART III: Results related to forest certification scheme evaluations.  

A summary of the key results from the assessments of five forest certification schemes 
and standards against the Scheme Assessment framework developed for this study.  

The Schemes/Standards included in the study are: 

1.  PEFC International, including national standards from Brazil, Romania, Russia and 

China. 

2.  FSC  International  including  national standard adaptation from Brazil, Romania, 

Russia, and China. 

3.  Bureau veritas’s OLB 

4.  Sustainable Biomass Program, and 

5.  ISO Standard 38200 on chain of custody of forest products. 

All reports are annexed to this report. 

The assessments contain an overview of how well the schemes provide assurance that 
certified material is legally harvested and traded and how this assurance could be used as 
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part of Operators’ efforts to comply with the obligations of the EU Timber Regulation. T he 
detailed  assessments  were  focused  on  evaluating  the  normative  requirements  of the 
schemes and their procedures and systems to ensure consistency and integrity in the 
implementation of the schemes. These issues centre around requirements for certification 
bodies, accreditation, as well as scheme governance issues. 

This summary report presents the overall analysis based on the results of the scheme 
assessments. 

PART IV: Analysis of the application of a similar scheme evaluatio n ap pr oach , to 
other commodity certification schemes 

As  stated  above,  the  study  also  includes  an  evaluation  of  how  well  the  approach  to 
assessing forest certification schemes would work with covering certification of non -forest 
products from agricultural production. Special focus is given to products that have a high 
risk of originating from land converted from natural forest or other natural ecosystems.  

The  following  schemes  were  selected  to  evaluate  how  well  the  Scheme  Assessment 
Framework is functioning: 

1.  Soy certification by RTRS; 

2.  Cocoa certification by UTZ, and;  

3.  Palm oil certification by RSPO. 

For  each  of  these  schemes,  a  revised assessment framework was tested to evaluate 
which  indicators  would  be  relevant for other commodities and to  evaluate if additional 
indicators should be added.  

PART V: Recommendations 

The  fifth  and  final  part  contains  a  brief  overview  of  recommendations  based  on  the 
findings of the study. 

study. 

Annexes 

As  mentioned  above  this  report  contains  the  main  findings  and  summary  of  scheme 
assessments conducted as part of this study. In addition to this report several Annexes 
are attached to this report. 

The reports annexed to this report are as follows: 

  Annex 1: Forest Certification Schemes: an overview – This report p rovides a 
general  overview  of  the  structure  and  functioning  of  certification  schemes.  It 
provides  important  information  about  schemes  that  will  enable  the  reader  to 
understand  the  concepts  and  language used by certification schemes and the 
structure set up to implement and govern them. 

  Annex 2: Certification Scheme Assessment Procedure (SAP) – the procedure 

used to asses certification schemes 

  Annex  3:  Certification  Scheme  Assessment  framework  (SAF)   –  the 

Framework used to assess certification schemes. 

  Annex 4: PEFC Scheme Assessment Report - results of the assessment of the 

PEFC Scheme. 

  Annex 5: FSC Scheme Assessment Report - results of the assessment of the 

FSC Scheme 

  Annex 6: SBP Scheme Assessment Report - results of the assessment of the 

SBP Scheme 

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  Annex 7: ISO 38200 Standard Assessment Report – results of the assessment 

of the ISO 38200 Standard.  

  Annex 8: OLB Scheme Assessment Report – results of the assessment of the 

OLB Scheme. 

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PART I: Background and methodology 

1. History of forest certification 

Concerns about deforestation, illegal logging, poor forest management and land rights of 
forest-dependent peoples – particularly in tropical timber-producing countries - emerged in 
the mid-1980s to early 1990s and supported through campaigns by NGOs and Indigenous 
peoples’  organisations  (FERN,  2001).  At  the  same  time,  the  concept  of  sustainable 
development was gaining popularity in the wake of the 1987 Brundtland’s report and the 
United Nations Conference on Environment and Development (‘Earth Summit’) of 1992 in 
Rio. In 1990, international negotiations aiming at setting up a global forest treaty were 
launched  but  this  process  failed  as  the  international  community  never  reached  a 
consensus for a binding multilateral instrument on forests and the necessary definition of 
sustainable forest management and mechanism to enforce it (Perera & Vlosky, 2006).  

In parallel, discussions between the forest products sector, consumers of wood products 
and  environmental  and  human-rights  NGOs  led  to  the  development  of  a  non-
governmental market-based approach, designed to provide a credible way of identifying 
well-managed forests and timber products derived from those forests while meeting the  
various  needs  and  interests  of  actors  involved  (FERN,  2001).  This  started  the 
development of voluntary certification, which led the foundation of the Forest Stewardship 
Council (FSC) in 1993, as an early ‘front-runner’. Set up as an independent non-profit 
organisation with a global reach, FSC pioneered innovative decision-making processes 
accommodating  diverse  interests  and  helped  shape  the  form  that  sustainable  forest 
management  certification  would  take  through  its  ‘Principles  for  Forest  Stewardship’ 
(Brown et al., 2008). 

In the next few years, competition  in the field of voluntary certification emerged, mainly 
from national and regional initiatives; in the USA with the Sustainable Forestry Initiative 
(SFI) in 1994, in Canada with the Canadian Standards Association in 1996 and the Pan -
European  Forest  Certification  (PEFC)  in  1999  (Perera  &  Vlosky,  2006,  Brown  et  al., 
2008). 

The multiplication of such national or regional forest certification schemes soon brought 
debates  over  mutual  recognition.  Based  on  its  successfully  working  with  European 
industry  and  stakeholders,  PEFC  re-launched  in  2003  as  a  global  initiative  called 
“Programme for the Endorsement of Forest Certification schemes”, working as a bench -
marking scheme endorsing national certification schemes also outside Europe, such as 
SFI and CSA. By 2019, 48 national schemes were supported under PEFC (Brown et al., 
2008).  PEFC  is  now  the  certification  scheme  with  the  largest  area  of  certified forest, 
followed  by  FSC,  with  around  325  million  hectares  and 210 million hectares certified, 
respectively. 

Given the timeframes required to achieve Forest Management (FM) certification and the 
time taken to build a critical mass of certified forest, a gap emerged between the available 
volumes of certified timber and the demand for certified material. One early obstacle to the 
growth of the certified forest area, was the challenges faced particularly by wood chip and 
fibre  industries,  as  the  requirement  to physically segregate certified and non -certified 
material is very costly. Another obstacle faced by producers of asse mbled products, for 
whom it could be very challenging to acquire all product components from certified forests. 
The result in both cases was an either-or situation, where either all or nothing of a product 
could be marketed as certified. To address these challenges, different procedures for 
mixing certified and uncertified material were introduced, the two most common of which 
is  the  mass  balance  system  (credit  system)  and  the  threshold  system  (percentage 
system).  

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In the meantime, government-led action to fight unsustainable forest management and 
deforestation emerged with several regulatory measures taken by countries or regions to 
restrict the entry into their internal market of illegally harvested or traded products. In this 
regard, the United States government amended its Lacey Act in 2008, Australia adopted 
the Illegal Logging Prohibition Act in 2012 and the European Union launched its Forest 
Law Enforcement, Governance and Trade Action plan in 2003 and adopted its Timber 
Regulation (EU 995/2010) 4  in October 2010.5  

These new regulatory measures represent an effort to ensure the legality of timber traded 
both domestically and internationally. They mainly took the form of obligations of timber 
businesses trading in forest products to exercise ‘due diligence’ or ‘due care’ in relation to 
the potential risk of illegality in the country of harvest or during their trade.  

Before  aiming  at  sustainability,  the  push  towards  securing  legality,  alongside  the 
challenges  of  sustainability  certification  schemes,  led  to  the  development  of  other 
certification  or  verification  schemes,  such as the Bureau Veritas’ OLB,  geared toward 
ensuring the legality of timber rather than the more demanding threshold of sustainable 
forest management.  

This new set of schemes encompasses the certification of legal harvesting directly at the 
forest level as well as  the certification of legality in trade and transport at  various points  
along  the  supply  chain.  Other  schemes  focus  on  certifying  the  robustness  and 
performance  of  due  diligence  practices  conducted  by  an  organisation  on  its  timber 
supplies.  

These latter schemes have mainly been developed by organisations already involved in 
delivering  certification  services  for  precursor  schemes  (for  instance,  Bureau  Veritas 
(OLB), Control Union (TLV), SCS (Legal Harvest) and Preferred by Nature (LegalSource).  

Similarly,  other  certification  schemes  have  emerged in relation to more specific forest 
product groups or processes. Examples include the Sustainable Biomass Program (SBP) 6  
as a scheme for sustainable biomass production, schemes for non-timber forest products 
(e.g. FairWild7, the International Standard for Sustainable Wild Collection of Medicinal and 
Aromatic Plants, etc.), as well as the ISO Standard specifically for the traceability o f timber 
products (ISO 38200/2018) 8, etc. 

2. Key features of certification 

Forest-related  certification  schemes  may  help  operators  comply  with  the  EU  Timber 
Regulation (EUTR). It is explicitly stated in the regulation text that certification schemes 
may  be  taken  into  account  in  risk  assessment  and  mitigation  procedures.  Still,  it   is 
important to emphasise that the regulation does not exempt certified products from the 
EUTR requirements. While certification may significantly contribute to ensuring legality of 
wood sourcing for operators, they still need to understand the strengths and limitations of 
forest-related  certification  schemes  in  the  context  of  complying  with  the  EUTR 
requirements.   

4 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32010R0995  

5 The EUTR entered into force in March 2013.  

6 https://sbp-cert.org/  

7 https://www.fairwild.org/  

8 https://www.iso.org/standard/70179.html  

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Despite many similarities, each forest-related certification scheme comprises its own set 
of  requirements,  a  discrete  set  of  certification  and accreditation procedures, differing 
approaches to quality assurance and a varying degree of transparency. These differences 
result  in  a  high  level  of  complexity  for  certificate  holders, who in some cases may be 
simultaneously certified under several different certification schemes. This may lead to a 
lack of understanding of the limitations of the individual certification scheme and cause 
certificate holders to fail to understand that compliance with a voluntary forest certification 
scheme does not necessarily equal compliance with all applicable laws in the country in 
which they operate.  

This report seeks to give its readers a much more comprehensive understanding of forest-
related certification schemes, their design, structure, and applicability with the  EUTR. 

Figure 1: Overview of forest-related certification 

2.1 Key features of forest-related certification 

This  paper  focuses  on  legal  and/or  sustainable  forest  management  certification  and 
traceability systems for forest products9 and class them according to key differences in the 
certification  process.  It  may  be  helpful  to  distinguish  between  four  distinct  types  of 
certifications,  depending  on  the  process  and  object  of  certification.  However,  many 
certification schemes share characteristics of more than just one of the following types of 
certifications.   

  Product certification is when the object of certification is the product itself. Product 
certification seeks to ensure that a product meets predetermined specifications, 
such  as  a  certain  quality  level  and  composition. While most forest certification 
schemes are not product certification systems per se since the product itself is not 
subject  to  evaluation.  The  schemes  permit  on-product  certification  claims  for 
marketing purposes.    

  System certification is when the object of certification is a system of procedures 
designed to deliver a uniform product or outcome. Under a system certification, the 
assessment focus on policies, processes, and systems in place rather than the 

9 Certification systems dedicated to product specific attributes, such as wood quality or formaldehyde emissions from wo o d  
products, have omitted from this report. 

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product or performance. The ISO 9000 family of quality management systems is 
an example of a system certification regime.  

  Process certification focuses on specific steps in a production process to acquire 
desired product properties. Chain of custody (CoC) certification can be described 
as a process certification, as the goal is to ensure traceability in the production 
flow through auditing. 

  Performance-based  certification  focuses  on  outcome  rather  than  process. 
Performance-based certification allows for flexibility in achieving a given outcome 
to meet certain thresholds or objectives.  

Most  forest  certification  schemes  contain  elements  of  both  performance -based  and 
system certification. Some criteria and indicators may set specific thresholds that need to 
be met by the certificate holder, while other criteria and indicators may require certain 
systems or procedures to be in place. 

Figure 2: Overview of Overview and roles of actors in certification schemes 

2.2  Actors commonly  involved  in certification 

The following types of entities are usually present within a certification scheme:  

  The  Scheme  owner  is  responsible  for  the  development,  administration,  and 
maintenance  of  a  scheme.  Their  role  usually  involves  developing  a  set  of 
normative requirements (standards) and ensuring that the standards are regularly 
revised, appropriately interpreted and implemented. Scheme owners also establish 
the requirements and procedures for certificate holders and develop an assurance 
system to ensure the proper functioning of the scheme.  

  Accreditation bodies are tasked with accrediting other organisations (certification 
bodies)  to  deliver  qualified  certification  services  under  a  predetermined set of 
requirements. Accreditation bodies should regularly evaluate certification bodies' 
performance to ensure their continuous technical competence and integrity when 
conducting conformity assessment work. An accreditation body may be included in 
a scheme’s institutional setup, in which case the scheme owner will usually choose 
the  accreditation  body.  One  or  more  accreditation  bodies  may  provide 
accreditation services under a certification scheme. However, not all certification 
schemes  function  with  an  independent  accreditation  body,  as  some  scheme 
owners directly accredit certification bodies.  

  Certification  bodies  (CBs)  are  the  third-party  entities  that  deliver  certification 
services,  principally  through  auditing  practices.  A  certification  body  usually 

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employs individual auditors. Their role is to ensure that certificate holders conform 
to the applicable set of requirements whilst following the relevant procedures set  
by the scheme owner for CBs. Some private-sector legality verification schemes 
are, however, also delivering certification activities themselves.  

  Certificate holders are the organisations committing to the conformity assessments 
against  one  or  more  standards.  As  auditors  regularly  assess  the  certificate 
holders,  they  are  generally  referred  to  as  the  “auditee”.  However,  some 
certification bodies distinguish between the ‘certification client’, and the ‘auditee’, 
i.e.  the  client  of  certification  can  be  the  owner  of  a  corp oration  with  many 
subsidiaries, while the auditee may be a specific entity of that corporation.  

  Stakeholders  may  play  different  roles  within  the  functioning  of  a scheme. The 
development of a standard can rest entirely in the hands of the scheme owner, or 
it  may  be  developed  through  a  collective  effort  involving  different  types  of 
stakeholders. 

2.3  Common  characteristics of certification schemes 

  Schemes are international but not governed by sovereign states.  

o  Although environmental policies have historically been promoted through 
government  involvement  via  regulatory  mechanisms,  almost  all  forest -
related certification schemes are voluntary arrangements backed by a mix 
of  private  enterprises,  business  associations,  and/or  civil  society 
organisations. Though public agencies may be involved at some level, they 
are usually not part of the scheme's decision-making bodies.  

  Schemes develop their own standards. 

o  As  similar  international  initiatives  without  governmental  support,  forest 
certification  schemes  can  apply  to  multiple countries without any formal 
association between the sovereign states included in their scope. A notable 
trait  of  these  non-governmental  initiatives  is  their  ability  to  develop 
standards,  guidelines,  product  specifications  and  requirements 
in 
production  methods  to  a  common  standard  above  what  is  required  by 
national laws. 

  Schemes are voluntary.  

o  Because of the sponsorship by non-governmental institutions, international 
initiatives  are  proprietary  systems  where  certificate  holders  participate 
voluntarily.  This  aspect  is  shared  across  all  present  sustainable  forest 
management certification and timber-legality certification schemes.  

  Access to a scheme requires adherence to the requirements of the scheme.  

o  Schemes use standards to ensure a uniform application of requirements, 
and prospective scheme participants will have to undergo an application 
process. Depending on the applicants' place in the supply chain, it may set 
different requirements. The evaluation process may be more performance -
based at the forest level, including implementing legal or sustainable forest 
management  practices.  For  operators  in  the  supply  chain,  Chain  of 
Custody  (CoC)  requirements  tend  to  be  more  system-based  in  nature, 
usually providing normative requirements related to traceability and claims 
about the status of certified products.  

  Certification bodies shall be independent and impartial. 

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o  The  governing  bodies  of  certification  schemes  are  aspiring  to maintain 
independence and objectivity in certification decisions. The impartia lity of 
auditors, who evaluate conformance against a given standard, are core to 
this mission. To ensure objectivity in conformance evaluations, certification 
schemes  rely  upon  an  independent  third  party  to  conduct  conformity 
assessments  and  make  certification  decisions.  In  third-party audits, the 
auditor is without any conflict of interest to the auditee and performs the 
audit to verify conformance with requirements.  

 

It is the certificate holders who pay for certification schemes. 

o 

It  is  a  key  principle  in  forest  certification  schemes  that  the  certificate 
holders  fund  the  costs associated with third-party auditing. A motive for 
forest owners, operators and traders to participate in private certification is 
the  prospect  of  gaining  market  access  or  selling  certified  goods  at  a 
premium, compared to competing products. 

2.4  Definition  of standard requirements  for certificate holders 

The key part of a certification scheme is the requirements to which a certificate holder 
shall conform. The normative requirements listed within standards are usually structured 
within a hierarchy according to the importance of the requirements. A common approach 
is the use of principles, criteria, and indicators (see section 6). In addition to standards, 
most  certification  schemes  provide  additional  guidance,  policies,  procedures,  and 
interpretative documents to support the functioning of the scheme. 

2.5  Understanding  the scope of a certificate 

Organisations usually need to define the scope of forest or forest products and activities 
that the certification body shall evaluate. An organisation may wish to certify only a subset 
of its forest operations or products.  

A  forest  management  certification  may focus on a single site or multiple sites, usually 
made up of individual Forest Management Units (FMU) owned or managed by a forest 
management enterprise (FME). Depending on the scheme, specific rules may apply to 
multisite certification. Special conditions or separate normative requirements, policies, or 
procedures may also apply to the FMUs that are excluded from the certification scope not 
included within the certification.  

Another  approach  to  certification  is seen taken by the Sustainable Biomass  Program, 
which applies a sourcing standard. That means that the system is based on the buyer 
conduction  risk  assessments  and  due  diligence on the material sourced from specific 
regions. This may include areas that are already certified by other certificati on schemes 
but could originate from locations that are non-certified. 

For processing or trade organisations, the scope of their CoC certificate may be limited to 
certain  products  composed  of  certified  raw  material.  It  is  left  to  the  discretion  of  the 
certificate holder to determine what products to include in the scope of certification.   

It is important to keep in mind that the chain of custody in forest-related certification does 
not necessarily provide an ability to trace wood products back to their spec ific FMUs or 
forests of origin. CoC standards, however, do contain requirements designed to prevent 
any mixing or substitution of products or materials not meeting the requirements of the 

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scheme,  in  the  supply  chain.  Each  link  in  the  supply  chain  must  implement  those 
requirements for the whole system to function. 

2.6  The certification process 

The  evaluation  of  the  certificate  holder’s  conformance with the relevant requirements 
(standards)  is  conducted  through  audits.  Audits  often  involve  on -site  visits,  where 
representatives  (auditors)  of  the  Certification  Body  conduct  an  evaluation  of  the 
performance  of  the  certificate  holder  (or  prospective  certificate  holder),  by  reviewing 
documents, conducting inspections, inventory assessments, interviews with staff and/or  
consultation with stakeholders. The frequency of audits is detailed within the scheme’s 
rules and procedures.  

Certification schemes usually set rules on how audits should be conducted. Certification 
Bodies are typically required to apply a documented methodology for the assessment of 
organisations. In forest certification, an important distinction between schemes is whether 
stakeholder consultation shall be a part of the audit or not.  

Most  schemes  require  the  outcome  of  the  audit  findings  to  be  documente d  as  a 
confidential audit report. A scheme may also require that a part of the report, typically a 
summary of findings, be made publicly available to ensure transparency regarding the 
performance of certificate holders and certification decisions. Transpar ency about audit 
findings  is  important  and  a  notable  differentiator  between  certification  schemes.  The 
publication of summary reports of certification audits can be valuable in relation to the 
EUTR, as they may provide relevant information regarding the pe rformance of certified 
organisations and the scope of activities under evaluation.    

Non-conformances can be considered the failure to implement and maintain systems or 
procedures  or  not  meeting  a  performance  threshold  that  may  jeopardize  the  well -
functioning  and  effectiveness  of  the  certification  scheme.  Non-conformances  can  be 
classified depending on their gravity and scale. Different categories of non -conformance 
may have different deadlines for corrective measures to be implemented or may have a 
different impact on a certification decision.  

Based on the conclusion of an audit, a recommendation will be made on whether to award 
or maintain the certification. The certificate will usually have a fixed period of validity, with 
five years being the norm, after which the certificate would need to be renewed. Renewal 
of a certificate will usually entail a full assessment of the certificate holder’s compliance 
with the applicable standards. 

2.7  Chain  of Custody models 

Traceability and chain of custody are not synonymous, despite their common use. A chain 
of  custody  system  includes  measures  that  define  the responsibility for the custody of 
materials and products when these are transferred from one organisation to another within 
the relevant supply chain. Its purpose is to ensure that specified characteristics (e.g. that 
the product is certified) are indeed the ones that are actually delivered in the output.  

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Figure 3: Overview of the CoC system 

Traceability, on the other hand, is defined as the ability to trace the history or location of a 
product. It delivers the ability to follow the movement of a product and its components 
through specified stages of production, processing, and distribution. These two systems 
are not the same. 

Most certification schemes make use of one or more different types of Chain of Custody 
(CoC) models, but very few apply a traceability system. 

There are different types of CoC that have different levels of assurance of the material’s 
actual physical presence in the end product. 

Figure 4: Illustration of the different CoC models in terms of their ability to preserve the original physical presence of the 
certified material. 

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The different CoC models are described briefly below. 

Figure 5: Illustration of the “identity preserved” model. 

The identity preserved model is a chain of custody model, in which the inputs originate 
from a single source. In this model, the material or product is kept physically separated 
throughout the supply chain and the certification status maintained throughout the supply 
chain.  Materials  or  products  are  clearly  identifiable  throughout  the  supply  chain  as 
originating from the single source. 

The second model is the segregated or transfer system model. 

Figure 6: Illustration of the segregated or transfer model. 

In  the  segregated  or  transfer  model,  the  specified  characteristics  of  a  product  are 
maintained, throughout the supply chain. Inputs from different sources that are all certified 
by the same scheme may be mixed. In this model, which is a very commonly used model 
in forest certification, the identity of the source is most often lost. 

Next in list of CoC models are models that allow blending of materia l with different types 
of certification status. For example, this is used in PEFC where PEFC certified material 
can  be  mixed  with  non-certified  material  as  long  as  this  material  is  from  Controlled 
Sources. 

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Figure 7: illustration of the controlled blending model with a percentage -based use 

The controlled blending model is a chain of custody model in which certified materials or 
products are mixed with non-certified materials or product, but often with a set of criteria 
such as Controlled Sources. This results in a known proportion of the certified material in 
all parts of the final output. That means that the end user will know the percentage of 
certified material in each product with that specific certification claim. This mode l applies a 
percentage-based calculation. 

Another CoC model that allows mixing is known as the mass balance model. In the mass 
balance  model certified materials or products are mixed with non -certified materials or 
products, resulting in a claim on a part of the output that must be proportional to amount of 
certified input. The calculation of volumes may be percentage based or managed in a 
credit system. Importantly, in this model the end- use may buy a product with no certified 
material in. 

Figure 8: Illustration of the mass balance model. 

The mass balance model can be used by applying a rolling average calculation of the 
percentage of certified inputs over a period, or credit system where the output of certified 
claim shall correspond to the volume of certified input for a specific credit period. 

The last model described here is the book and claim system. The book and claim model 
aim  to  ensure  that  for  each  purchase  for  which  a  certification  claim  is  made,  a 
corresponding volume of certified materials is purchased. 

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Figure 9: Illustration of the book and claim model. 

The  book  and  claim  model  is  an  alternative  chain  of  custody  model  in  which  the 
administrative record flow is not connected to the physical flow of materials or products 
throughout  the  supply  chain.  After  production  of  certified material, the information on 
specified  characteristics within the supply chain is decoupled from the actual material. 
Credits are issued when materials or products enter the market. The credits can then be 
traded and sold independently of the physical delivery of certified materials.  

2.8  Certification claims and communication 

Forest certification schemes usually permit certificate holders to market certified produ cts 
to consumers in the form of labels on the product itself (also known as ‘on -product claims’) 
and/or  communication  to  consumers  about  the  certified  status  of  the  product  or  the 
certificate holder (also known as ‘off-product claims’). Certification labels have  increased 
complexity as many certification schemes use different on-product labels, depending on 
the  type  of  input material used (reclaimed material for example) and/or the method of 
segregating/mixing certified and uncertified material (mass balan ce/threshold systems) 
within the supply chain. A basic understanding of the meaning of the different certification 
labels is necessary to understand their applicability under the EUTR.  

Some certification schemes restrict the use of certain types of product claims to business-
to-business  communication  only,  thus not permitting those certification claims towards 
consumers. An example of this is FSC Controlled Wood (non-certified material of known 
origin, with a low risk of origin from unacceptable harvesting practices), which may only be 
marketed in business-to-business communication. In contrast, FSC Certified Wood (wood 
products originating from a certified forest or wood products containing both FSC certified 
material and FSC Controlled wood) may carry on-product claims (FSC 100% or F SC Mix 
logos) directed towards consumers. 

Unlike  sustainability  certification  schemes,  timber  legality  certification schemes do not 
usually permit certificate holders to make on-product claims on their certified products. 

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2.8.1  Understanding certification claims, trademarks and labels 

A certification “claim” refers to the language that a certification scheme allows certified 
organisations to make about the product they are producing or selling. This claim usually 
refers to the product's certified status, such as “this product originates from sustainably 
managed forests”. The claim is, therefore, a short description of the certification status of 
the product. 

A “trademark” is the logo of the certification scheme. This trademark will oft en be used 
together  with  the  claim  to  create  a  label.  Still,  it may also be used when publishing a 
statement about the certification status of an organisation, for example, on their website.  

The  “label”  refers  to  the  sticker  or  graphic  element  that  can be  a combination of the 
certification claim, the trademark of the certification scheme, and sometimes also a code 
to identify the certificate holder’s unique license number. 

Claims  and  labels  are  used  differently  by  different  schemes  and  standards  to 
communicate  about  the  certification  status  of  the  material  or systems covered by the 
scope of certification. 

It is important to understand the meaning of different claims which are possible within a 
scheme,  as  each  may  hold  a  different  weight and have different levels of meaning in 
relation to the EUTR. 

Types of claims 

The word “claim” is used to describe the type of certification covering a specific product or 
process.  

Different types of claims are used and commonly certification schemes have claims that 
cover the following: 

1.  100% from certified forest - a claim that indicates that all the material in a product 

originates from a forest that is certified against the FM standard.  

2.  A mixed claim, which cover material that is a mix of material from certified fo rest 
and material that originates from non-certified sources (e.g. Controlled Sources of 
the PEFC Scheme) 

3.  A recycled or reclaimed claim, which cover material that originates from material 
that  has  been  reclaimed  either  from  pre-  or  post-consumer  use.  The  exact 
definition of reclaimed or recycled differs between schemes (see below).  

The specific claims used by each scheme is addressed in part III of this report a summary 
of the findings for each of the schemes or standards included in the study are presented. 

Types of trademark use 

Some  schemes  allow  certificate  holders  to  use  different  forms  of  their  registered 
trademark (e.g. the PEFC logo) on-product labels and claims as well as off-product; some 
only  off-product  claims.  Claims  or  trademarks  of  the  specific  scheme  can  be used in 
different ways: 

1.  On-product use: Labelling of certified products or their packaging.  

2.  Promotional use (off-product): Use of the trademarks for marketing purposes. E.g. 
on homepages, stationary templates, product catalogues, trade fair banners, etc. 

There may be different labels and requirements for the different types of trademark use. It 
should also be mentioned that several schemes do not allow their certification logo and 
claim to be used alongside claims from other certification schemes. This means that a 
certificate holder that operates with both PEFC and FSC certification, cannot label the 
material with both claims at the same time. 

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2.9  Accreditation of Certification  Bodies 

Accreditation is the process of evaluating and approving ce rtification bodies to function 
under  the  scheme  rules.  The  goals  of  providing  robust  and  objective  conformance 
assessments imply consistency over time, locations, and between certification bodies with 
similar  audit  conclusions  reached  –  independently  of  the  time,  location,  auditor,  or 
certification body in question. Many approaches for calibration, guidance or interpretation 
have been employed by certification schemes to prevent or rectify threats to credibility and 
objectivity – often in line with ISO or ISEAL10 guidelines.  

Schemes usually include requirements to ensure that certification bodies, auditors, and 
other personnel relevant to the conformance evaluation of an organisation are competent 
and impartial in their decision making. Risks to impartiality and conflicts of interest can be 
prevented and monitored in various ways. 

2.10  Transparency 

Schemes differ in their level of transparency, some aspects of which are fundamental to 
allow operators, competent authorities and other organisations to evaluate the  applicability 
of the certification scheme to their due diligence system. Examples of where transparency 
is important to include: 

  The provision of information on certificate scope (forests, manufacturing facilities) 

and validity via publicly available official databases. 

 

 

Information  of  relevance  to  buyers  of  certified  products  (species  and  origin, 
reclaimed content). 

Information  on  the different aspects of how a scheme is functioning (normative 
scheme requirements for certificate holders). This is important for the evaluation of 
the applicability of a scheme to the EUTR. 

A  good  assurance  system  must  also  have  detailed  and  consistently  implemented 
procedures  to  handle  appeals  and  complaints.  A  complaints  procedure  allows  the 
expression of dissatisfaction over the functioning of a scheme, scheme-related entities 
(certification bodies, accreditation bodies) or scheme participants (certificate holders).  

3.  Certification Schemes and the EUTR 

Despite similarities, different scheme and standards aiming at certifying o r verifying forest 
and/or timber legality encompass different requirements and definitions of legal, social 
and  environmental  criteria.  In  addition,  different  schemes  have  varying  levels  of 
transparency, different rules and procedures, and different qualit y assurance systems. 
These can lead to different approaches to ensuring conformance among organisations 
that participate (certify) in the scheme. 

10 ISEAL is a global membership organisation for development of sustainability systems.  

https://www.isealalliance.org/about-iseal  

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In  the  following  sections,  it  is  discussed  how  certification  schemes may be used as a 
component  of  the  due  diligence  system  applied  by  Operators  to  meet  the  EUTR 
requirements. 

The EUTR includes provisions to recognise third-party verification as a tool to mitigate 
risks  in  supply  chains.  Implementing  Regulation  607/2012  details  four  conditions 
necessary for certification schemes to be considered when implementing risk assessment 
and risk mitigation: 

1.  they  shall  have  established  and  made  available  for  third -party  use  a  publicly 
available  system  of  requirements,  which  system  shall  at  the  least  include  all 
relevant requirements of the applicable legislation;  

2.  they shall specify that appropriate checks, including field-visits, are made by a third 
party at regular intervals no longer than 12 months to verify that the applicable 
legislation is complied with;  

3.  they  shall  include  means,  verified  by  a  third  party,  to  trace  timber  harvested 
following applicable legislation, and timber products derived from such timber at 
any point in the supply chain before such timber or timber products are placed on 
the market, and; 

4.  they shall include controls, verified by a third party, to ensure that timber or timber 
products  of  unknown  origin  or  timber  or  timber  products  that  have  not  been 
harvested according to applicable legislation do not enter the supply chain.  

The EUTR guidance document (Commission Notice of 12.06.2016 - Guidance document 
or the EU Timber Regulation 11) further details the role of third-party verification schemes in 
risk assessment and risk mitigation.  

These points form the basis for evaluating schemes in relation to the  EUTR and defining 
the factors that can affect scheme performance and credibility. Each scheme includes 
different  requirements,  procedures,  and  assurance  systems.  Each  will  need  to  be 
evaluated by the individual operator sourcing certified products to dete rmine its value as 
an indicator of negligible risk.  

The operator needs to ensure that the certification scheme can provide a sufficient level of 
risk  mitigation  as  desired.  Looking  at  certification  schemes  through  the  lens  of  due 
diligence is therefore about understanding the make-up and functioning of the schemes 
and their potential areas of strength and potential weaknesses to understand how these 
might impact existing risks in timber supply chains. 

3.1  Forest certification schemes and the EUTR 

Whether related to certification schemes’ standards and requirements or to the schemes’ 
institutional and procedural arrangements, the following elements are considered in the 
evaluation  to  understand  the  strengths  and  potential  limitation  of  those  schemes, 
particularly given their use by Operators comply with EUTR requirements. 

A comprehensive interpretation of the five categories of applicable legislation included in 
the EUTR has been used in the study. The Preferred by Nature LegalSource indicators 
has  been used as the basis for providing a specific framework of legality issues to be 
addressed. 

11 https://ec.europa.eu/environment/forests/pdf/C_2016_755_F1_ACT_EN_V6_P1_831439.PDF  

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Often the first information available to an operator about a certified product is a copy of 
the certificate itself – or a link to its publicly available online certificate database. Whether 
related to certification schemes’ standards and requirements, or the schemes’ institutional 
and procedural arrangements, the following list provides some key elements which should 
be considered for evaluation to understand the strengths and  potential limitation of those 
schemes, given their use by operators to comply with EUTR requirements:  

  Scheme normative requirements and the definition of legality 

  Alignment with EUTR definitions, such as that for reclaimed material 

  Chain of custody (CoC) requirements 

  Certification claims and their specific meaning in relation to the EUTR 

  Robustness of the scheme quality assurance systems 

  Validity of certification (1-5 years) 

  Level of scheme transparency in findings, audit results and complaints 

  Stakeholder  engagement  in  the  certification  scheme  as  indicators  of  the 

robustness and credibility of the scheme. 

3.2  Aligning  with the EUTR  definition  of applicable legislation 

Normative requirements of a certification scheme for specific standards should b e well 
formulated  and  organised,  sufficiently  clear  to  allow  for  consistent interpretation, and 
implemented in a sufficiently rigorous way to provide strong assurance on systems and 
performances.  To  ensure  consistent  conformance  and  evaluation  of  conforman ce by 
certificate holders and auditors, schemes must clearly identify the specific types of legality 
that should be complied with by certificate holders and audited against by auditors.  

The EUTR has its own definition of forest-related applicable legislation, including national 
legislation and international conventions. Therefore, it is important to determine if/where 
schemes differ from this definition: some schemes might go beyond the EUTR definition, 
while  other  schemes  might  fall  short  of  aligning  with  this  definition  and  provide  clear 
interpretations, in which case it is important to determine where exactly are the gaps (i.e. 
where a scheme does not include an area of legislation included in EUTR).  

The EUTR includes a broad global definition of the categories of the applicable legislation 
that should be considered relating to the due diligence process of Operators. According to 
Article 2 (h) in EUTR these are: 

“‘applicable legislation’ means the legislation in force in the country of harvest covering the  
following matters:  

(1) rights to harvest timber within legally gazetted boundaries,  

(2) payments  for  harvest  rights  and  timber  including  duties  related  to  timber 

harvesting,  

(3) timber harvesting, including environmental and forest legislation including forest 
management  and  biodiversity  conservation,  where  directly  related  to  timber 
harvesting,  

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(4) third parties’ legal rights concerning use and tenure that are affected by timber 

harvesting, and  

(5) trade and customs, in so far as the forest sector is concerned.”12  

These categories have been purposefully worded as broad categories, which should be 
interpreted  at  a  national  level  to  ensure  that  all  relevant  and applicable legislation is 
included when considering the forest sector. For Preferred by Nature to evaluate, in de tail, 
how  well  certification  schemes  and  standard  are  covering  these,  the  LegalSource 
standard has been used as a reference. This has provided a comprehensive interpretation 
of sub-categories that are essential to comply with and to evaluate specifically t o ensure 
compliance with applicable legislation. 

The  Preferred  by  Nature  interpretation  of  applicable  legislation contains the following 
specific sub-categories to provide details: 

1. Legal rights to harvest  

1.1  

Land tenure and management rights 

1.2   Concession licenses 

1.3  Management and harvesting planning 

1.4 

Harvesting permits 

2. Taxes and fees 

2.1   Payment of taxes, royalties and harvesting fees 

2.2   Value-added taxes and other sales taxes 

3. Timber harvesting activities  

3.1  

Timber harvesting regulations 

3.2   Protected Sites and species 

3.3   Environmental requirements  

3.4   Health and safety 

3.5  

Legal employment  

4. Third parties´ rights 

4.1   Customary rights 

4.2  

Free, Prior and Informed Consent (FPIC) 

4.3  

Indigenous and traditional peoples' rights 

4.4 

Public rights to access forests  

5. Trade and transport 

5.1   Classification of species, quantities and qualities 

5.2  

Trade and transport 

5.2   Offshore trading and transfer pricing 

5.4   Customs regulations 

5.5 

CITES 

12 EUTR, Article 2(h) 

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Forest-related schemes usually include requirements on the legal compliance of forest 
management units with applicable legislation, thereby defining boundaries of what legal 
rules are considered for by the Scheme.  

Requirements to ensure supply-chain legality have, to some extent, been included within 
certification  schemes  as  additions  to  standard  requirements,  which  have  historically 
focused on demonstrating forest-level management performance. As the EUT R includes 
legal  requirements  in trade and exports, it also becomes important to  determine if the 
scheme’s standards and systems to ensure legality in supply chain entities are robustly 
implemented and monitored. 

An important issue relates to how well schemes manage the risk of corruption and other 
types of fraud by potential certificate holders. The extent to which schemes are vulnerable 
to different types of corruption which may impact the forest sector is evaluated, particularly 
bribery and conflict of interest. External evidence from publicly available information has 
been used to assess this aspect as corruption risks are mentioned explicitly by the EUT R 
as a crucial risk factor to illegality. 

4.  Assessment methodology 

The  schemes  included  in  this  study  were  assessed  against  the  Preferred  by  Nature 
Scheme  Assessment  Framework  (SAF)  -  which  include  the  EUTR  criteria  outline  in 
section 3.1 above - using a specially developed Scheme Assessment Procedure (SAP).  

Please see these specific documents for details. 

The  Scheme  Assessment  Framework  (SAF)  has  been  used  to  assess  the  ability  of 
certification  schemes  to  provide assurance that material traded via the scheme has a 
negligible (low) risk of being illegally harvested or traded.  

The framework and the assessment procedure have been developed as a comprehensive 
interpretation of the  legality definition of the EU Timber Regulation and the associated 
Guidance Document and requirements for the use of third party certification schemes as 
outlined  in  the  Commission  implementing  Regulation  (EU)  No 607/2012. Preferred by 
Nature has done that by using the LegalSource legality definition as a basis for developing 
such a comprehensive interpretation. 

There  is  also  added  requirements  from  ISO  and  ISEAL,  and  other  quality assurance 
systems, to address issues related to scheme implementation and go vernance. 

4.1 Overview of assessment approach 

The assessment framework (the SAF) has been applied to the Scheme standards. This 
means that where the scheme is organised through national (or sub -national) standard -
setting  and  quality  management  schemes,  these  are  the  object  of  assessment. 
International rules, procedures, or standards have been evaluated where they are relevant 
to the Scheme implementation. 

The framework includes requirements to assess how different timber certification schemes 
provide assurance of low (negligible) risk of ‘legal non-compliance’ of certified material.  

The  assessment  of  each  Scheme  has  been  conducted  using  four  broad  sources  of 
information: 

(1) Publicly  available  information  from  the  scheme  itself:  in  relation  to 
documented normative requirements (existing standards, policies and procedures) 

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and  documents  that  guide  the operational functioning of the Scheme (such as 
guidance13 and other tools or resources which describe how requirements should 
be interpreted) 

(2) Direct interviews and discussions with relevant Scheme personnel: the 
application  of  the  Framework  will  not  be  limited  to  desk-based  review  of 
documents  but  will  also include on-site interviews with relevant representatives 
from  the  selected  Schemes  (and  where  relevant,  related  bo dies  such  as 
assurance  providers,  accreditation  bodies  and  certificate  holders) to ensure a 
detailed representation of the functions of the schemes.  

(3) Stakeholder input via the Stakeholder Consultative Forum: input solicited by 
Preferred  by  Nature  –  or  submitted  independently  by  Stakeholders  -  via  the 
Stakeholder Consultative Forum. 

(4) Outcomes  or  impacts  information:  Publicly  available  information  or  data 
(research  studies,  stakeholder  reports,  competent  authority  data,  certificate 
databases)  as  well  as  expert  or  authority  consultations,  which  inform  the 
evaluation of the Scheme in relation to the results or impacts that it has achieved, 
or that relates to Schemes in general. 

4.2 Certification Scheme  Assessment Framework (SAF) 

The  assessment  of  each  Certification  Scheme  has  been  conducted  by  applying  the 
criteria, indicators, and threshold guidance in the Scheme Assessment Framework (SAF).  

The SAF is divided into separate sections aiming at evaluating different aspects of the 
Scheme. These include: 

A: Requirements for Certificate Holders 

  A.1 Legal Requirements at the forest level 

  A.2 Legal requirements for supply chain entities 

Evaluates  if  the  scheme  includes  a    comprehensive  set  of  requirements  enabling 
evaluation  of  compliance  with  applicable  legislation  by  the  certificate  holder.  These 
requirements are applicable to forest level, as well as supply chain entities.  

  A.3 Requirements for material control 

Evaluates  if  the  scheme  includes  requirements  to  avoid  that  material  from  unknown 
sources is mixed into the product flow included in the scope of the certification. T his may 
be  via  a  CoC  system  using  different forms of physical separation or using risk -based 
approaches  to  supply  chain  management.  It  should  be  emphasized  that  it  is  not  a 
requirement of the SAF that schemes have a specific type of CoC system, but there does 
need to be performance requirements that assure the absence of mixing.  

  A.4 General requirements for Certificate Holders 

  A.5 Quality and procedural requirements for Certificate Holders 

13  Guidance  is  often  contained  within  separate  guidance  documents  or  embedded  in  assurance  requirements  as 
interpretation  guidance  that  can  be  referred to. It provides necessary context and consistency for the interpretation of 
standards. 

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The  SAF  contains  criteria  that  were  used  to  assess  how  the  scheme  ensures  that 
Certificate  Holders  have    systems,  capacity  and  qualifications  in  place  to  meet  the 
Scheme requirements continually. 

B: Requirements for Certification Bodies 

  B.1 General Certification Body requirements 

  B.2 Certification Body requirements for auditing and certification 

These  criteria  were  formulated to assess the system of the Scheme that should be in 
place to manage processes like accreditation, oversight, competence and resources in 
relation to Certification Bodies. 

C: Requirements for Certification Schemes 

  C.1 Transparency 

  C.2 Standard setting 

  C.3 Accreditation 

  C.4 Certification process 

These  criteria  were  formulated to assess the system of the Scheme that should be in 
place to manage standard setting and revision, as well as on-going scheme maintenance 
and development, including scheme transparency, managing complaints etc. in terms of 
transparency, here the focus was to evaluate how the scheme manages transparency in 
terms of making the scheme requirements public, as well as having publicly available lists 
of certified organisation, in addition to summaries of certification findings for certificate 
holders. 

4.3 Evaluation  of indicators 

For  each  of  the  indicators  in  the  Scheme  Assessment  F ramework,  a  conclusion  will 
indicate to which degree the Scheme or Standard covers the indicators. The following 
differentiations were applied: 

Table 1: Overview of categorisation of findings. 

Conclusion 

Definition 

Explanation 

Covered 

When available Scheme 
requirements and information 
- and any impacts evidence 
available - indicate the 
coverage of the SAF indicator. 

Coverage is the ability of the 
Scheme to provide assurance 
that material traded via the 
Scheme has a low (negligible) 
risk of being illegally 
harvested, traded in line with 
the legality definition of the 
EU Timber Regulation. 

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Partially Covered 

Not Covered 

When available Scheme 
requirements and information 
- and any impacts evidence 
available - indicate only partial 
coverage of the SAF indicator.  

Alternatively, special concerns 
about Scheme Standards, 
credibility, rigor or coverage 
may exist. 

Partial Coverage means the 
Scheme is only partly able – 
or may be compromised in 
one or more ways – to 
provide assurance that 
material traded via the 
Scheme has a low (negligible) 
risk of being illegally 
harvested, traded in line with 
the legality definition of the 
EU Timber Regulation. 

When available Scheme 
requirements and information 
- and any impacts evidence 
available - indicate that there 
is no coverage of the SAF 
indicator. 
NOTE: It is important to justify 
a no coverage conclusion. 

The Scheme is not – or 
inadequately – able to provide 
assurance that material 
traded via the Scheme has a 
low (negligible) risk of being 
illegally harvested, traded in 
line with the legality definition 
of the EU Timber Regulation. 

Not Applicable (N/A) 

When, for whichever reason, 
the SAF indicator does not 
apply. 

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PART II: Cross-cutting issues – findings and 

discussion 

The  findings  from  the  assessment  of  specific  schemes are presented in the following 
sections along with observations reached from the review of other external information 
which highlights challenges related to real-world performance of certification schemes. 
The  key  issues  identified  regarding  the  functioning  of certification to meet EUTR due 
diligence obligations are outlined.  

In relation to the EUTR, certification schemes and standards are often an important tool 
for Operators to assess and mitigate risks in their supply chain, with the potential for the 
Operator to achieve a high level of confidence in the supply, with minimal resources and 
effort – thereby assuring an optimal option from a cost efficiency perspective.  

The combination of activities which comprise forest certification schemes - including desk-
based evaluation, regular on-site assessment of performance, stakeholder consultation 
and  the  requirement  for  systems  of  segregation  and  traceability  - may not be readily 
available  or  be  practically  impossible  or  commercially  unviable,  for  the  Operator  to 
conduct  these  by  themselves.  Additionally,  other  approaches  (e.g.,  documentation 
checks)  conducted  by the Operator themselves) will be far from effective to mitigating 
risks in comparison. 

Often importers in the EU have long supply chains and are significantly curtailed in their 
ability to gain access to the forest or their sub-suppliers as required for them to conduct 
effective risk mitigation within a reasonable – and commercially viable – timeframe. This is 
for  multiple  reasons,  notwithstanding  the  financial  resources  necessary  to  conduct 
effective  due  diligence;  the  availability  of  in-house  technical  competences, as well as 
language capacity of the country of harvest and supply-chain entities. 

The result of these factors means that -for many companies – certification is an important 
option  available  in  the  marketplace  that  approaches  their  ability  to  be  assured  of  a 
negligible risk conclusion for their wood material sources.  

As  mentioned  above,  the  findings  in  this  chapter  also include an overview of existing 
publicly available information concerning the performance of the certification schemes. 
The assessments of certification schemes and their standards focused primarily on how 
the  normative  requirements  of  certification  cover  specific  issues  (such  as including a 
comprehensive legality definition or have in place requirements for audit frequency), as 
well  as  other  important  aspects  of  the  performance  of  certification  schemes.  These 
aspects include issues that are harder to evaluate, or measure based only on assessing 
the normative requirements and procedures of the schemes, but relate to how these are 
implemented, enforced, and interpreted in practice. To evaluate these issues, which have 
profound importance on the integrity of certification, additional information available from 
publicly available reports. 

A desk-based literature study was conducted to identify observations and findings from 
credible  studies  related  to  certification schemes performance in general or of specific 
schemes of specific situations. 

In general, the quantity of scientific studies and other impact data which speaks to the on -
the ground performance of certification is relatively low (Dasgupta, 2017). In addition, the 
research  available  has  been  generally  considered  to  be  of  varying quality and using 
different methodologies, making it difficult to confirm the real impacts of forest certification. 
Apart  from  scientific  research,  there  is  a  wealth  of  reports  available  from  a  range   of 
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organisations with information on specific cases of the impacts or efficiency of certification 
– mostly critical reports that address findings related to shortcomings of specific schemes 
in countries or regions. Most of this information focuses on FSC, and PEFC certification – 
very  little  has  been  published  specifically  about  the  OLB,  SBP  schemes and the ISO 
38200 standard, which also have much less volume certified. 

The outlining of the findings of the assessments combined with performance information 
from external sources follows below. 

5.  Coverage  of  applicable  legislation  by  the  specific 

certification schemes 

This  section  outlines  how  the  study's  selected  schemes  cover  specific  categories  of 
applicable legislation and evaluate compliance by certificate holders. 

The  coverage  of  categories  of  applicable  legislation  is  addressed  in the Assessment 
Framework Sections A1 and A2. 

The EUTR contains requirements that Operators evaluate the risk that timber products 
placed on the internal market have been harvested or traded in violation of applicable 
legislation in the country of harvest. The Regulation also contains a definition of what such 
applicable legislation covers – broadly defined as: 

“‘applicable legislation’ means the legislation in force in the country of harvest covering the 
following matters:  

(1) rights to harvest timber within legally gazetted boundaries,  
(2) payments  for  harvest  rights  and  timber,  including  duties  related  to  timber 

harvesting,  

(3) timber harvesting, including environmental and forest legislation including forest 
management  and  biodiversity  conservation,  where  directly  related  to  timber 
harvesting,  

(4) third parties’ legal rights concerning use and tenure that are affected by  timber 

harvesting, and  

(5) trade and customs, in so far as the forest sector is concerned.”14  

This definition is broad, not detailing specific areas or sub -categories of legislation that 
should  be  considered.  As  outlined  in  the  methodology  section,  a  comprehe nsive 
interpretation of applicable legislation was developed based on the EUTR definition. T his 
interpretation is used as the basis for the evaluation framework. 

14 EU Regulation No 995/2010, Article 2(h) 

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Box  1:  Note  on  the  selection  of  the  legality  framework  used  in  the 
assessments. 

In  relation  to  applicable  legislation,  it  should  be  underlined  that  the  study  aimed  at 
evaluating if the schemes and standards included specific clear and unambiguous wording 
that covered the requirements of the assessment framework. The objective was to i dentify 
how  well  schemes  included  detailed  normative  requirements  to  ensure  a  consistent 
interpretation of the scope of legality for the following purposes:  

  consistent  standard  development,  or  adaptation  of  generic  requirements  to  the 

national or local levels. 

  consistent interpretation by certificate holders over time and different geographies, 
to understand exactly what types of legislation they have to be in compliance with  

  ensuring  auditors  have  a  consistent  basis with which to evaluate compliance by 

certificate holders. 

As a result of this approach, generic statements (e.g., “All applicable legislation shall be 
met…”), were not considered sufficient to cover the assessment framework requirements, 
as being too generic in nature and allowing for ambiguities or variation in the subsequent 
interpretation of compliance requirements. As a comparison, one would also not consider 
generic  statements  like  “the  forest  shall  be  managed  sustainably” as adequate to fulfil 
objectives to attain sustainable forest management – also here more specific issues need 
to be comprehensively detailed. 

It  is  also  underlined  that  the Preferred by Nature definition of legal sub -categories was 
developed in collaboration and with inputs from with FSC, ETTF and Client Earth back in 
2010  –  2011  when  the  Preferred by Nature (then NEPCon) LegalSource standard was 
developed. This definition formed the basis for the application – and subsequent approval – 
as a Monitoring Organisation. 

The study results show that, while most schemes and standards include a range of legal 
requirements that are considered too broadly cover the five categories of the applicable 
legislation of the EUTR, there are specific issues that some schemes do not cover or only 
cover partially. 

The overview table (See PART III of this report) of the assessment findings provides a 
side-by-side comparison of the evaluation findings and can provide an overview of where 
schemes  are  considered  to  include  requirements  that  fully  or  partially  cover  the 
assessment requirements. 

5.1 Implications 

A  very  stringent  and  detailed  approach  has  been  applied  in  this  study  to  evaluate 
coverage of the legal requirements of the schemes and standards. This means that most 
of the schemes included in this study have areas in which they only have partial coverage 
of  very  specific  wordings  from  the  assessment  framework.  So,  in  the  following,  the 
implications of findings will be discussed. In terms of operator’s obligations to conduct due 
diligence and evaluate the risk of specific applicable legislation being in non-compliance in 
their supply chains, the information of this assessment can be used to detail their risk 
assessment work.  

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The  EUTR  is  clear  that, though certified material may play a role in the due diligence 
process, it is not a “green lane” to meet the due diligence obligations. Operators also have 
to conduct risk assessment on material carrying a certification claim.  

Therefore, the findings of this study demonstrates that additional risk assessment may be 
required for certification schemes, by Operators or MOs, to evaluate where potential gaps 
may exist in the coverage of a specific certification scheme.  

5.2 Recommendation/Guidance 

Therefore, the findings of this study can be used as a support to risk assessment and add 
detail to this process by providing information on where potential gaps may exist in the 
coverage of the specific certification scheme. Thus, it can help by allowing operators and 
competent  authorities  to  ask  specific  questions  related  to  the  risks  relevant  to  the 
certification claims. 

Therefore, it is recommended that the results are used as part of the risk assessment 
process and applied in combination with an evaluation of the overall legality risks in the 
country of harvest of the material. One may then be able to identify specific risks in the 
country of harvest and evaluate if there are specific areas of risk that are not covered or 
partly covered by the scheme in question. 

An  example  of  this  could  be  certified  timber  sourced  from  a  country  where  a  risk 
assessment has identified a high risk of illegal issues surrounding the issuing of harvest 
licenses. If there are also gaps in the certification scheme in the same areas, this would 
require additional risk mitigation actions to cover the gap in the certification scheme a nd 
the  identified  risk.  This  example  highlights  the  importance  of  managing  fraud  within 
certification systems. The question is how well schemes address attempts to cheat the 
systems  –  as  discussed  below,  this  is  a  key  issue  for  many  schemes,  as  they  often 
struggle to adequately address this in their systems and procedures. 

6.  Traceability and CoC 

Without a relatively secure way of ensuring that material actually originates from a forest 
that is certified or from a source which has been controlled for illegal harvesting and trade, 
a scheme would not have credibility. Chain of custody (CoC) systems within schemes are 
designed for this purpose, to provide the assurance that materials carrying certification 
claims have not been contaminated or mixed (accidentally or intentionally) with material 
not carrying such claims. 

The question is if the traditional CoC systems used by most certification schemes provide 
this assurance to a level that allows an Operator to have confidence that such mixing has 
not taken place. 

An answer to this question needs to consider the original purpose of chain of custody 
systems. They have been set up to ensure that the claim of certification is transferred 
between  certified  entities, while ensuring that material that does not meet the sch eme 
requirements is not mixed into the product flow. However, the systems were not intended 
to provide traceability of the material back to the source of origin, or to provide verification 

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of volumes between entities. These can be seen as four distinct asp ects of the chain of 
custody: 

1.  Information about origin. 
2.  Avoidance of mixing within and between entities. 
3.  Transferring correct claim information. 
4.  Validation of transactions (volume, species and qualities) between entities.  

Most certification schemes have applied the chain of custody (CoC) certification as a way 
of addressing points 2 and 3 above. The purpose of CoC certification is to control certified 
material flows in each entity of the supply chain. This is intended to provide assurance for 
the  end  consumer  that  the  labelled  product  purchased,  conforms  to  the  rules  of 
certification schemes. This applies to many land use schemes including forest certification 
schemes. 

As the schemes have expanded, various types of risk to the CoC system’s integrity have 
also grown, and the CoC systems need to develop to provide assurance. Over the past 
years, concerns among stakeholders have been raised over the efficiency and integrity of 
CoC  systems,  partly  because  they  are  not  designed  or  implemented  to  identify  and 
address fraud.  

CoC auditing in timber supply chains is currently done through annual audits that normally 
include on-site inspection, sample control of documents and staff interviews. While this 
type of system is designed to verify compliance with system requirements, as well as to 
audit the volume data and conversion factors provided by the certified entities, it is not 
considered  to  be  well  adapted  for  detecting  fraud  in  exchange  of  materials  and  the 
volumes that are sold as certified.  

In  these  traditional  CoC  systems,  there  is  no  way  of  tracking  transactions  between 
certified  companies,  and  that’s  where  the biggest potential for double -dealing lies, by 
opening up possibility to manipulate volumes, qualities and species within a unit, with no 
real time ability for auditors to verify this information. 

Box 2: China – the complicated  mix. 

  China's unequivocal position as the workshop of the world is also prevalent within the global 
timber products industries. The country ranks as the largest timber importer in th e world. 
Over 60 per cent of tropical logs on the global market are imported to into China, with much 
of it being species at high risk of illegal harvesting or trade. A large proportion of the wood 
China imports is processed and then re-exported. According to the NGFA, China imported 
USD 83.72 billion and exported USD 815.6 billion worth of wood products in 2018, including 
imports  of  59.67  million  m3  logs  and 36.74 million m3 sawn timber. It is noticeable that 
approximately 17.5 per cent of total imported logs to China by volume and 45 per cent of 
total  imported  sawn  timber  by  volume  were  from  Russia  in  2019, adding further to the 
caution market participants should take when engaging in trades on this market.    

  Another part of the industry that carries a significantly elevated risk is composite products 
manufacturing. In 2015, the UK National Measurement and Regulation Office conducted 
tests on plywood coming from China. Results show that of the 13 samples tested, nine did 
not  match  the  wood  species  declared. Chinese authorities and the industry have been 
making  good progress towards curbing and reducing the illegal timber flowing in recent 
year.  However,  China's  timber  processing  sector  is  characterised  by  many  small  and 
medium-sized  enterprises  who  have  little  to  no  capacity  in  the  areas  of  supply  chain 

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management and traceability, due diligence, or the ability to identify the presence of illegal 
timber in their stock. Additionally, supply chains are usually a complex activity that adds to 
the challenge of tracing the origin of timber and identifying potentially illegal timber sources.  

  So, it is unsurprising that a notable proportion of wood material imported into China within 

timber-supplies found in the Chinese market are unknown origin and/or risk-profile.  

China's  governing  bodies  are    aware  of the issues in general and are introducing new 
control measures. For instance, a new forest law came into force in July 2020, which, to a 
degree, require due diligence of companies, although it is yet to be seen how  the statute of 
the law will be exercised. At present, China has only developed non -mandatory guidelines 
for domestic enterprises to implement stricter oversight over supply chain management for 
overseas  sourcing.  This leaves many Chinese companies in a pre carious position, with 
managers finding it necessary to forge documents to meet buyers' demand.  

Under  today’s  CoC  auditing  regimes,  a  certified  company  can  easily  manipulate  the 
system and hide this from the auditor although the audit is conducted with t he greatest 
care and according to all procedures. The company may be selling products containing a 
volume of ‘certified’ timber material that exceeds the volume of certified raw material that 
they are buying. They can do this in spite of the audit, who has no way of checking this 
except under very special circumstances.   

While still providing a level of assurance compared to non-certified material, manipulating 
CoC systems is relatively easy for those who wish to exploit the opportunity. T he truth is 
that  the  current  CoC  systems  will  be  highly  challenged  to  detect  issues with certified 
entities  which  are  deliberately  and  fraudulently  manipulating  their  data  on  volumes 
purchased/sold or production data (conversion factors etc). 

The results of this study also highlight the fact that only SBP, of the schemes evaluated, 
have developed traceability systems that include a way to conduct volume reconciliation 
between entities.  

SBP have developed an online platform for volume reconciliation and claims transfer – the 
SBP  Data  Transfer  System  (DTS).  In the DTS the initial biomass producer enters the 
volume supplied, and this volume cannot be changed. Volumes are always summarized 
by biomass producers for annual audits and audited. 

FSC  have  worked  on  developing  different  solutions  to  managing  supply  chains  for a 
number  of  years.  Their  Online  Claims  Platform  project  was  initiated  to  create  a  B2B 
volume  reconciliation  tool  but  was  never  implemented,  mainly  due  to  stakeholder 
concerns about data security. It has since been replaced by the Transaction Verification 
Procedure (FSC-PRO-10-201).15 The Procedure and associated guidance is intended to 
react  to  stakeholder  complaints,  suspicion  or  concerns  of  fraud  in  specific  sectors, 
geographies or within specific products or industries. Transaction verification involves the 
analysis of trade volumes within a sector and geography. This work is led by conducted 
Accreditation Services International (ASI) with the required support of Certification Bodies 
and certificate holders, by obtaining and analysing volumes and other transaction data. 
Transaction verification also includes the requirement for certificate holders to support 
fibre testing by surrendering samples and specimens of materials and information about 
species composition. 

15 https://fsc.org/en/supply-chains/transaction-verification#updates  

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The approach has been implemented on several supply chains, as can be  seen on the 
FSC  website.  FSC  has  developed a new advice note (ADVICE-40-004-18 Addressing 
deliberate  false  claims-  effective  6  April  2020 16).  The  advice  note  specifies  that 
Certification Bodies shall actively register any potential “false claims” identified  with F SC 
and  ASI  at  the certificate holder level. It also specifies the circumstances under which 
certificate holders will be “blocked for up to 5 years”, should investigations corroborate the 
false  claim(s).  The  blockage  of  a  certificate  holder  is  now  visible  on  the  public  FSC 
certificate holder database. Furthermore, certificate holders can be held financially liable, 
as  outlined  in  the  new Procedure: Calculating financial penalty/compensation fee and 
processing evidence for blocked organizations (FSC-PRO-10-003 V1-0 EN, valid 6 April 
2020).  

While both the Transaction Verification and the Advice on false claims are steps in the 
right  direction  to  address  the  issues  of  supply  chain  fraud  and  manipulation  of  the 
weaknesses  in  the  CoC  system,  they  are both  reactive to where issues are identified 
through  concerns  raised  by  auditors  or  complaints  received  from  stakeholders  or  by 
certificate holders themselves. Neither of them really addresses the actual problems of the 
CoC system weaknesses.  

OLB, ISO 38200 and PEFC entirely rely on a traditional CoC approach and without B2B 
volume verification.  

In SBP, all claims are transferred digitally in order to be valid. The system used is called 
DTS (Data Transfer System) 17 and is mandatory to use when selling and buyin g biomass 
with  SBP-claims.  In  the  system,  auditors  can  extract  summaries  of  transactions  and 
volume reconciliation. 

6.1 New approaches 

Several testing methods, such as stable isotope, DNA and wood anatomy, can provide 
information on origin or species of wood products. Stakeholders are increasingly using 
these methods to verify suppliers’ origin information. As these methodologies improve and 
become  more  cost-efficient,  they  will  most  likely play an increasingly important role in 
verifying species and origin information. 

Block  chain  technology,  combined  with  species  testing  may  also  be  considered  as  a 
potential tool to control volume data and basic information on species and origin in future 
CoC systems. Both FSC, Preferred by Nature, private operators, CAs and  others explore 
options to use this technology for volume and origin control in supply chains.  

In general, there is a strong need to rethink the entire Chain of Custody system to address 
the weaknesses related to volume fraud and mixing of certified with n on-certified material. 
So instead of implementing a CoC system, implementing a system that would provide the 
assurance of traceability in the supply chain could be implemented. A system that would 
allow and require B2B control of volumes, species, and qualities. Such systems contain a 
great deal of challenges given the level of complexity of production systems and material 
flows that may diverge and converge, all of this adding to supply chain complexities.  

16 ADVICE-40-004-18 Addressing deliberate false claims 

17 https://sbp-cert.org/data-transfer-system/  

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The  overarching  question  in  independent  certification  must  still  be  how  well  the 
certification  system  can  ensure  that  auditors,  and  the  accreditation  system  ensuring 
auditor integrity, maintain a high level of integrity, evaluate the actual performance in a 
consistent manner and maintain independence from the certificate holders.   

6.1.1 Use of non-certified material by certification schemes 

All  the  schemes  included  in  this  study  allows  some  form  of  non-certified  material,  in 
addition  to  recycled  materials,  to  be  mixed  with  certified  material  and  form  part  of  a 
certified product with a certified or mixed claim.  

The  Assessment  Framework  includes  evaluating  the  legality definition included in the 
schemes different versions of allowing non-certified materials to enter the supply chain in 
Sections number A1b and A2b.  

FSC  and  PEFC  both  have  specific  standards  based  on  a  risk-based  due  diligence 
approach to sourcing non-certified materials. SBP is also applying a risk-based approach 
and also includes an approach where certificate holders’ source FSC or PEFC certified 
materials. ISO 38200 is primarily a due diligence standard, using a risk-based approach 
and may also cover material certified against other certification schemes.  

OLB has a different approach to allowing non-certified material, as they allow material 
included  under  what  is  called  a  “Supplier  Verification  Program”.  Certificate  holders 
themselves implement this Supplier Verification Program. Even though the OLB standard 
requires minimum documentation checks and onsite audits by qualified (as defined by t he 
own company) staff, the quality and robustness of these assessments may vary. Also, it is 
not possible from the claim on verified material to identify which material is from 100% 
certified  areas  and  which  include  material  from  sources  covered  by  the  “Su pplier 
Verification Programme”. 

6.2 Definition  of  applicable 

legislation  applicable 

to  non-

certified material 

Both PEFC and FSC apply comparable systems to enable non -certified material to be 
mixed with certified materials – however there are fundamental differences in how these 
are implemented. 

PEFC uses a due diligence approach within its CoC standard, which is mandatory for all 
certificate  holder  to  apply,  in  the  case  of  non-certified  materials.  Under  this  system, 
certificate holders can source non-certified material and mix with certified material when 
the non-certified materials are found, according to the risk assessment process, to meet 
the ‘PEFC Controlled Sources’ requirements. The Controlled Sources requirements do 
include requirements to exclude materials originating from illegally harvested and traded 
sources, as follows: 

“a)  Activities  not  complying  with  applicable  local,  national  or  international 
legislation on forest management, including but not limited to forest management 
practices;  nature  and  environmental  protection;  protected  and  endangered 
species;  property,  tenure  and  land-use  rights  for  indigenous  peoples,  local 
communities or other affected stakeholders; health, labour and safety issues; anti -
corruption and the payment of applicable royalties and taxes.” 

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The  study  found  that  the  PEFC  Controlled  Sources  system  only  partially  covers  the 
applicable  legislation  at  the  forest  level  of  the  assessment  framework  and  has  some 
significant gaps that should be noted. (See below the discussion on the implementation of 
the  risk  assessment  process  used  by  schemes  to  reduce  the  risk  of  non -compliant 
material entering the supply.) However, PEFC Controlled Sources does not contemplate 
at all risks of legal non-compliance in relation to trade and transport in the supply-chain. 

FSC implements the Controlled Wood system. This system is a mandatory due diligence 
process  that  sits  apart  from  the  FSC  Forest  Management  and  CoC  standards.  The 
Controlled Wood system can be applied both by forest managers, as a forest  certification 
standard, or it can be used through a risk-based process by CoC certified entities sourcing 
wood materials. 

In terms of the FSC Controlled Wood standard definition, it was found that the standard 
and  the  risk  assessment  framework  contain  a  legality  definition  that  fully  covers  the 
requirements  of  the  Assessment  framework  at  the  forest  level.  However,  the  FSC 
Controlled Wood system is still not fully aligned with EUTR, in that it does not contemplate 
risks of legal non-compliance in relation to trade and transport in the supply-chain. 

OLB also allows non-certified timber through their Supplier Assessment programme. T his 
system is based on suppliers conducting their own evaluation of legality based on the 
OLB CoC standard criteria. It is based on the verification of a set of criteria to be assessed 
at the forest level. Therefore, it is required that the company implementing the Supplier 
Evaluation Program is close enough to the forest or that it can prove traceability from the 
intermediaries to the forest level.  

Only a list of criteria is provided in the standard, without clear indicators or guidance to 
ensure  that  Certificate  Holders  consistently  implement  it  and objectively evaluated by 
Bureau Veritas auditors.  

Both ISO 38200 standard and the SBP scheme allow material from other schemes to be 
included as part of material covered by the scope of their standards. In this case, any 
material  from  non-certified  forest  from  other  schemes  included  can be mixed into the 
certified material stream. 

6.3 Quality  of  due  diligence  systems  or  risk  management  of 

the non-certified  materials 

Related  to  the  above  issues  of  how  well  schemes cover specific and detailed legality 
categories in the non-certified material inputs, the quality of the process surrounding the 
implementation of risk-based approaches to allowing non-certified material into certified 
material stream is considered.  

Important lessons about the integrity of the use of non-certified material, through a risk -
based approach, have been made by FSC. FSC was one of the first certification schemes 
to implement the use of “mixed” claims. They did this by allowing non-certified material to 
be mixed with certified material through a policy on allowing “Percentage Based Claims”. 
Non-certified  material  was  required  to  NOT  have  originated  from  what  is  called 
Controversial Sources”.  

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Controversial Sources include: 

A.  timber of illegal origin 
B.  timber harvested in contravention of local and international forestry legislation  
C.  timber extracted without payment of appropriate taxes and royalties 
D.  timber extracted without the knowledge or permission of land owners 
E.  genetically modified timber 
F.  timber resulting from the conversion of certified forest to other land uses.  

The  initial  Controlled  Wood  system  of  the  FSC  was  primarily  based  on  the  ability  of 
companies to conduct their own risk assessments and their own verification of the risks on 
the ground. The system was found to have a range of challenges including:  

1.  An inconsistent interpretation of the requirements in the Controlled Wood Standard 

by certificate holders, as well as by certification bodies 

2.  Difficulty in tracking wood back to the forest of origin using invoices and shipping 

documents 

3.  A low level of stakeholder confidence in company-developed Risk Assessments 

and in company field verification in areas of “unspecified risk” 

4.  An inconsistent level of verification and enforcement by CBs and ASI 
5.  Limited transparency 

(FSC, 2011) 

These findings clearly point to challenges of systems where companies are tasked with 
conducting their own risk assessments and their own verification. Also, the finding that 
certification bodies and the accreditation body (ASI) had challenges in interpreting the 
requirements consistently underline that such systems are complex and require clear and 
comprehensive rules and definitions.  

FSC has since revised their CW system significantly and have developed national and 
centralized risk assessments (developed by FSC International or national FSC offices, 
according to set rules and procedures) and revised the certification standards to create 
less room for interpretation, which is considered to have a higher level of integrity and 
transparency than previous system. 

However,  the  findings by FSC in 2011 of their own evaluation of the Controlled Wood 
system might be considered still relevant today, to other schemes who have developed 
and  implemented  comparable  systems.  The  challenges  listed  above  for  FSC  back in 
2011,  could  be  considered  relevant  for  schemes  who  are  still  implementing  a  less 
developed system for allowing non-certified material to be mixed with certified, such as 
OLB and PEFC. This is particularly the case, when it comes to:  

  ensuring a consistent interpretation of the requirements of the DDS procedures, by 

certificate holders, as well as certification bodies; 

  having confidence in company-developed Risk Assessments and in company field 

verification; 

  ensuring consistent level of verification and enforcement by CBs; and,  
transparency in relation to risk assessment results and procedures 
 

For OLB, this study has also highlighted that the Supplier Verification Programme used t o 
allow non-verified material into the certified supply chain is considered inadequate to meet 
or  align  with  the  EUTR.  Also,  the OLB system does not allow buyers to identify which 
materials  or  products  may  originate  from  OLB  verified  sources  or  from  non -verified 
sources  evaluated  by  the  suppliers  themselves,  through  the  Supplier  Evaluation 

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Programme.  This  indicates  a  significant  gap  in  the  OLB  scheme,  signifying  a  lack  of 
alignment with the EUTR. 

PEFC  implements  the  Controlled  Sources  system,  as  part  of  their  due  diligence 
requirements in the Internationally applicable CoC standard. This allows certificate holders 
to  implement  a  risk-based  approach  to  sourcing  non-certified  material  and  mix  with 
certified materials.  

The gaps identified in the legality definition, resulted in the conclusion that it is not fully 
aligned with EUTR. The Controlled Sources system of PEFC has, apart from this, further 
challenges.  

The DDS procedures defined in the COC standard are formulated in a way that it is not 
clear that the system will always capture risks. The following observations are made on 
the process to conduct the risk assessment within the PEFC due diligence system:  

  The  DDS  risk  indicators  allow  those supplies verified by governmental or non-
governmental verification or licensing mechanisms (other than forest certification 
systems)  can  be  considered  as low risk, as long as they address the activities 
covered by the term controversial sources. However, there are no requirements or 
guidance  on  what  basis  –  or  how  -  the  schemes  shall  be  evaluated  by  the 
certificate  holder  other  than  that  they  cover  the  activities  included  in the term 
controversial sources and are covered by third-party certification.  
It is not clear how the DDS would be able to detect all risks within supply chains in 
line with the definition of negligible and non-negligible risk as outlined in the EUT R 
and prohibition of illegal material or material with a non-negligible risk category. As 
examples, the following issues are observed:  

 

1.  There is no clear definition of the term ‘significant risk’. 
2.  Table 1, point c) of the table considers as negligible risk wood coming from 
sources  with  “documents,  including  contractual  agreements  and  self -
declarations, or other reliable information indicating that products do not 
originate  from  controversial sources”. Scenarios may exist that allow for 
wood sources to be considered as negligible risk even though risks exist. 
E.g., in relation to tenure rights. It is not always possible to ascertain a risk 
conclusion from such documents, or even from documents alone. 

3.  A low-risk conclusion may be possible in some cases where this may not 

be warranted. For example: 

  Table  2  a)  I-IV,  can  be  used  to conclude negligible risk of wood 
from countries where the CPI is 50 or higher. This may lead to false 
conclusions as illegality risks may also be found in countries with a 
CPI  above  50.  An  alternative  database that is cited includes the 
World  Justice  Project  (WJP)  Rule  of  Law Index. Again, countries 
with  a  score  lower  than  0,5  may  also  contain  illegality  risks. 
Examples  include  India  and  Thailand,  both  with  a score of 0.51. 
PEFC  includes  a  note  that  “These  indices  might  not  always  be 
appropriate for forestry. Where more appropriate indicators exist, 
these can be used with a prior agreement with the PEFC Council. 
These  alternative  indicators  will  be listed in the chain of custody 
guidance document”. 

  Table 3 (List of indicators for significant risk at supply chain level) 
includes  in  c)  as  a  significant  risk  indicator,  evidence  of  illegal 
practices concerning controversial sources by any company in the 
supply  chain.  However,  again,  the  definition  of  controversial 
sources  only  applies  to applicable local, national or international 
legislation on forest management and does not make reference to 

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the  trade  and  transport  laws.  So,  there  is  no  requirement  to 
consider a supply-chain entity that had been sanctioned for illegal 
trading of wood-products, for example. 

The PEFC due diligence system, and in particular the methodology to score risks, is seen 
as being too open to interpretation and may allow users to arrive at a false “negligible risk” 
conclusion. 

As can be seen from the above, the nature and extent of due diligence processes within 
certification schemes can vary considerably and warrants attention by Operators as to 
both their strengths and potential shortfalls in their robustness. 

7.  Reclaimed material 

One issue where inconsistencies appear to remain, between the EUTR and some of the 
certification schemes, relates to the use of reclaimed and/or recycled materials. 

The  following  resources  are  available  from  the  European  Commission  in  relation  to 
reclaimed material: 

  EU Timber Regulation (995/2010) 18  
  EUTR Guidance document on Recycled timber and timber products 19  

The EUTR excludes,  from the requirements to conduct due diligence, waste materials. 
The EUTR defines reclaimed materials as follows: 

 

 

“Article 2 (a) 'timber and timber products ' means timber and timber products set 
out  in  the  Annex, with the exception of timber products or components of such 
products manufactured from timber or timber products that have completed their 
lifecycle and would otherwise be disposed of as waste, as defined in Article 3(1) of 
Directive  2008/98/EC  of  the  European  Parliament  and  of  the  Council  of  19 
November on waste. 
' Directive 2008/98/EC Article 3(1) ' 'waste ' means any substance or object which 
the holder discards or intends or is required to discard.'” 

The EUTR does not use the specific wording for recycled raw materials that is often used 
by certification schemes (namely pre- or post-consumer reclaimed material). However, the 
EUTR  Guidance  document  on  Recycled  timber  and  timber  products  reinforces  the 
EUTR’s  exemption  only  for  material  generated by end users of a product that can no 
longer  be  used  for  its  intended  purpose  –  a  post-consumer  reclaimed  definition  - by 
describing that this exemption: 

 

“applies  to  timber  products  of  a  kind  covered  by  the  Annex,  produced  from 
material  that  has  completed  its  lifecycle  and  would  otherwise  have  been 

18 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32010R0995  

19 https://ec.europa.eu/environment/forests/pdf/Guidance%20 -%20Recycled%20timber%20and%20timber%20products. p d f   
EUTR Guidance document on Recycled timber and timber products: “By-products” from another production are  n o t wa st e  
but are to be regarded as a raw material in the production. Material in a regulated timber prod uct is not recycled materi a l i f  
the material is the by-product of a manufacturing process. Example: Sawdust or off-cuts from sawn tim b e r u se d  t o  m a ke  
particle board or medium density fibreboard. 

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 

disposed  of  as  waste  (e.g.,  recycled  paper,  timber  retrieved  from  dismantled 
buildings, or products made from waste wood)”.  
“does  not  apply  to  by-products  of  a  manufacturing  process  that  involves 
material which has not completed its lifecycle and would otherwise have been 
discarded”. 

Providing some scenarios as an example, the Guidance document describes that:  ““By-
products” from another production are not waste but are to be regarded as a raw material 
in the production. Material in a regulated timber product  is not recycled material if the 
material is the by-product of a manufacturing process”. The following examples are given: 
“Sawdust or off-cuts from sawn timber used to make particle board or medium density 
fibreboard”. 

This study shows that all, except OLB, include a definition of reclaimed materials. 

SBP and ISO 38200 all apply a definition of reclaimed or recycled materials that are in line 
with the definitions of the EUTR – in that they only allow post-consumer recycled material 
into the definition.  

The study of PEFC and FSC schemes concluded that there was not alignment between 
these  scheme’s  definitions  of  reclaimed  material  and  the  EUTR.  As  a  result,  some 
material  deemed  as  reclaimed  by  the  schemes  may  in  fact  be  subject  to  EUTR 
requirements. 

In the case of PEFC, material deemed a by-product of a manufacturing process is not 
considered  exempt  from  the  EUTR  due  diligence  obligation.  The  PEFC  definition  of 
recycled material is found in standard PEFC ST 2002: 2020, 3.35) and   has two parts. 
Part a) describes material recovered from waste during a manufacturing process, correctly 
excluding certain types of material that would not be considered as waste according to the 
definition of the EUTR. Examples of excluded material from the definition include materi al 
capable of being reclaimed within the same process that generated it, and by -products 
resulting from primary production processes. Part b) describes material that can no longer 
be used for its intended purpose would be considered as waste according to t he definition 
of the EUTR. This includes material generated by households or by commercial, industrial 
and institutional facilities in their role as end users of the product that can no longer be 
used for its intended purpose.  

The  combination  of  parts  a)  and  b)  appear  to  define  residues  from  secondary 
manufacturing processes as reclaimed material. However, given the descriptions within 
the guidance, it is not clear that such material is necessarily exempt from the EUTR.  

The FSC scheme’s definition of post-consumer reclaimed material  – and the examples 
given in Annexes I and II (pages 10/11 of the Reclaimed Standard, FSC-STD-40-007) – 
appear to overlap with the definition described in the EUTR, as any material described 
would have: i) completed its lifecycle AND ii) would otherwise be disposed of as waste. 
However, FSC descriptions of pre-consumer reclaimed material described in Annexes I 
and II are more nuanced and the evaluation of the scheme concluded that some materials 
are  included  within  the  scope of the EUTR, based on the consideration that while the 
materials  may  have  been  disposed  of  as  waste,  they  may  not  have  completed  their 
lifecycles. Some examples include: 

  …discontinued items not used for their intended purpose. 
  Offcuts,  shavings,  sawdust,  and 

the 

like,  generated  during  secondary 

manufacture…. 

  Some of the paper scrap example materials for Annex II 

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FSC  itself  has  commented  on  this  issue 20:  “FSC  considers  “pre-consumer  reclaimed 
materials from secondary manufacturing” as waste…However, the EU defines part of this 
(e.g. sawdust, wood chips, off-cuts from untreated wood) as by-products for which the 
legality of harvesting needs to be investigated.” FSC thus acknowledges the gap, and the 
guidance goes on to state: “This problem does not exist for reclaimed materials coming 
from  primary  manufacturing,  because  both  FSC  and  the  EUTR  consider  these  co -
products, for which the origin is verified as from certified sources or as controlled wood.   

However, in the above mentioned FSC guidance describes how  “the problem does not 
exist for recycled paper or paper scrap, as these are explicitly excluded from the scope of 
the EUTR.”. 

8.  General requirements for certificate holders 

The  Assessment  Framework  used in this study also included evaluation of aspects of 
certification  related  to  requirements  placed  on  certificate  holder  regarding  conflict 
resolution and management of corruption. These requirements lie outside specific legality 
definitions, and quality management of certification implementation, but are essen tial to 
ensuring responsible practices by certificate holders. They are a key factor, when it comes 
to illegalities perpetrated in the forest sector is hampered by corruption.  

The issues are addressed in the Assessment framework part A4 and A5. 

8.1 Corruption 

Transparency International defines corruption broadly as “…the abuse of entrusted power 
for private gain”. Corruption may range in forms, from direct payment of bribes to different 
types  of  conflict-of-interest  situations.  Examples  may  range  from:  public  servants 
demanding  or  taking  money  or  favours  in  exchange  for  services; politicians misusing 
public money or granting favours, such as contracts, licences or access, to their sponsors; 
friends and families, or corporations bribing officials to ob tain lucrative deals or special 
advantages outside of normal processes. 

The key is that corruption can be used as a way for forest sector operators to act in non -
compliance with the law to increase their profitability or ability to compete and operate. As 
a clandestine activity, corruption is hard to detect, as corporations may have all the correct 
licenses, permits and documents in place, even if these has been issued with the use of 
corrupt practices. 

Most  schemes  require  certificate  holders  to  follow  the  law,  but  there  are  only  limited 
requirements that address corruption and evaluate the risk of corruption by certificate 
holders. To differing extents, audit practices focus on the availability of legally required 
documents, licenses or permits, as a proxy for ensuring legal compliance. However, given 
the  challenges  in  detecting corruption as described above, as well as natural limits of 
resources  or time which can be channelled into the audit process, this may inhibit the 
ability  of  the  auditor  to evaluate how such documents have been issued and whether 
there are any indications that due processes have not been followed or that corruption 

20 https://ic.fsc.org/file-download.eu-timber-regulation-implementation-guide.a-13.pdf  

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may be at play. This is an important point in relation to the EUTR, and even relevant in 
relation to non-certified supplies: operators are often provided with documents to show 
compliance  with  applicable legislation. Experience shows that such documents can be 
prone to fraud and corruption, particularly in countries with low levels forest -governance or 
high corruption. 

As  seen  in  the  examples  in  the  Box  3,  malpractice  by  companies,  under  cover  of 
corruption,  may  take  many  shapes  and  forms.  It  may  include  operating  under  illegal 
licenses, or under inadequate permits and procedures allowed by bribing officials. It may 
include  overharvesting  or  harvesting  of  areas  or  species  not  legally  permitted  for 
harvesting.  It  may  include  illegal  imports  of  timber  from  abroad  or  export  of  illegally 
obtained materials. 

The challenge for certification schemes is to include detection of such corrupt practices in 
their auditing – a very difficult undertaking, as corruption is obviously rarely done openly. It 
is underlined that the challenges of corruption are applicable also for material not sourced 
with a certification claim, and that certification scheme in most cases add some level of 
evaluation  or  precautions  in  this  regard,  that  does  not  exist  without  the  certification 
system. 

Box 3: Romania  – domestic  disturbance to the EU's timber supply  chain 

Romania is regrettably claiming a prominent position on timber legality issues am ong  the 
EU-27.  The  country's  abundant  forest resources have been harvested for millennia to 
benefit its domestic users and neighbouring buyers.  

Much  to  the  concern  of  monitoring  organisations,  recent  revelations  have  uncovered 
fraudulent  behaviour  by  international  corporations  headquartered  amongst  fellow  EU 
member  states.  The  Romanian  State  authorities  and  non-governmental  organisations 
have investigated several FSC or PEFC certified enterprises for including illegal wood in 
the  supply  chain.  More  alarming  is  the  Romanian  authorities  inadequate  action  on 
preventing such criminal activities, as recognised  in a letter of formal notice** presented 
by the EC to the Government of Romania in February 2020. 

Scholars found in a survey on timber legality issues that 54% of identified non -conformities 
constituted  a  violation  of national laws. Illegalities in harvesting operations is an obvious 
place  to  focus  risk  mitigation by improved supply chain management by relevant actors, 
but  also  recognised"…  the  Romanian  exhaustive  legal  frameworks  with  no  flexibility  in 
terms  of  compliance  coupled  with  the  governmental  enforcement  failures  create a risky 
business environment for the companies operating in the forest industry."   

Despite Romania's shortcomings in timber legality, the country is making positive progress 
on  several  key  issues.  For  example,  it  boasts  the  "Wood  Tracking" information system, 
which  gives  its  users  an  opportunity  to  track wood  products  in  real-time  through  GNSS 
technology. The IT system vastly improves the accountability of the timber trade industry's 
future. 

FSC  have  implemented  changes  to  their  standards  to  include  requirements  that 
organisations  have  in  place  anti-corruption  measure.  These steps are outlined in the 

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report  “FSC  &  Corruption”  from  2017 21.  FSC  is  also  implementing  a  risk  based  due 
diligence approach to evaluating applicant for FSC certification. Applicants are requested 
to submit as self-evaluation. In certain cases where the applicant has other non -certified 
holdings and is in a country with a high perceived level of corruption, FSC will conduct  
additional screening against the FSC Policy of Association. 

PEFC does not have a “policy of Association” but implements a procedure to receive and 
manage complaints at all levels of the certification process.  

Through  such  measures,  certification  has the  potential to address corruption through 
several levels of the scheme implementation. 

Firstly, schemes can include direct requirements to ensure that licenses, right of tenure 
and management rights, have been issued according to the legally prescribed proce dure 
and  with  absence  of  corrupt  practices.  In  the  study,  only  FSC  and  SBP  normative 
requirements  conformed  fully  to an indicator on this topic. FSC and PEFC specifically 
require that the Certificate Holder shall comply with anti-corruption legislation whe re this 
exists. In the absence of anticorruption legislation, FSC requires the Certificate Holder to 
“implement  other  anticorruption  measures  proportionate  to  the  scale  and  intensity  of 
management activities and the risk of corruption”. Others schemes partially covered this 
topic only. 

Secondly, as a general requirement for all certificate holders, the scheme can include 
requirements to ensure that certificate holders do not engage in corrupt practices related 
to illegal harvesting. In the study, the certification schemes addressed this requirement to 
greater or lesser extents, with some notable exceptions (ISO 38200)  

Thirdly, schemes can include mechanisms to identify - or for the Certification Body to do 
so  -  companies  sanctioned  for engagement in corrupt  practices relevant to the forest 
sector. Remarkably, none of the schemes evaluated have in place any active system or 
procedure, to identify sanctioned companies. In the case of FSC, mechanisms exist which 
could  identify  and  deal  with  corrupt  practices  by  Certificate  Holders:  the scheme has 
procedures  for  processing  complaints,  which  can  be  used  for  complaints  regarding 
corruption of organisations already associated with FSC. Furthermore, a clause within its 
Policy  of  Association  states  that  FSC  shall  conduct  due  diligence  “to  evaluate  the 
existence of objective evidence that an organization is directly or indirectly involved in any 
of the unacceptable activities” prior to entering into an association with them. However, 
despite the above there are no normative requirements or formal processes, for identifying 
organisations sanctioned for engagement in corrupt practices proactively or otherwise, 
and prior to (or post) association with FSC. 

Finally, within Forest certification schemes, contact between stakeholders can be fostered 
at two levels: via the implementation of a clear and transparent complaint mechanism and 
by robust stakeholder consultation. Stakeholder consultation – if carried out effectively – 
can serve as a tool to widen the opportunity to capture corrupt practices. It raises the 
opportunity to capture issues and allow the limited time and financial resources available 
to conducting audits to be targeted or focussed to where concerns may arise. 

All schemes – with the exception of ISO 38200 – have complaints mechanisms in place, 
although perhaps with varying levels of transparency and robustness. Most schemes  – 
again with the exception of ISO 38200 – include processes for stakeholder consultation. 

21 https://dk.fsc.org/preview.hvad-gr-fsc-for-at-forhindre-korruption.a-1591.pdf  

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However, the extent and use of stakeholder consultation varied. FSC requires that CBs 
conduct stakeholder consultation for Forest management certificates as well as for entities 
implementing  controlled  wood  due  diligence  systems.  PEFC  has  requirements  for 
stakeholder consultation in case of forest management certification. However, although 
the requirement applies to all countries it appears that it is not followed by all assessed 
national standards. For chain of custody, there is no requirement to conduct stakeholder 
consultation. 

The  role  of  environmental  NGOs  and  civil  society  organisations  is  not  to  be 
underestimated  in  raising  issues  of  malpractice  and  corruption  in the forest sector to 
certification schemes. NGOs focused on forest certification can engage in whistleblowing 
when they perceive social and/or environmental criteria to be compromised by a particular 
certificate  holder  –  this  is  a strong measure that has been shown to function through 
critical review of specific certification examples. One may discuss the effects on certificate 
implementation  overall,  but  investigations  and  the  exposure  of malpractices by CSOs 
shows that external monitoring of scheme implementation can help by identifying scheme 
failures.  

Such  interventions  could  be  viewed  as  one  way  of  controlling  corruption  when  new 
certificates are issued in poor governance settings. Yet those forest managers who are 
first to engage in certification in poor governance settings are unlikely to be a mong the 
worst offenders in corruption terms, and indeed may be among those most motivated to 
raise forest management standards.  

The annual audit process forming part of certification procedures offers a relatively regular 
local check on forest management practices in certified areas. This practice is likely to 
reduce  certain  types  of logging activity (potentially facilitated by corruption) which are 
contrary  to  the  established  scheme  criteria.  “Clear -cutting”  trees  in  a  certified  area 
contrary to the agreed criteria would, for instance, probably be made visible through such 
audits.  However,  evidence  shown  above  indicate  systemic  issues  in  schemes  that 
indicates  challenges  of  the  audit  process  to  address  certain  types  of  malpractice  by 
certificate holders.    

9.  Requirements for certification bodies 

An integral part of a certification schemes is the functioning of the certification bodies. A 
certification  body  is  an  independent  organisation  that  evaluates  conformance  of 
companies  to  the  requirements  of  the  applicable  standards.  Certification  bodies  are 
usually accredited by an accreditation body, either at a national level or at an international 
level. 

FSC and SBP collaborates with an international accreditation organisation called ASI, who 
is responsible for accreditation of all FSC and SBP CB’s worldwide, while PEFC relies on 
national accreditation organisations to accredit certification bodies at a national level.  

The Assessment framework includes assessment of requirements on certification Bodies, 
by each of the schemes in section B. 

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9.1 Conflict of interest 

An  often-cited  criticism  of  certification  schemes  is  that  the  certificate  holders  pay 
certification bodies for the auditing. While this is true, there is limited evidence that this 
relationship  between  certificate  holders and their auditors should particularly inflict on 
auditors'  independence  directly.  Auditors  are  used  to  verify  other  types  of  business 
performance, such as e.g. financial accounts, and these systems do seem to work.  

There  is  perhaps  a  higher-level  argument  about  certification  regarding  the  efforts  of 
certification schemes to be competitive in a market with competing schemes. Questions 
have been raised as to the objective of certification schemes to secure clients to remain 
competitive, thus allowing or ignoring non-conformances among clients to maintain the 
volume of certificates and area under certification. 

In national certification schemes, such as those operating under PEFC recognition, the 
issue  of  conflict  of  interest  could  be  argued  to  be  even  more  relevant.  In  the  PEFC 
scheme  the  certification  standard  is  often  developed  and  managed  by  the  national 
government. An example is the Belarus PEFC national scheme. In Belarus, the standard 
is developed by State entities and managed by the ministry of Forestry. The accreditation 
is managed by the Belarusian State Center for Accreditation. There is a single accredited 
Certification Body, which the Ministry of Forestry also governs, and certificate holders are 
state forests. Even if these entities operate according to specific procedures for their roles 
in certification, it is clear that conflict of interest could likely arise from an apparent lack of 
independence. 

10.  Scheme Governance 

Scheme  governance  requirements  of  this  study’s  Scheme  Assessment  Framework 
include issues such as transparency, scope of the standards used, accreditation of CBs 
and certification process management.  

This aspect of the study is covered in the Scheme Assessment Framework Section C. 

Schemes  differ  in  their  level  of  transparency,  some  aspects  of  which  are  extremely 
important to allow operators, competent authorities, and other organisations to evaluate 
the applicability of the certification scheme to their due diligence concerns.  

A  good  assurance  system  must  also  have  detailed  and  consistently  implemented 
procedures  to  handle  appeals  and  complaints.  Appeals refer to the possibility for the 
(applicant) certificate holder to obtain the reconsideration of a cert ification decision taken 
by the certification body. The Complaints procedure refers to permitting the expression of 
dissatisfaction  over  the  functioning  of  a scheme, scheme-related entities (certification 
body, accreditation body) or scheme participant (certificate holder).  

Schemes also differ in their approaches to standard setting and the level of transparency 
that comprises the standard-setting process. Furthermore, schemes can range in the level 
to which stakeholders are able to influence, participate in or support the standing setting 
process. 

Management of certification bodies refer to the process by which the scheme ensures that 
certification bodies providing certification against scheme standard ensure a consistent 

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approach to evaluation of conformance and how certification bodies operate to secure the 
integrity of the scheme.  

The  requirements  put  on  certification  bodies known as the accreditation process, are 
evaluating and approving certification bodies to function under the Scheme rules. The 
goals  of  providing  robust  and  objective  assessments  implies  consistency  over  time, 
locations and between certification bodies (two similar situations shall be assessed the 
same way – with similar audit conclusions reached – independently of the time, location,  
and auditor in question). Many approaches for calibration, guidance, or interpretation, 
have been employed by certification schemes to prevent or rectify threats to credibility and 
objectivity – in line with ISO or ISEAL guidelines.  

Even  where  a  certification  scheme  does  not accredit independent certification bodies 
(such  as  where  the scheme owner is also the auditing organisation, as in the case of 
many timber-legality certification schemes) an oversight system will be applied to ensure 
the continued competence and performance of certification auditors to carry on conformity 
assessments to a particular standard (in short, measures to monitor the integrity of the 
audit process).  

Schemes usually include some requirements to ensure that certification bodies and their 
auditors, and other personnel relevant to the conformance evaluation of an organisation, 
are impartial to the entities under evaluation. Risks to impartiality and conflicts of interest 
can be prevented and monitored in various ways. 

10.1  Conformance  or performance 

The auditing of certificate holders, and the accreditation requirements for CBs, are in most 
certification schemes based on ISO standards. Both PEFC and FSC uses ISO standards 
as a basis for development of their accreditation systems. In FSC accreditation is done by 
ASI at an international level, while in PEFC accreditation is done at national level by local 
accreditation bodies. 

ISO standards are primarily seen as focused on systems and existence of procedures to 
manage such systems. While an important aspect of implementing activities, both at forest 
level, but also in the auditing and certification process, in a consistent and documented 
way, the culture of considering all requirements of a standard as equally important, seems 
to  have  shifted  focus  away  from  the  actual  performance  on  the  ground  –  the  real 
achievements  of  responsible  forestry,  towards  focus on being in conformance with all 
procedural and documented requirements of the standards.  

The result of the ISO approach is that CB auditors need to spend more time on checking, 
double  checking,  and  triple  checking  documents  to  ensure  that  nothing  is  forgotten, 
instead of focusing on verifying management performance in the forest. 

The approach thus forces the CBs to focus on non-essential issues when they carry out 
client auditing, and thereby also forcing certified companies to spend considerable time 
and  resources  on  maintaining  and  updating  administrative  systems,  which  is  likely to 
detract from the actual performance of the organization. 

A  record  documenting  the  fact that a training occurred becomes more important than 
ensuring  that  the  staff  understand  their  obligations;  a  date  on  the  risk  assessment 
becomes  more  important  than  the  content  of  the  risk  assessment;  a  map  of  HCVF 

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becomes more important than the management of the HCVF; a list of group members in 
the FSC database becomes more important than whether the group is certifiable.  

Solving  this issue would require certification schemes to re -focus standards on critical 
performance  issues  of  the  certificate  holders,  as  well  as  ensuring  that  auditors have 
strong  competencies  in  evaluating  performance  issues,  rather  than  evaluating  the 
existence of procedures and systems. 

Box 4: Russia/Ukraine  – illegal logging at EU's doorstep 

The  Russian  Federation  and  Ukraine  account  for  a  dominant  part  of  EU's  annual 
consumption of timber products, but accountability is missing in a significant proportion of 
it.  

Amongst  important issues is the exploitation of sanitary felling permits. While  a sanitary 
logging  permit  may  be  entirely  legal  , forest  managers across  Ukraine  and  Russia 
are widely suspected of inflating the size of impacted areas to increase their allowance for a 
higher  profit.  The discrepancy  between what  is  harvested  out  of  nece ssity and what is 
actually  being felled, is very hard to document, according to Preferred by Nature's own 
research. Corruption within the agencies tasked to issue the permits is also a plausible 
cause for inappropriate timber sourcing based on sanitary felling permits.   

With the proliferation of third-party timber auditing schemes such as the FSC, some of the 
illegal logging taking place might have been curbed. Though there are still plenty of gaps 
to slip through. "Personally, I am not confident that all the sanitary logging done by FSC 
certified companies is good sanitary logging that makes sense in terms of fighting pests. I 
am sure all the official paperwork these FSC certified companies are producing is fine. 
However, there is legality in terms of official documents, and there is legality in terms of 
common  sense,"  said  Nikolay Shmatkov, director with FSC in Russia. The country has 
become the world's number one FSC certified area with more than 53 million hectares of 
FSC certified forest.   

Despite auditing schemes such as the FSC appear to positively affect prospective timber 
traders'  ability  to  perform  due  diligence  as required by the EU Timber Regulation, the 
challenge ultimately lies with weak institutions and an absence of policing the law in both 
countries. "We are, of course, particularly attentive to any signs that the documentation has 
been  tampered  with.  We  can,  for  instance,  check  that  the  actual  state  of  the  forest 
corresponds  with  the  data  in the  documents. However, if the whole system is cor rupt, it 
becomes more difficult," said Justinas Janulaitis, Director of Traceability at Preferred by 
Nature. As a direct consequence of the legality challenges, the number of FSC certified 
forest  units  has  grown  to  around  four million  hectares  in  Ukraine  a lone.  Although  the 
certification boom has undoubtedly improved Ukrainian forestry, certification schemes have 
their blind spots too by design as FSC is based on voluntary participation and itself does 
not provide compliance with the EUTR. "If someone wants to commit fraud intentionally, 
they  can  do  that  very  easily  by  making  two  copies  of  the  sales  invoice. One 
with incorrect information  regarding  FSC  status,  which  they  send to the customer, and 
another one, without FSC claims, which they show to us," noted  Mr. Janulaitis. 

10.2  Conformance  evaluation  allowing  for improvement 

Most  schemes  operate  with  a  similar  approach  to  addressing  non -conformances  by 
certificate holders or applicants to be certified. During assessments auditors may identify 
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where the auditee  is not meeting a specific requirement and issue a non-conformance 
report (NCR), as either a major or a minor issue. Based on the NCR the certification body 
will  then  formulate  a Corrective Action Request (CAR) outlining the specific corrective 
actions the organisation under evaluation will have to conduct, as well as the timeline  – 
depending on the grading as either major or minor there will be a set timeline to act and 
show conformance, from 3 to 12 months.  

Certificate holders are thus allowed to remain certified where both minor and major non -
conformances  are identified if they address these within the allotted timeline. Such an 
approach would not be in line with the EUTR, where a non -compliance with applicable 
legislation  is  considered  to  constitute a risk. It should be mentioned that cases where 
procedural changes are needed to ensure improved performance could be considered low 
risk. 

A study published in 2019 (Buliga and Nichiforel 2019) analysed corrective actions issued 
by FSC auditors in Romania. The study evaluated how much of the Forest Stewardship 
Council (FSC®) standard used for forest management certification is contingent on legal 
rules,  and  it  was  concluded  that  69%  of the standard requirements are addressed in 
national  legislation.  The  authors  also  evaluated,  from  a  legal  perspective,  the  non-
conformities  identified  between  2008  and  2017  in  the  108  FSC  audit  reports.  They 
document  that  de  facto,  the  implementation  of  the  legal  system  faces  essential 
enforcement problems since 54% of the identified non-conformities represent a violation 
of  laws.  The  three  main  non-compliances  with  the  legal  requirements  are  related  to 
harvesting operations. 

Other studies have conducted comparable analysis of nonconformities, primarily based on 
FSC data (Trishkin et al. 2015; and Aureliu-Florin, et al 2016). Both evaluated the number 
and distribution of NCRs over the different principles of the FSC standard in Russia and 
on other European countries. They arrived at similar conclusions related to the aspects of 
certification  responsible  for  most  NCRs.  Most  or  around  50%  of NCRs are issued for 
Principle 6 (Environmental impact) of the FSC standard, while around 10% of all NCRs 
are issued for legal compliance as covered in Principle 1 (Compliance with the laws and 
FSC  principles).  Note  that  the  studies  are  based  on  the  former  version  of  the  FSC 
standard, which did not include as detailed a legality definition as the current version.  

The  evidence  discussed  above  indicates  that  the  procedure  for  addressing  non -
conformances  in  certification  may  mean  that  certificate  holders  are  in  fact allowed to 
operate even where legal non-compliance may have been identified. Such a system may 
in fact mean that some timber is certified even where legal non-compliances are present, 
in which case this would not be in line with the EUTR requirements. 

The conclusion related to this structure of most certification schemes is that it poses a risk 
of allowing timber potentially harvested in violation of applicable legislation to enter the 
supply chain as certified. This would mean that such timber would not meet the EUTR 
obligations related to illegal timber if placed on the EU market. Therefore, it must be part 
of the due diligence process to evaluate the risks that timber form certified forest  are low 
risk of non-compliances with applicable legislation. 

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SECTOR AND FOR WOOD-BASED PRODUCTS 

10.3  Transparency 

In the context of the EUTR, certification-scheme transparency is important to Operators 
and other organisations relevant to the proper application of the regulation. In practice, it  
comprises several related elements which are discussed in turn below. These are:  

  Public  availability  of  scheme  requirements  for  both  Certificate  Holders  and 
Certification Bodies, including general information on scheme governance, how 
stakeholders may engage with the scheme.  

  publicly accessible register Certificate Holders and Certification Bodies.  
  publicly accessible public summaries of audits carried out on Certificate Holders.  

Operators benefit from being able to understand the requirements for certificate holders, 
to evaluate what the scheme covers in terms of applicable legislation. It is also important 
for Operators to understand quality aspects of the scheme, such as the level and extent of 
oversight by Certification Bodies. As a natural part of scheme transparency, most of the 
schemes evaluated in this study were observed to ensure the public availability online of 
Scheme requirements, in terms of normative requirements for both Certificate Holders.  

This  transparency  extended  to  scheme  requirements  for  Certification  Bodies  also, 
although  there  were  some  gaps.  For  example,  PEFC  failed  to  make  available  some 
procedures related to the accreditation process. The exception to the rule, however, was 
ISO 38200. The standard ISO 38200:2018 is not supported  by a scheme, and it is not 
possible to easily obtain a full overview of the scheme requirements for certificate holders 
and certification bodies. Systems implemented by certification bodies and accreditations 
bodies might differ between organisations, as there are no requirements specified related 
to  the  implementation  of  ISO  38200:2018.  In  addition  to  ensuring  the  normative 
requirements,  it  would  aid  evaluation  buy  Operators  and  other  stakeholders,  if  the 
schemes made publicly available impacts information about their schemes and aspects of 
these which are relevant to the EUTR. In the study, it was observed that the availability of 
such information by schemes themselves was patchy. 

Equally  as  critical  to  scheme  transparency  is  ensuring  that  an  up -to-date  register  of 
certified  or  verified  organisations  is  publicly  available.  Having  access  to  real -time 
information  is  essential  to  operators  –  data  on  a  certificate  must  be  up-to-date  and 
accurate. Although it was not always clear how quickly new information was inputted into 
certificate  databased, all schemes evaluated were aligned in providing a least a basic 
register of certified or verified organisations externally, with the exception of ISO. There is 
no complete online register for organisations certified under ISO 38200. 

However, there was room for improvement across a number of schemes in relation to the 
broader  quality  of  data  available  publicly,  which  would  be  of  interest  to  Operators  in 
conducting  due  diligence.  For  example,  while  PEFC  makes  available  a  r egister  of 
certified/verified organisations, the online database does not include information about 
forest area or locations within the scope of forest management certificates. All schemes 
lacked clear data on any certification gaps (periods where the comp any many have been 
suspended) in the databases. 

Besides  basic  information  on  certified  or  verified  organisations,  a  list  of  other 
data/information of interest to Operators includes the following: 

  Scope of certification, including: 

o  Specific products or product groupings 
o  Relevant species 

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REPORT : STUDY ON CERTIFICATION AND VERIFICATION SCHEMES IN THE FOREST 
SECTOR AND FOR WOOD-BASED PRODUCTS 

o  Additional information where products are comprised of recycled material 

(type of reclaimed material, quantities) 

o  Claim or claims methods or systems used? (e.g., Credit system, controlled 

o 

sources/wood, etc…) 
Information  about  forest  area(s)/location(s)  within  scope  –  as  well  as 
specific areas excised from the certification for whatever reason.  
  Periods of suspensions or terminations, to allow operators to be aware of times 

 

when the company was not certified. 
Information relating to materials sourced via a controlled sources/wood system or 
DDS, such as the location of the forests/suppliers, the risk conclusions reached by 
the  certificate  holder  conducting  due  diligence,  as  well  as  the  risk  mitigation 
actions implemented. 

  The names and locations of members or facilities included within group/multisite 

certificates. 

Finally, the study evaluated if - and what - each scheme made available on the internet, in 
relation  to  summary  reports  or  other  information  derived  from  the  actual  aud its  of 
Certificate holders. Such information provides a window into the actual performance of the 
certificate holder. For example, findings of auditors on areas of potential or actual non -
conformance by the certified entity, may provide useful information  in relation to good-
performance by the certified organisation or - on the other hand - areas where legal non -
compliances may have been identified, issues related to tenure-rights or relationships with 
local communities, locations of actual harvest, etc. 

Overall, schemes within the study performed differently. In the case of FSC, summaries of 
forest management (and FM Controlled Wood) evaluations are made available on the 
FSC certificate database. Information in relation to the content and language of the pu blic 
summary  is governed by scheme requirements. No public summary report (other than 
basic data in relation to the certification scope) is required for COC certificates  – in line 
with  all  schemes included in the study. However, in the case of FSC Controll ed Wood 
(DDS) certification for supply-chain entities, summaries of basic information with relevant 
Certification Body findings are required and are available on the FSC certificate database. 
In the case of PEFC, reports are not available in the online pla tform developed by the 
PEFC  International.  While  it  has  been  observed  that  PEFC  Germany  uploads  public 
summary reports on their national website, overall the Scheme at the international level is 
not responsible for making reports publicly for Forest Management Certificates. As can be 
seen  from  practice,  summary audit reports are not available on the internet for PEFC 
certificates  in almost all countries. There are no requirements for public summaries of 
audits in relation to controlled sources materials. 

SBP ensures the latest public summary report is available on its website. This includes 
main results, evaluation process, any stakeholder consultations that has taken place, and 
any open non-conformities. The supply base report is also available on this website, which 
declares the sourcing area, number of suppliers, type of biomass sources and relevant 
forest  resource  information relevant for that area. In the case of Bureau Veritas OLB, 
forest  management  audit  reports  are  available  upon  request  via  e -mail  (not  directly 
available on the internet).  

55 

 
 
 
 
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SECTOR AND FOR WOOD-BASED PRODUCTS 

PART III: Summary of Forest Certification Scheme 

Assessments 

In  the  following  a  summary  is  provided  for  each  of  the  forest  certification  schemes 
included  in  the  study.  Details  of  the assessment of each scheme assessment can be 
found in the respective scheme assessment reports. 

This summary is intended to provide a quick overview of findings which should allow the 
reader to gain an overview of the key strength and weaknesses of specific schemes. This 
allows the reader quickly to identify a relevant scheme and access the findings.  

The Forest Stewardship Council (FSC) is one of the World’s largest voluntary forest 
certification schemes with over 220 million certified hectares and 45,000 certified supply 
chain entities. It is also one of the oldest, having been legally established in 1994. FSC 
operates  a  third-party  system,  whereby  its  main  functions  are  to  set  the  normative 
requirements and guidance, and to manage the strategic direction and day to day running 
of the scheme. FSC operates two approaches to certification: i) certification at the forest 
management level and the supply chain level; and ii) a risk-based approach to managing 
non-certified materials to FSC claim, through the Controlled Wood programme. Out of  the 
84 indicators of the scheme assessment framework evaluated within the study, 58 was 
concluded as covered, 22 as Partially Covered and 2 as Not Covered. 2 indicators were 
concluded  as  Not  Applicable.  FSC  is  a  fully  developed  scheme  with  systems  for 
transparency and oversight built in. There are mostly robust processes and systems in 
place, covering all the key components of the certification scheme.  

The Programme for the Endorsement of Forest Certification  (PEF C)  is one of the 
World’s  largest  voluntary  forest  certification  schemes  with  over  320  million  certified 
hectares  and  27,000  certified  supply chain entities. It is the largest forest certification 
scheme in terms of certified forest area. PEFC operates a third-party certification system, 
whereby  it  sets  the  normative  and  benchmark  standards  together  with  guidance and 
procedural  documents.  PEFC  operates  two  certification  approaches  which  apply  to 
forests: i) certification of forest – and forest management – organisations and supply-chain 
entities; and ii) certification of a risk-based due-diligence mechanism for managing non -
PEFC-certified material inputs into PEFC-certified products. Out of the 84 indicators of the 
scheme  assessment  framework  evaluated  within  the  study,  30  were  concluded  as 
covered, 39 as Partially Covered and 14 as Not Covered. One indicator was concluded as 
Not Applicable. PEFC is a fully developed certification scheme, which includes many of 
the processes and elements that would be expected of such a global certification scheme.  

The SBP (Sustainable Biomass Program) is a certification scheme that accepts input 
from other large and well-known certification schemes (currently FSC, PEFC and PEFC 
endorsed  schemes),  as  well  as  input  sourced  under  the  scope  of  its  own  evaluation 
framework. The sourcing through its own scheme is based on risk assessments for SBP’s 
indicators. The objective is to have one system for certified biomass. In total, out of the 84 
indicators  of  the  scheme  assessment  framework  evaluated  within  the  study,  65  were 
concluded as “Covered”, 13 as “Partially Covered” and 5 as “Not Covered”. One indicator 
was concluded as “Not Applicable”.  

The overall finding of the assessment is that SBP is a transparent scheme that covers 
many critical parts of the EUTR. It should be noted that the coverage of the SBP scheme 
is dependent, to a large extend, on the strength of the schemes they approve – currently 
FSC and PEFC endorsed schemes.  

56 

 
 
REPORT : STUDY ON CERTIFICATION AND VERIFICATION SCHEMES IN THE FOREST 
SECTOR AND FOR WOOD-BASED PRODUCTS 

The BV OLB (Origine et Légalité des Bois) verification scheme was developed in 2004 
by  Bureau  Veritas  Certification  (BV),  an  international  independent  certification  body 
headquartered in Paris, France. The purpose of OLB verification is to verify that a forest is 
managed legally, the origin of forest products is controlled, and the transfer of cert ificate 
claims along the supply chain is ensured. Chain of custody certification aims to ensure 
that the certification claim is transferred along the value chain. The system is based on 
two main standards: 1) forest management (FM) standard for forest enterprises, and 2) a 
chain  of  custody  (CoC)  standard  for  supply  chain  entities  (processors  and  trade 
companies).  The  BV  OLB  scheme  is  assessed  to  be  a  comprehensive  scheme  that 
covers many critical parts of the EU Timber Regulation.  

The  standard  “ISO  38200:2018  Chain  of  custody  of  wood  and  wood-based 
products” sets requirements for a chain of custody system to enable the exchange and 
tracking of information on wood and wood-based products throughout a supply chain. It 
includes traceability measures (CoC) as well as due diligence requirements to ensure that 
only  legal  input  material  is  included in the CoC system. ISO 38200 is an international 
standard  and  not  a  forest  certification  scheme.  This  means  there  are  no  normative 
requirements developed for the accreditation of certification bodies certifying against the 
standard, and it is important to note, that the standard is not intended for certification only. 
The  due  diligence  system  of  ISO  38200  shall  include  the  elements  of  information 
gathering,  risk  assessment  and  mitigation  measures.  The  ISO  38200  CoC  standard 
provides  a  flexible  approach  to  controlling  supply  chains  using  multiple  different 
certification claims under one CoC system. ISO 38200 partially cover the indicators of the 
evaluation framework. 11 indicators are covered, 48 indicators are partially covered, while 
25  are not covered. The standard is clear in requiring that only legally harvested and 
legally procured material can enter the chain of custody system of a company.  

The following table provides an overview of the study findings at a Criterion level.  

These colour condes are used to indicate the assessment findings: 

C overed: 

P a rtially c overed: 

No t c overed: 

No t a pplicable: 

57 

 
 
 
 
 
 
 
 
 
 
 
REPORT : STUDY ON CERTIFICATION AND VERIFICATION SCHEMES IN THE FOREST SECTOR AND FOR WOOD-BASED PRODUCTS 

Table 2: Overview of certification scheme assessment findings (see findings for individual schemes below for details). 

Requirement Section 

PEFC 

PEFC Non-
certified 
material 

FSC 

(FM) 

FSC  

(CW-FM) 

FSC Non-
certified 
material  

(CW-CoC) 

SBP 

ISO 38200 

OLB 

OLB Non-certified 
material 

A. Requirements for Certificate Holders 

A.1 Legal Requirements at the forest level 

A.1.1 Rights to harvest timber within legally 
gazetted boundaries 

Partially 
covered 

Partially 
covered 

A.1.2  Payments  for  harvest  rights  and 
timber  including  duties  related  to  timber 
harvesting 

Partially 
covered 

Partially 
covered 

Partially 
covered 

Partially 
covered 

Partially 
covered 

Covered 

Partially 
covered 

Partially 
covered 

Partially covered 

Partially covered 

Covered 

Covered 

Partially 
covered 

Partially 
covered 

Covered 

Partially covered 

and 

Timber 

harvesting, 
forest 

including 
A.1.3 
legislation 
environmental 
including 
and 
biodiversity  conservation,  where  directly 
related to timber harvesting 

forest  management 

Partially 
covered 

Partially 
covered 

Covered 

Partially 
covered 

Covered 

Covered 

Partially 
covered 

Covered 

Partially covered 

A.1.4  Third  parties’  legal  rights  concerning 
use and tenure that are affected by timber 
harvesting 

Covered 

Partially 
covered 

Covered 

Covered 

Covered 

Partially 
covered 

Partially 
covered 

Partially covered 

Partially covered 

A.1.5  Trade  and  customs,  in  so  far  as  the 
forest sector is concerned 

Partially 
covered 

Not covered 

Partially 
covered 

Covered 

Covered 

Partially 
covered 

Partially 
covered 

Partially covered 

Partially covered 

A.2 Legal requirements for supply chain entities 

A.2.1. Legal registration 

Not 
covered 

Not covered 

Not covered 

Not covered 

Not covered 

Covered 

Partially 
covered 

Covered 

Covered 

58 

 
 
 
 
 
 
 
REPORT : STUDY ON CERTIFICATION AND VERIFICATION SCHEMES IN THE FOREST SECTOR AND FOR WOOD-BASED PRODUCTS 

Requirement Section 

PEFC 

PEFC  Non-
certified 
material 

FSC 

(FM) 

FSC  

(CW-FM) 

A.2.2 Taxes and fees 

A.2.3 Trade and transport 

Not 
covered 

Partially 
covered 

Not covered 

Not covered 

Partially 
covered 

Partially 
covered 

Partially 
covered 

Partially 
covered 

A.3 Requirements for material control 

FSC Non-
certified 
material  

(CW-CoC) 

Not covered 

SBP 

ISO 38200 

OLB 

OLB  Non-certified 
material 

Partially 
covered 

Partially 
covered 

Covered 

Partially covered 

Not covered 

Partially 
covered 

Partially 
covered 

Partially covered 

Partially covered 

A.3.1 Material control 

Partially covered 

Partially covered 

Covered 

Partially 
covered 

Covered 

Partially covered 

A.3.2 Recycled material 

Partially covered 

Partially covered 

Covered 

Covered 

Not covered 

Not covered 

A.4 General requirements for Certificate Holders 

A.4.1 Conflict resolution 

Partially covered 

Covered 

Covered 

Not covered  Partially covered 

A.4.2 Corruption 

Partially covered 

Covered 

Covered 

Not covered  Covered 

A.5 Quality and procedural requirements for Certificate Holders 

A.5.1  Internal  procedures  for  Certificate 
Holders 

Covered 

Partially covered 

Partially 
covered 

Covered 

Partially covered 

A.5.2 Qualification and competence 

Covered 

Partially covered 

Covered 

Covered 

Covered 

A.5.3  Risk  based  approaches  to  sourcing, 
trade or production 

Partially covered 

Covered 

Partially 
covered 

Partially 
covered 

Partially covered 

59 

 
 
 
 
 
 
 
REPORT : STUDY ON CERTIFICATION AND VERIFICATION SCHEMES IN THE FOREST SECTOR AND FOR WOOD-BASED PRODUCTS 

Requirement Section 

PEFC 

PEFC Non-
certified 
material 

FSC 

(FM) 

FSC  

(CW-FM) 

FSC Non-
certified 
material  

(CW-CoC) 

SBP 

ISO 38200 

OLB 

OLB Non-certified 
material 

B. Requirements for Certification Bodies 

General 

B.1 
requirements 

Certification 

Body 

Covered 

Partially covered 

B.2  Certification  Body  requirements  for 
auditing and certification 

Partially covered 

Partially covered 

C.1 Transparency 

Partially covered 

Partially covered 

C. Requirements for Certification Schemes 

C.2 Scheme & standard scope 

Partially covered 

Partially covered 

C.3 Accreditation and oversight 

Partially covered 

Partially covered 

C.4 Certification process 

Partially covered 

Partially covered 

Covered 

Covered 

Partially 
covered 

Partially 
covered 

Partially covered 

Partially covered 

Covered 

Partially 
covered 

Partially covered 

Partially 
covered 

Partially 
covered 

Covered 

Partially 
covered 

Partially 
covered 

Partially covered 

Partially 
covered 

Partially 
covered 

Partially covered 

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REPORT : STUDY ON CERTIFICATION AND VERIFICATION SCHEMES IN THE FOREST 
SECTOR AND FOR WOOD-BASED PRODUCTS 

11.  PEFC 

The Programme for the Endorsement of Forest Certification (PEFC) is one  of the World’s 
largest voluntary forest certification schemes with over 320 million certified hectares and 
27,000 certified supply chain entities. It is the largest forest certification scheme in terms 
of certified forest area. 

PEFC  operates  a  third-party  certification  system,  whereby  it  sets  the  normative  and 
benchmark standards together with guidance and procedural documents. The scheme 
has support from International Accreditation Forum (IAF) in recognizing bodies allowed to 
accredit  the  certification  bodies.  In  addition  to  the  accreditation  process,  certification 
bodies shall be notified by PEFC22 before issuing certificates. Evaluations of Certificate 
holders include field audits. 

The scheme recognises national forest certification system standards. The  recognition 
process and incorporation into the PEFC family of new national forest certification systems 
is known as ‘endorsement’ and includes assessments made by an independent assessor 
and recognition of PEFC Council. After five years of the approval date, endorsed systems 
shall initiate a standard review process in relation to their standards.  

PEFC National Governing Bodies (NGBs) play multiple roles in assuring the credibility of a 
system  in  a  specific  country.  NGBs  conduct  notification  of  certification  bodies  (CBs), 
without that CBs cannot issue PEFC FM certificates. Simultaneously, NGBs have a role in 
forest certification system setting, appointing a standardizing body or acting themselves as 
a standardizing body and responsible for maintaining the forest certification system. At the 
international  level,  NGBs  are  part  of  PEFC  Council  Board  tog ether  with  International 
Stakeholders,  accepting  new  National  Governing  Bodies  and  changes  of  Scheme, 
including normative and Benchmark standards. Similarly, Accreditation Bodies are part of 
IAF, involved in accepting new Accreditation Bodies.  

Certification Bodies conduct assessments and issue certificates to organisations. Various 
organisations can apply for certification at the forest or supply chain level, from single to 
groups  of  forestry  companies;  smallholders  and  community  groups;  from  sawmills, 
traders, manufacturers and printers.  

PEFC operates two certification approaches which apply to forests: i) certification of forest 
– and forest management – organisations and supply-chain entities; and ii) certification of 
a risk-based due-diligence mechanism for managing non-PEFC-certified material inputs 
into PEFC-certified products. 

PEFC's Forest Management (FM) standard is a benchmark standard based on 6 criteria 
(chapter 8) and 94 requirements. Certification at the forest level is based on standards 
developed by the national forest certification system, which conform to the set of rules and 
requirements  defined  by  PEFC  International 23.  The  development  of  PEFC  standards 
includes consultation with stakeholders.  

22 PEFC International or National Governing Body 

23 PEFC ST 1003:2018 Sustainable Forest Management, is the latest benchmark standard developed by PEFC International 
to which national standards are independently assessed against and must conform to, in order to become PEFC endorsed.  

61 

 
 
 
                                              
REPORT : STUDY ON CERTIFICATION AND VERIFICATION SCHEMES IN THE FOREST 
SECTOR AND FOR WOOD-BASED PRODUCTS 

PEFC’s Chain of Custody (CoC) standard is a global standard, applied as-is, to all supply 
chain  entities  wishing  to  sell  PEFC  certified  products  with  a  PEFC  claim.  PEFC  has 
integrated a due diligence mechanism into its CoC standard to allow the mixing of PEF C -
certified material and non-PEFC-certified material in the manufacture of PEFC-certified 
products,  whilst  at  the  same  time  avoiding  raw  material  from  controversial  sources. 
PEFC’s definition of controversial sources includes illegally harvested and traded wood.    

Finally, the system provides for the inclusion of recycled wood material via the Chain of 
Custody standard. 

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11.1 Summary  of PEFC findings 

In total, out of the 84 indicators of the scheme assessment framework evaluated within the study, 30 were concluded as “Cover ed”, 39 as “Partially 
Covered” and 14 as “Not Covered”. One indicator was concluded as “Not Applicable”.   

Table 3: Summary of PEFC findings 

PEFC (a) – cov erage of applicable 
legislation of certified material 
(Forest Management - FM) 

PEFC (b)  – Cov erage of applicable legislation 
of non-certified material (Controlled Sources) 

PEFC – Cov erage of other requirements for 
certificate holders 

PEFC – Cov erage of requirements for scheme 
gov ernance 

 Criteria 

Indicator 

 Criteria 

Indicator 

 Criteria 

Indicator 

 Criteria 

I ndicator 

A1.1 Rights to harv est 
timber   

A1.2 Payments for 
harv est rights and 
timber   
A1.3 Timber 
harv esting 

A1.4 Third  parties’ 
legal rights 

A1.5 Trade and 
customs 

A1.1.1.1 
A1.1.1.2 
A1.1.1.3 
A1.1.2.1 
A1.1.3.1 
A1.1.3.2 
A1.1.4.1 
A1.2.1.1 
A1.2.2.2 

A1.3.1.1 
A1.3.1.2 
A1.3.2.1 
A1.3.2.2 
A1.3.3.1 
A1.3.4.1 
A1.3.5.1 
A1.3.5.2 
A1.4.1.1 
A1.4.1.2 
A1.4.2.1 
A1.4.3.1 
A1.5.1.1 
A1.5.2.1 
A1.5.3.1 
A1.5.4.1 
A1.5.5.1 
A1.5.6.1 

A1.1 Rights to harv est timber   

A1.2 Payments for harv est rights 
and timber   
A1.3 Timber harv esting 

A1.4 Third  parties’ legal rights 

A1.5 Trade and customs 

A1.1.1.1 
A1.1.1.2 
A1.1.1.3 
A1.1.2.1 
A1.1.3.1 
A1.1.3.2 
A1.1.4.1 
A1.2.1.1 
A1.2.2.2 
A1.3.1.1 

A1.3.1.2 
A1.3.2.1 
A1.3.2.2 
A1.3.3.1 
A1.3.4.1 
A1.3.5.1 
A1.3.5.2 
A1.4.1.1 
A1.4.1.2 
A1.4.2.1 
A1.4.3.1 
A1.5.1.1 
A1.5.2.1 
A1.5.3.1 
A1.5.4.1 
A1.5.5.1 
A1.5.6.1 

A3.1 Material control 

A3.2 Recycled material 

A4.1 Conflict resolution 
A4.2 Corruption 
A5.1 Internal procedures for 
Certificate Holders 

A5.2 Qualification and competence 
A5.3 Risk based approaches to 
sourcing, trade or production 

A3.1.1.1 
A3.1.1.2 
A3.1.1.3 
A3.1.1.4 
A3.2.1.1 
A3.2.1.2 
A3.2.1.3 
A4.1.1 
A4.1.2 
A5.1.1 

A5.1.2 
A5.2.1 
A5.3.1 
A5.3.2 
A5.3.3 
A5.3.4 

C1 Transparency 

C2 Scheme & standard scope 

C3 Accreditation and ov ersight 

C4 Certification process 

C 1.1.1 
C 1.1.2 
C 1.1.3 
C 1.1.4 
C 1.2.1 
C 1.3.1 
C 2.1.1 
C 2.2.1 
C 2.3.1 
C 2.4.1 

C 3.1.1 
C 3.1.2 
C 3.1.3 
C 3.1.4 
C 3.2.1 
C 3.2.2 
C 3.2.3 
C 3.2.4 
C 4.1.1 
C 4.1.2 
C 4.1.3 
C 4.1.4 

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A2.1 Legal registration 
A2.2 Taxes and fees 

A2.3 Trade and transport 

A2.1 Legal 
registration 
A2.2 Taxes and fees 

A2.3 Trade and 
transport 

A2.1.1.1 

A2.2.1.1 
A2.2.2.1 
A2.3.1.1 
A2.3.2.1 
A2.3.3.1 
A2.3.3.2 
A2.3.4.1 
A2.3.5.1 
A2.3.6.1 

A2.1.1.1 
A2.2.1.1 

A2.2.2.1 
A2.3.1.1 
A2.3.2.1 
A2.3.3.1 
A2.3.3.2 
A2.3.4.1 
A2.3.5.1 
A2.3.6.1 

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SECTOR AND FOR WOOD-BASED PRODUCTS 

Coverage by the scheme of legal requirements at the forest level 

Strengths 

The  first  part  of  this  study  addressed  legal  requirements  at the forest level for forest 
management certification, evaluating how PEFC ensures that Certificate Holders comply 
with all applicable legislation. The study concluded that legal requirements at the forest 
level are mostly Covered by PEFC Forest Management standard (PEFC ST 1003: 2018), 
and  Partially  Covered  as  far  as  the  Controlled  Sources  requirements within the COC 
standard (PEFC ST 2002: 2020) are concerned. Of the 27 indicators assessed, 15 were 
evaluated as covered, 9 were partially covered and 3 are not covered for PEFC Forest 
Management.  On  most  occasions,  the  four  national  forest  cer tification  standard 
evaluations conducted (for Brazil, China, Russia and Romania) corroborated the findings 
of the international level evaluation. Although, it must be noted that these standards had 
not  yet  been  updated  to  the  current  version  of  the  intern ational  Sustainable  Forest 
Management (FM) benchmark standard (PEFC ST 1003: 2018). 

Gaps or areas of lower coverage 

Across the same 27 indicators in the case of Controlled Sources requirements, only 6 
were evaluated as Covered, 15 as partially covered and 6 as not covered. In both cases, 
many of the identified gaps related to ambiguities, omissions, or cases where no clear 
reference was made within PEFC standard requirements to an aspect of forest legality 
included in the framework.  

For  Controlled  Sources,  however,  all  indicators  related  to  trade  and customs are not 
covered.  The  definition  of  controversial  sources  does  not  appear  to  cover  legal 
compliance in relation to trade, transport and customs 24, for non-certified forest entities 
included  within  the  due  diligence  requirements  of  the  scheme.  This  represents  a 
significant gap within the scheme. 

PEFC requires that the international Sustainability benchmark standard is adapted to the 
national context in which it is being implemented by forest organisation. As of the date of 
this report, no countries have yet an approved national standard that has been updated 
from the previous version of the international FM benchmark standard (PEFC ST 1003: 
2010)  to  the  current  version.  At  the  same  time,  two  approved  standar ds  (Brazil  and 
Ireland) are still developed based on the initial version of the standard, developed in 1998 
- “Pan European Operational Level Guidelines”, although both schemes are currently in a 
process  of  review  for  compliance  with  PEFC  ST  1003:2018.  However,  the  delays  in 
updating all national FM standards to meet updated benchmarks, represents a significant 
gap in the PEFC system. 

Coverage by the scheme of legal requirements at the supply chain level  

Gaps or areas of lower coverage 

The study addressed requirements for legal compliance by Certificate holders which are 
supply chain entities, focussing on the PEFC CoC standard. This standard is applicable to 
all certified supply chain entities within the PEFC system. Of the 10 indicators evaluated, 3 
were  concluded  as  Partially  Covered,  while  7  as  Not  Covered.  This  is  considered  a 
significant  gap  within  the  PEFC  system.  While  the  normative  requirements  of  the 

24 Note: in the context of the EUTR, trade, transport and customs laws are only relevant within the country of harvest.  

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accreditation standard require Certificate bodies to collect information related to the legal 
status  of the certificate holder, the requirement for legal business registration and the 
holding of other relevant legally required licenses is not made a requirement of Certificate 
Holders  within  the  CoC  standard.  Certificate  holders  are  not  required  to  compl y  with 
legislation  concerning  taxes  and  fees,  how  products  are  classified,  trading  permits, 
offshore trading, transfer pricing, export/import licenses. 

A  second  major gap within the due diligence requirements is for non -certified material 
entering the PEFC system that form part of the PEFC Controlled Source requirements for 
supply-chain  entities.  Here,  the  PEFC  due  diligence  process  does  not  include  the 
evaluation of risks of legal non-compliance in relation to: legal business registration; trade, 
transport and customs, or the payment of taxes and fees within the country of origin. As a 
result, of the 10 indicators within this principle, all were evaluated as Not Covered.  

Material control 

Strengths 

Via  the  PEFC  CoC  standard  and  other  normative  requirements,  the  PEFC  system 
maintains  a  system  of  material  control,  tracking  and  traceability,  similar  to  other  fully 
developed certification schemes. PEFC standard requirements include clear and effective 
measures  to  prevent  material  from  non-negligible  risk,  unverified  or  potentially  illegal 
sources from entering the supply chain. 

Gaps or areas of lower coverage 

The  CoC  system does not include any validation of certified volumes transferred from 
sellers to purchasers vertically up and down supply chains, meaning that  risks of errors - 
or even fraudulent activity  – exist in relation to the volumes of PEFC-certified products 
sold along supply chains. However, it is also not a concern specific to PEFC, but many of 
the schemes evaluated within this study.  

A  further  gap  to  be  noted  regards  reclaimed  timber.  PEFC  descriptions  of  recycled 
material described in Terms and definition of the COC standard (PEFC ST  2002: 2020), 
do not entirely align with the definition of waste material as defined in – and excluded from 
the requirements of – the EU Timber Regulation and associated guidance documents. 
This discrepancy between PEFC and EU definitions means material might enter the PEFC 
system without the required due diligence. 

Other requirements for certificate holders 

Strengths 

General  requirements  for  certificate  holders  related  to  Quality  and  procedural 
requirements are mostly addressed within the PEFC system. Documented systems and 
procedures  covering  all  requirements  of  the  relevant  standards are required both for 
Forest Management and Chain of Custody certification.  

In the case of requirements that certificate holders do not engage in corrupt practices 
related to illegal harvesting, this is addressed within the PEFC system for FM certification.  

Gaps or areas of lower coverage 

Requirements for CoC certificate holders related to conflict resolution  – specifically that 
disputes  are identified, recorded and managed in a robust and transparent way  – are 
covered. However, conflict resolution is assessed as partially covered for FM ce rtification 
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because standard requirements do not extend to requiring the exclusion from the scope of 
a certificate situations or forest areas where the legality of tenure or management is not 
defined, unclear or disputed.  

For CoC certification, there is no requirement that certificate holders do not engage in 
corrupt practices related to illegal harvesting. 

In relation to requirements for risk-based approaches to sourcing (Due Diligence Systems) 
for non-certified material, PEFC was concluded as partially covering the quality indicators. 
Due diligence procedures are described in Annex 1 of the PEFC CoC standar d. However, 
there  are  no  requirements  or  guidance  on  what  basis  –  or  how  –  other  certification 
schemes  shall  be  evaluated  by  the  certificate  holder  other  than  that  they  cover  the 
activities included in the term controversial sources and are covered by a su pported by 
third-party certification. At the same time, DDS procedures defined in the COC standard 
are such that it is not clear that the system will always capture risks present within supply -
chains.  

Requirements for Certification Bodies 

Strengths 

Quality  requirements  for  Certification  Bodies  were  generally evaluated as Covered (6 
indicators),  based  on  PEFC  normative  requirements,  with  some  notable  exceptions 
(resulting in 2 Partially Covered indicators, 1 not covered).  

Gaps or areas of lower coverage 

Important indicators that are partially covered are related to the frequency of audits, as 
these  may  exceed  12  months  in  the  case  of  CoC  certification.  In  the  case  of  forest 
management, it is not clear if standards consistently include the ability for unannounced or 
short-notice audits in case of substantiated claims or for other reasons.   

At the same time, stakeholder consultation is concluded as partially covered. For forest 
management,  not  all national schemes include stakeholder consultation for ev aluating 
compliance of certificate holders. In the case of Chain of custody, there is no requirement 
to conduct stakeholder consultation. 1 indicator is partially covered. 

One important gap was identified: there are no mechanisms or formal processes for th e 
scheme  -  or  requirements  for  Certification  Body  -  to  proactively  identify  companies 
sanctioned for engagement in corrupt practices relevant to the forest sector.  

Other requirements of the Certification scheme 

Strengths 

In  relation  to  issues of accreditation and oversight, most indicators were evaluated as 
covered  based  on  the  normative  requirements.  PEFC  has  in  place  a  system  for  the 
accreditation and oversight of Certification Bodies to ensure that CBs have in place the 
required procedures, capacity and competencies.  

Gaps or areas of lower coverage 

In  relation  to  scheme  transparency,  1  indicator  was  assessed  as  covered.  Of  the  4 
indicators  evaluated  as  partially  covered  and  1  not  covered,  some  of  these  cover 
important issues:  

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  Most of the procedures and standards related to the Scheme are publicly available 
on internet. However, some procedures related to the accreditation process and 
impact information are not publicly available. 

  A  register  of  certified/verified  organisations  is publicly available. The d atabase 
allows  a  user  to  identify  the certification status of named companies from their 
name or certification code. However, the database does not include information 
about certified forest areas or locations within the scope of the certificate. At the 
same time, the Scheme is not requiring that summary audit reports are publicly 
available on the internet. 

  Some of the procedures used for accreditation are publicly available, however not 
all of them. For example, standards used in the assessment of Accredit ation or 
Certification Bodies applicants, are not publicly available. 

The  PEFC  system  includes  an  oversight  mechanism  which  is  independent  of  the 
Certification Bodies and includes requirements to ensure the frequency of oversight or a 
procedure for determining the frequency. However, while the PEFC system includes in 
field evaluation of Certification bodies, stakeholder consultation does not form part of the 
accreditation or evaluation process.  

Certification  bodies  may  issue  corrective  actions  to  certifica te  holders  for  non-
conformances (up to 3 months for major non-conformities and up to 12 months for minor 
non-conformities, according to different audit types). This approach ensures that non -
conformances in relation to PEFC requirements are addressed systematically and within a 
specific  timeframe.  It  is  also  an approach similar to that employed by almost all forest 
certification schemes. 

In the case of surveillance and re-certification audits, the timeframes permitted to address 
and  close  non-conformities  are  such  that  there  is  a  possible  risk  that illegal (or non-
negligible) wood products may enter the EU market without mitigation having taken place. 
This could occur if a non-conformity which represented an infringement of legislation was 
issued to a certificate holder. It is possible the non-conformity would not be addressed for 
a period of up to 3 or 12 months, during which production or trade was still taking place.  

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Table 4: PEFC International findings 

Requirem ent Section 

Conclusion 

Sum m ary 

Conclusion 

Sum m ary 

A.  Requirements  for Certificate  Holders 

A.1 Legal  Requirements 
at the forest level 

A.1.1 Rights  to harvest 
timber  w ithin legally 
gazetted boundaries 

a - Forest management  certification 

b - Input  from non-PEFC  certified forest 

Partially covered 

5 indicators  are 
covered  

2 indicators  are 
partially  covered 

Indicators  related to land tenure, management 
rights, and concession license are almost  covered. 
Standard  requires to cover legislation  but not 
explicitly  requiring  legal methods  to obtain  these 
documents.  2 indicators are covered and 2 
partially  covered. 

Partially covered 

1 indicator  is 
covered 

6 indicators  are 
partially  covered 

PEFC  standard requirements  cover legislation 
related  to forest management,  harvesting planning 
and permits.  3 indicators  assessed as covered. 

Indicators  related to land tenure and management 
rights, and concession licenses are partially  covered. 
The  standard includes  applicable  legislation  on forest 
management  as w ell as tenure and land-use  rights for 
indigenous  peoples, local communities  or other affected 
stakeholders.  How ever, a specific reference to 
legislation  in the case w hen there are no indigenous 
peoples,  local communities  or other affected 
stakeholders  is not made.   

For other indicators of this criterion, the PEFC 
international  standard includes  compliance  w ith 
applicable  local, national  or international  legislation  on 
forest management.  How ever, it does not make  clear 
reference to legally-gazetted  boundaries  and legal 
business registration. 

Indicators  related to management  and harvesting 
planning  are partially  covered. Indicator  related  to 
harvesting permits  is covered.   

The  PEFC  standard includes compliance  w ith applicable 
local, national  or international  legislation  on forest 
management  but does not make  clear references to 
certain aspects of management  planning;  the 
requirement  for legally  required  planning  documents  to 
be approved before the implementation;  legislation 
regulating  the issuing of harvesting permits,  licenses or 
other legal  documents  required for specific harvesting 

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A.1.2 Payments  for 
harvest rights and 
timber  including  duties 
related  to timber 
harvesting 

Partially covered 

2 indicators  are 
partially  covered 

PEFC  standard includes compliance  w ith 
legislation  related  to the payment  of applicable 
royalties and taxes but does not explicitly  request 
compliance  w ith legislation  regulating  value-added 
taxes; stumpage  fees, other volume-based  fees, 
land area taxes. 

Partially covered 

2 indicators  are 
partially  covered  

The  PEFC  standard includes compliance  w ith legislation 
related  to the payment  of applicable  royalties and taxes 
but does not explicitly  request compliance  w ith 
legislation  regulating  value-added  taxes; stumpage  fees, 
other volume-based  fees, land area taxes. 

operations. 

Partially covered 

5 indicators  are 
covered 

3 indicators  are 
partially  covered  

A.1.3 Timber 
harvesting, including 
environmental  and 
forest legislation 
including  forest 
management  and 
biodiversity 
conservation, w here 
directly related to timber 
harvesting 

Indicators  related to timber  harvesting regulations 
are almost  covered. Note  that the PEFC  standard 
requires control of potential  illegal  activities by 
third parties w ithin the managed  area. At the same 
time,  it requires compliance  w ith forest 
management  legislation.  How ever, clear 
references to compliance  w ith legislation 
regulating  harvesting techniques and technologies 
is not made.  1 covered and 1 partially  covered. 

Indicators  related to protected sites and species 
are almost  covered. The PEFC  standard requires 
compliance  w ith legislation  regulating  protected 
and endangered  species, but does not include 
clear reference to legislation  regulating  the 
identification  of protected areas. 1 covered and 1 
partially  covered. 

Indicator  related  to environmental  requirements  is 
partially  covered. Specific references to 
compliance  w ith legislation  regulating 
environmental  impact  assessments is not made.  1 
indicator  partially  covered. 

Indicators  related to health  and safety and legal 
employment  are covered by the national 
standards, although  the international  standard is 
not clear for legal employment.  These 3 indicators 

70 

Partially covered 

3 indicators  are 
covered 

5 indicators  are 
partially  covered  

Indicators  related to timber  harvesting regulations  are 
almost  covered. Standard requests comply w ith forest 
management  legislation.  How ever, an explicit  request to 
compliance  w ith legislation  regulated  harvesting 
techniques  and technology  is not made.  1 covered and 
1 partially  covered. 

Indicators  related to protected sites and species are 
almost  covered. Standard includes  compliance  w ith 
legislation  regulating  protected and endangered 
species, but not clearly reference legislation  regulating 
the identification  of protected areas. 1 covered and 1 
partially  covered. 

Indicator  related  to environmental  requirements  is 
partially  covered. Specific references to compliance  w ith 
legislation  regulating  environmental  impact  assessment 
is not made.  1 indicator partially  covered. 

PEFC  standard requirements  cover the indicator  related 
to health and safety. Indicators  related  to legal 
employment  are almost  covered. Standard  requests 
comply  w ith forest management  legislation.  How ever, a 
specific reference to compliance  w ith legislation 
contracts and w orking permits,  obligatory  insurances, 
certificates of competence  and other training 
requirements,  and payment  of social and income  taxes, 
is not made  w ithin the PEFC  normative  requirements.  1 

 
 
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A.1.4 Third  parties’ 
legal  rights concerning 
use and tenure that are 
affected by timber 
harvesting 

A.1.5 Trade  and 
customs, in so far as 
the forest sector is 
concerned 

how ever w ere concluded as covered. 

indicator  covered and 1 partially  covered. 

Covered 

4 indicators  are 
covered  

Indicators  related to customary rights; Free, Prior 
and Informed  Consent;  and Indigenous  and 
traditional  peoples'  rights are  covered by the 
standard requirements.  4 indicators covered. 

Covered 

4 indicators  are 
covered  

Indicators  related to customary rights; Free, Prior  and 
Informed  Consent;  and Indigenous  and traditional 
peoples'  rights are covered by the standard 
requirements.  4 indicators  covered. 

Indicators  related to the classification of species, 
quantities,  qualities;  trade and transport; Offshore 
trading  and transfer pricing; Customs  regulations; 
CITES  and Legislation  requiring  due diligence  / due care 
procedures are not covered.  

The  definition  of controversial sources (3.7) includes 
forest and tree-based material  sourced from activities 
not complying  w ith applicable  local,  national,  or 
international  legislation  on forest management,  including 
forest management  practices and other areas of law . 
How ever, the definition  does not appear to cover legal 
compliance  in relation  to trade, transport and customs, 
for non-certified forest entities included  w ithin the due 
diligence  requirements  of the scheme. 

Partially covered 

1 indicator  is 
covered 

2 indicators  are 
partially  covered 

3 indicators  are not 
covered  

Indicators  related to the classification of species, 
quantities,  qualities;  and trade and transport are 
partially  covered.  

Not Covered 

6 indicators  are not 
covered 

There  is a requirement  to comply  w ith applicable 
local, national  and international  legislation  on 
forest management.  How ever, clear reference to 
complying  w ith legislation  regulating  how  
harvested material  is classified or related  to trade 
and transport is not made.  2 indicators partially 
covered. 

Indicator  related  to CITES  is covered. The 
international  PEFC  standard does not have explicit 
requirements  related to CITES  permits,  but all 
national  standard assessed have requirements 
related  to CITES.  1 indicator covered. 

Indicators  related to offshore trading; transfer 
pricing; customs regulations;  and legislation 
requiring  due diligence  / due care procedures are 
evaluated  as not covered. While  there is a 
requirement  to comply w ith applicable  local, 
national  and international  legislation  on forest 
management,  no clear reference is made  to 
compliance  in relation  to these areas of law . 3 
indicators concluded  as not covered. 

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A.2 Legal  requirements 
for supply chain entities 

a - Certificate  Holders 

A.2.1. Legal registration  Not covered 

1 indicator  is not 
covered  

A.2.2 Taxes and fees 

Not Covered 

A.2.3 Trade  and 
transport 

2 indicators  are not 
covered  

Partially covered 

2 indicators  are 
partially  covered 

5 indicators  are not 
covered  

Indicator  related  to legal  registration  is assessed 
as not covered. The  certification body is collecting 
information  related to the legal status of the 
certificate holder.  How ever, legal  business 
registration  or other relevant legally  required 
licenses are not specifically required  to be 
ascertained or evaluated.  Simultaneously,  there is 
no requirement  in the chain of custody standard to 
ensure the existence of legal  business registration 
or other relevant legally  required licenses. 

Standard  has no requirement  to ensure 
compliance  w ith legislation  covering taxes and 
fees. 

Standard  has no requirement  to ensure 
compliance  w ith legislation  regulating  how  
products are classified, trading  permits,  offshore 
trading,  transfer pricing, export/import  licenses. 5 
indicators not covered. 

Indicator  related  to CITES  is assessed as partially 
covered. When  CH  is not implementing  a DDS, 
there is no requirement  to ensure compliance  w ith 
CITES  legislation,  but if the Certificate  Holder  is 
implementing  a DDS,  then the requirement  is 
included.  1 indicator partially  covered. 

Indicator  related  to due diligence/  due care 
procedures is assessed as partially  covered. 
There  is no specific reference ensuring 
compliance  w ith legislation  covering due 

72 

b - Input  from non-PEFC  certified forest 

Not Covered 

1 indicator  is not 
covered 

Not Covered 

2 indicators  are not 
covered  

Not Covered 

7 indicators  are not 
covered  

Indicator  related  to legal  registration  is assessed as not 
covered. Standard  requirements  include  forest and tree-
based material  sourced from activities not complying 
w ith applicable  local, national  or international  legislation 
on forest management,  including  forest management 
practices and other areas of law . This definition  is 
specific to forest management  only. It does not appear 
to include compliance  relevant to the supply chain 
legality,  covering legislation  relevant to business 
registration  and other relevant  legally  required licenses 
that applies  to supply chain entities. 

Standard  has no requirement  to ensure compliance  w ith 
legislation  covering taxes and fees. 

Standard  requirements  include forest and tree-based 
material  sourced from activities not complying  w ith 
applicable  local, national  or international  legislation  on 
forest management,  including  forest management 
practices and other areas of law . This definition  is 
specific to forest management  only. It does not appear 
to include compliance  w ith trade and transport 
legislation  (Classification  of species, quantities, 
qualities;  Trade and transport; Offshore trading  and 
transfer pricing;  Customs  regulations;  CITES; 
Legislation  requiring  due diligence  / due care 
procedures). 7 indicators not covered. 

 
 
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diligence/due  care procedures. Appendix 1 is 
effectively a due diligence  mechanism,  but it does 
not apply to all  certificate holders themselves.  1 
indicator  partially  covered. 

Requirem ent Section 

Conclusion 

Sum m ary 

A.3 Requirements  for material  control 

A.3.1 Material  control 

Partially covered 

1 indicator  is covered 

3 indicators  are partially 
covered  

A.3.2 Recycled  material 

Partially covered 

3 indicator  are partially 
covered  

related 

to  material  origin  and 

Indicators 
identification  are  partially  covered.  PEFC  standard 
requirements  enable  the  identification  of  the  country  of  harvest  and  species  included  in  materials  or 
products  through  Due  Diligence  system  used  in  case  of  non-certified  material  –  Controlled  Sources. 
In  case  that  PEFC-certified  products  are  used,  it  is  only  voluntary  to  implement  a  Due  Diligence 
system  and  obtain  information  related  to  the  country  of  harvest  and  species.  2  indicators  partially 
covered. 

PEFC  standard  requirements  include  clear  and  effective  measures  to  prevent  material  from  non-
negligible  risk,  unverified  or  potentially  illegal  sources  from  entering  the  supply  chain.  How ever,  the 
CoC  system  does  not  include  any  validation  of  volumes  transferred  from  sellers  to  purchasers 
(verification  of  volumes) vertically up and dow n supply chains, w hich is considered as a major gap in 
the system. 1 indicator  covered and 1 indicator  partially  covered. 

Indicators  related  to  w aste  material  are  assessed  as  partially  covered.  PEFC  standard  requirements 
include  a  definition  of  recycled material that is not entirely aligned w ith the definition of w aste material 
as  described  by  the  EUTR  and  associated  guidance  document.  For  this  reason,  other  indicators 
relating  to  systematic  processes  to  enable  the  identification,  and  segregation  of,  w aste  material  are 
assessed as partially  covered. 

A.4 General  requirements  for Certificate  Holders 

A.4.1 Conflict  resolution 

Partially covered 

Forest Management:  1 

For  forest  management  certification,  standard  requirements  do  not  extend  to  requiring  the  exclusion 
from  the  scope  of  the  certificate  situations  or  areas  or  forest  w here  the  legality  of  tenure  or 

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A.4.2 Corruption 

indicator  is partially 
covered. 

Chain  of custody: 1 
indicator  is covered. 

Partially covered 

Forest Management:  1 
indicator  is covered. 

Chain  of custody: 1 
indicator  is not Covered. 

management/harvesting  is not defined or is unclear and disputed.   

In  the  case  of  chain  of  custody,  standard  requirements  require  exclusion  from  the  scope  of  the 
certificate,  material  for  w hich  there  are  unresolved  substantiated  concerns.  Basic requirements exist 
in relation  to the transparency of dispute/complaint  resolutions processes. 

For  forest  management,  corrupt  practices  related  to  illegal  harvesting  is  directly  addressed  in  the 
normative  requirement  at  the  level  of  PEFC  International.  For  chain  of  custody,  there  is  no 
requirement  that certificate holders do not engage in corrupt practices related to illegal  harvesting. 

A.5  Quality  and  procedural  requirements  for 
Certificate  Holders 

A.5.1 Internal  procedures for Certificate Holders  Covered 

2 indicators  are covered 

Indicators  related 
for  Certificate  Holders  are  assessed  as  covered. 
Documented  systems  and  procedures  covering  all  requirements  of  the  relevant  standards  are 
required both for Forest Management  and Chain  of Custody  certification. 

internal  procedures 

to 

A.5.2 Qualification  and competence 

Covered 

1 indicators  is covered 

Requirements  are  included  that  certified  organisations have personnel w ith sufficient  competencies to 
implement  Scheme  requirements. 

A.5.3  Risk  based  approaches  to sourcing, trade 
or production 

Partially covered 

2 indicators  are covered 

2 indicators  are partially 
covered 

Indicators  related  to  risk-based  approaches  to  sourcing,  trade  or  production  are  partially  covered. 
Normative  requirements  are  described  for  the  consistent  implementation  of  a  DDS  for  sourcing  non-
certified  material  and  w henever  there  is  a  change  in  the  risk  related  to  illegal  harvest,  trade  or 
transport  in  a  supply  chain  –  or  a  supply  chain  covered  by  a  DDS  – the risk shall be assessed and 
mitigated  prior to shipping  and sale.   

The  standard  describes  due  diligence  procedures  in  Annex  1.  The  DDS  determines  that  supplies 
verified  by  governmental  or  non-governmental  verification  or  licensing  mechanisms  (other than forest 
certification systems) can be considered as low  risk, as long as they address the activities covered by 
the  term  controversial  sources.  How ever,  there  are  no  requirements or guidance on w hat basis  – or 
how  - the schemes shall be evaluated by the certificate holder other than that they cover the activities 

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included  in the term controversial sources and are covered by a supported by third-party certification.   

At  the  same  time,  DDS  procedures  defined  in  the  COC  standard  are  such  that it is not clear that the 
system  w ill  alw ays  capture  risks.  Controversial  sources  is  applicable  just  to  the  chain  of  custody 
standard. 

B. Requirements  for Certification  Bodies   

B.1 General  Certification  Body requirements 

Covered 

4 indicators  are covered  

related 

to  competence  and  qualifications  are  assessed  as  covered.  For 

forest 
Indicators 
management,  auditors  and  other  relevant  personnel  of  the  Certification  Body,  are  qualified  and 
competent  to  evaluate  organisations’  compliance  w ith  specific  Scheme  requirements  is  indirectly 
(through  ISO  standards)  addressed  in  the  normative  requirement.  For  Chain  of custody, auditors and 
other  relevant  personnel  of  the  Certification  Body,  are  qualified  and  competent  to  evaluate 
organisations’  compliance  w ith  specific  Scheme  requirements  is  directly  addressed  in  the  normative 
requirement. 

Indicators  related  to  impartiality  are  assessed  as  covered.  The  impartiality  of  auditors  is  directly  (in 
chain  of  custody)  and  indirectly (in forest management through ISO 19011 and ISO 17021) addressed 
in the normative  requirement. 

B.2  Certification  Body  requirements  for  auditing 
and certification 

Partially covered 

2 indicators  are covered 

2 is partially  covered 

1 is not covered  

Indicators  related  to  auditing  process  are  almost  covered.  The  documented  methodology  for  the 
evaluation  (assessments  and  audits)  of  clients  is  directly  addressed  in  the  normative  requirement. 
Procedures  for  evaluation  of  conformity  of  organisations  to  the  Schemes;  review   and  certification 
decision;  issuance  of a certificate and periodic re-assessment are addressed for Forest management, 
through  ISO  17021,  and  directly  addressed  in  PEFC  ST  2003:2020  the  normative  requirement  Chain 
of custody certification.   

How ever, in case of forest management, it is not clear if standards consistently includes the ability for 
unannounced  or  short-notice  audits  in  case  of  substantiated  claims or for other reasons. In the case 
of  Chain  of  custody,  frequency  of audits may exceed 12 months. 2 indicators cover ed and 1 partially 
covered. 

Indicator  related  to  stakeholder  consultation  is  partially  covered.  At  the  forest  management  level,  not 
all  national  schemes  include  stakeholder  consultation  for  evaluating  compliance  of  certificate holders. 
In  the  case  of  Chain  of  custody,  there  is  no  requirement  to  conduct  stakeholder  consultation.  1 
indicator  is partially  covered. 

Indicator  related  to  corruption  is  not  covered.  There  are  no  mechanisms  for  the  scheme  -  or for the 
Certification  Body  -  to  identify  companies  sanctioned  for  engagement  in  corrupt  practices relevant to 

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C. Requirements  for Certification  Schemes 

C.1  Transparency 

Partially covered 

1 indicator  is covered 

4 indicators  are partially 
covered 

1 indicator  is not covered  

C.2  Scheme  & standard scope 

Partially covered 

1 indicator  is covered 

1 indicator  is partially 
covered 

1 indicator  is not covered 

1 indicator  is not applicable   

the forest sector. 1 indicator  is not covered. 

Indicators  related  to  transparency  are  mostly  partially  covered.  Scheme  requirements  ensure  that 
relevant  information  related  to  development  of  the  Scheme;  how   the  system  is  governed;  how   the 
scheme  is  w orking; w ho is evaluated and process; impact information and the various w ays in w hich 
stakeholders  can engage  is freely available.   

How ever,  some  procedures  related  to  the  accreditation  process  and  impact  information  are  not 
publicly  available.  A  register  of  certified/verified  organisations  is  publicly  available.  The  database 
allow s  a  user  to  identify  the  certification  status  of  named  companies  from  their  name or certification 
code.  How ever,  the  database  does  not  include  information  about  certified  forest  areas  or  locations 
w ithin  the  scope  of  the  certificate.  The  Scheme  does  not  require  summary  reports  to  be  publicly 
available  on the internet.  3 indicators partially  covered and 1 not covered. 

Indicator  related  to  impartiality  is  covered.  Procedures  for  complaints  and  appeals  are  publicly 
available  and steps for submitting  a comment  or complain  are clear. 1 indicator covered. 

Indicator  related  to  conflict  of  interest  and  corruption  is  partially  covered.  Corruption  and  conflict  of 
interest is not mentioned  at all  levels of the scheme. 1 indicator partially  covered. 

Indicator  related  to  international  standard  application  to  the  national  or  subnational  context  is  partially 
covered.  While  there  is  a  system  in  place  for  national  certification  standards  to  be  updated  to  the 
latest  version  of  the  international  Benchmark  Standard  PEFC  ST  1003:  2018,  there  are  currently  no 
national  standards  developed  in  conformance  w ith this standard and a small number of standards. At 
the  same  time,  tw o  approved  standards  (Brazil  and  Ireland)  are  still  developed  based  on  the  initial 
version  of  the  standard,  developed  in  1998  -  “Pan  European  Operational  Level  Guidelines”,  although 
both  schemes  are  currently  in  a  process  of  review   for  compliance  w ith  PEFC  ST  1003:2018.  PEFC 
explains  that  national  adaptation  is  an ongoing process and a number of standards w ill be updated to 
the  new est  version  of  the  international  Benchmark  Standard  in  the near future. 1 indicator is partially 
covered. 

Indicator  related  to  international  conventions  and  treaties  is  not  covered.  There  is  no  requirement  to 
develop  a  list  of  the  relevant  international  conventions  to  w hich  the  country  has  ratified,  and  w hich 
hold  legal  force  in  the  country  for  forest  management  or  chain  of  custody certification. 1 indicator is 
not covered. 

Indicator  related  to  the  use  of  contractors  is  covered.  PEFC  International  requirements  include  a 

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C.3  Accreditation and oversight 

Partially covered 

5 indicators  are covered 

3 indicators  are partially 
covered 

reference  to  normative  requirements  for  certificate  holders  also  being  applicable to the organisation’s 
contractors and outsourcing facilities. 1 indicator is covered. 

Indicator  related  to  endorsing  and  recognising  of  other  Schemes and systems is not applicable. PEFC 
does not endorse 3rd party private voluntary certification schemes.  1 indicator  is not applicable. 

Indicators  related  to  accreditation  are  almost  covered.  PEFC  International  includes  a  system  for 
accreditation  of  Certification  Bodies.  This  system  includes  requirements  to  develop  procedures, 
capacity and competencies.   

A list and details  of all accredited Certification  Bodies  is publicly  available.   

International 

PEFC 
to  ensure  qualification  and  competence  of  National 
Accreditation  Bodies.  Some  of  the  procedures  used  for  accreditation  are  publicly available, how ever 
not all of them.  3 indicators  covered, and 1 partially  covered. 

includes  a  system 

Indicators  related  to  oversight  mechanisms  are  almost  covered.  PEFC  International  includes  an 
oversight  mechanism  w hich  is  independent  of  the  Certification  Bodies  and  includes  requirements  to 
ensure the frequency of oversight or the procedure for determining  the frequency.  

PEFC  International  includes  in-field  evaluation,  but  stakeholder  consultation  is  conducted  for  the 
accreditation  process.  In  the  case  of  surveillance  and  re-certification  audits,  the  definition  of  non-
conformities  is  such  that  there  is  a  potential risk that a non-conformity may represent an infringement 
of  legislation.  As  a  result,  illegal  w ood  may  enter  the  EU  market  w ithout  mitigation  measures  to 
prevent  this  from  occurring  for  a  period  of  up to 3 or 12 months. 2 indicators covered and 2 partially 
covered. 

C.4  Certification  process 

Partially covered 

Indicator  related  to Compliance  evaluations  is partially  covered.  

3 indicators  are covered 

1 indicators  are partially 
covered  

PEFC  International  includes  requirements  that  ensure  that  the  Certification  Bodies  apply  a  clear basis 
for  establishing  conformance;  raising  corrective  actions,  and  certification  decision  making.  The 
decision  process  to  certify  organisations  or  maintain  certification  is  free  from  conflict  of interest and 
includes checks and balances.   

PEFC International includes a system to assess conformity w ith the standard. How ever, in the case of 
surveillance  and  re-certification  audits,  the  definition  of  non-conformities  is  such  that  there  is  a 
potential  risk  that  a  non-conformity  may  represent  an  infringement  of  legislation.  As  a  result,  illegal 
w ood  may enter the EU market w ithout mitigation measures to prevent this from occurring for a period 
of up to 3 or 12 months.  3 indicators  covered and 1 indicators partially  covered. 

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11.2  Understanding  PEFC labels and claims 

PEFC  have  introduced  a  new trademark standard (PEFC 2001:2020) 25. This standard 
contains the rules for using the PEFC trademark, as well as the labels and  claims to be 
used  on – and off-product by certificate holders, as well as other entities in the PEFC 
system. 

The claims used on labels provides information about the composition of the material or 
product in terms of the certification status of the material. This can include material from 
certified  forest,  material  from  Controlled  Sources  and  recycled  materials.  Clams  may 
cover a mixture of these material categories, as outlined in the details on claims below.  

Claims are transferred between certified entities on the invoice of the material. 

The generic PEFC on-product label looks like this: 

The PEFC certified label may be used whenever at least 70% of the forest and tree -based 
material included in the product is PEFC certified material and the content of r ecycled 
material is lower than 100%. The label message that shall accompany the PEFC certified 
label  is:  “[This  product]  is  from  sustainably  managed  forests,  recycled and controlled 
sources”. This means that material with this label may include bot certified material, non -
certified Controlled Sources and recycled materials. 

Where the product does not include PEFC certified material from recycled sources, the 
label message may be used without the word “recycled”. 

25  PEFC  Trademark  Rules  –  requirements.  https://cdn.pefc.org/pefc.org/media/2020 -02/d1ad5a21-0267-4db4-a41b-
07fd577ffdea/3abf07e8-b7f9-5f42-ba2a-9ca608ee415f.pdf  

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Where  the  product  includes  only  material  from  PEFC  certified  forests,  i.e.  material 
delivered with the claim “100% PEFC Origin”, the label message may be used with the 
wording: “[This product] is from sustainably managed forests”. 

The PEFC recycled label shall be used when the product includes only recycled material. 
The  label  name  is  “PEFC  Recycled”  and  the  label  message:  “[This  product]  is  from 
recycled sources”. 

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12.  Forest Stewardship Council (FSC) 

The  Forest  Stewardship  Council  (FSC)  is  one  of  the  world’s  largest  voluntary  forest 
certification schemes with over 220 million certified hectares and 45,000 certified supply 
chain entities. It is also one of the oldest, having been legally established in 1994.  

FSC operates a third-party system, whereby its main functions are to set the normative 
requirements and guidance, and to manage the strategic direction and day to day running 
of the scheme. Assurance Services International (ASI) conducts assessments and issues 
accreditations to independent Certification Bodies which, in turn, conduct assessments 
and issue certificates. Organisations can apply for certification at the forest and supply 
chain levels, from smallholders and community groups to large forestry companies, from 
sawmills, to traders, manufacturers and printers. Evaluations of both Cer tificate Bodies 
and Certificate Holders are performance-based and, thus, include field and witness audits.    

FSC operates two approaches to certification: i) certification at the forest management 
level and the supply chain level; and ii) a risk-based approach to managing non -certified 
materials to FSC claim, through the Controlled Wood programme.  

FSC’s Principles and Criteria for Forest Stewardship standard (FSC-STD-01-001), is the 
principal forest management (FM) standard for the scheme. It is an intern ational standard 
based on 10 principles and 70 criteria. The current version of this standard is version 5 -2, 
published in July 2015. The international standard of Principles and Criteria is adapted to 
regional  or  national  certification standards by local  balanced working groups following 
detailed  processes  mandated  by  FSC,  including  consultation  with  a  full  range  of 
stakeholders.  

FSC’s Chain of Custody Certification (CoC) standard, FSC-STD-40-004 V3.0, is also a 
global  standard,  applied  as  is, to all supply chain entities wishing to sell FSC certified 
products with an FSC claim.  

The FSC scheme includes the FSC Controlled Wood (CW) system, of which the principal 
standard is Requirements for Sourcing FSC Controlled Wood (FSC-STD-40-005 V3-1). 
This system allows for the use of non-certified, yet ‘controlled’, wood material to be mixed 
with FSC-certified material, in the manufacture of FSC-certified products. FSC Controlled 
Wood  basically  comprises  a  due  diligence  system  which  is  put  in  place  by FSC CoC 
certified supply-chain companies, in order to avoid that any non-certified material entering 
into production derives from five different categories of ‘unacceptable sources’. T he first 
category of unacceptable sources is illegally harvested wood.  

Once the sources of non-certified material have been assessed for risks of deriving from 
the unacceptable sources, and any identified risks have been mitigated, the raw material 
is considered to be ‘controlled’. The FSC Controlled Wood standard is a global standard 
that  mandates  the  use  of  National  Risk  Assessments  which  have  been  developed 
according to FSC’s detailed procedure and which also often contain defined mandatory 
risk mitigation actions. 

Besides via the use of a due diligence process at the supply chain level,  ‘Controlled Wood’ 
material can also enter into the FSC system via certification at the forest management 
(FM) level. In this case, the FM Controlled Wood standard (FSC-STD-30-010 V2-0 F SC 
Controlled Wood Standard for Forest Management Enterprises) is applied to a forest area, 
using a similar approach to the FM standard with field audits. The FM CW standard is not 
adapted to the national context in the same way.  

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Whether in relation to FM certification or FM CW certification, reduced requirements exist 
for  Small  and  Low  Intensity  Managed  Forests  (SLIMFs).  SLIMFs  are  also  subject  to 
reduced  requirements  for  external  auditing.  Within  the  FSC  system,  groups  of  small 
organisations (both at the forest and supply chain levels) may seek group (FM or COC) 
certification, which carries with it the advantage of reducing the intensity of external audits 
by the Certification Body (and therefore external costs of certification).    

Finally,  the  FSC  system  provides  for  the  inclusion  of  recycled  timber via a dedicated 
Reclaimed Wood standard (Sourcing reclaimed material for use in FSC Product Groups or 
FSC Certified Projects, FSC-STD-40-007 V2-0) which is applied at the supply chain level.   

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12.1 Summary of FSC findings 

In total,  out  of  the  84  indicators  of  the  scheme assessment  framework  evaluated  within  the  study,  58  were  concluded  as  Covered,  22  as  Partially 
Covered and 2 as Not Covered. 2 indicators were concluded as Not Applicable. 

Table 5: Summary of FSC findings 

FSC (a) – Coverage of applicable 
legislation of certified material 
(from forest management certified 
forest) 

FSC (a) – Coverage of applicable 
legislation of certified material 
(from CW certified forest) 

FSC (b) – Coverage of applicable 
legislation of non-certified material 
(Controlled Wood CoC) 

FSC – Coverage of other 
requirements for certificate holders 

FSC – Coverage of requirements for 
scheme governance 

 Criteria 

Indicator 

 Criteria 

Indicator 

 Criteria 

Indicator 

 Criteria 

Indicator 

 Criteria 

Indicator 

A1.1 Rights to 
harvest timber   

A1.2 Payments for 
harvest rights and 
timber   
A1.3 Timber 
harvesting 

A1.4 Third parties’ 
legal rights 

A1.5 Trade and 
customs 

A1.1.1.1 
A1.1.1.2 
A1.1.1.3 
A1.1.2.1 
A1.1.3.1 
A1.1.3.2 
A1.1.4.1 
A1.2.1.1 

A1.2.2.2 
A1.3.1.1 
A1.3.1.2 

A1.3.2.1 

A1.3.2.2 
A1.3.3.1 
A1.3.4.1 
A1.3.5.1 
A1.3.5.2 
A1.4.1.1 
A1.4.1.2 
A1.4.2.1 
A1.4.3.1 
A1.5.1.1 
A1.5.2.1 
A1.5.3.1 

A1.1 Rights to 
harvest timber   

A1.2 Payments for 
harvest rights and 
timber   
A1.3 Timber 
harvesting 

A1.4 Third parties’ 
legal rights 

A1.5 Trade and 
customs 

A1.1.1.1 
A1.1.1.2 
A1.1.1.3 
A1.1.2.1 
A1.1.3.1 
A1.1.3.2 
A1.1.4.1 
A1.2.1.1 

A1.2.2.2 
A1.3.1.1 
A1.3.1.2 

A1.3.2.1 

A1.3.2.2 
A1.3.3.1 
A1.3.4.1 
A1.3.5.1 
A1.3.5.2 
A1.4.1.1 
A1.4.1.2 
A1.4.2.1 
A1.4.3.1 
A1.5.1.1 
A1.5.2.1 
A1.5.3.1 

A1.1 Rights to harvest 
timber   

A1.2 Payments for harvest 
rights and timber   

A1.3 Timber harvesting 

A1.4 Third parties’ legal 
rights 

A1.5 Trade and customs 

82 

A1.1.1.1 
A1.1.1.2 
A1.1.1.3 
A1.1.2.1 
A1.1.3.1 
A1.1.3.2 
A1.1.4.1 
A1.2.1.1 

A1.2.2.2 
A1.3.1.1 
A1.3.1.2 

A1.3.2.1 

A1.3.2.2 
A1.3.3.1 
A1.3.4.1 
A1.3.5.1 
A1.3.5.2 
A1.4.1.1 
A1.4.1.2 
A1.4.2.1 
A1.4.3.1 
A1.5.1.1 
A1.5.2.1 
A1.5.3.1 

A3.1 Material control 

A3.2 Recycled 
material 

A4.1 Conflict 
resolution 
A4.2 Corruption 
A5.1 Internal 
procedures for 
Certificate Holders 
A5.2 Qualification 
and competence 
A5.3 Risk based 
approaches to 
sourcing, trade or 
production 

A3.1.1.1 
A3.1.1.2 
A3.1.1.3 
A3.1.1.4 
A3.2.1.1 
A3.2.1.2 
A3.2.1.3 
A4.1.1 

A4.1.2 
A5.1.1 
A5.1.2 

A5.2.1 

A5.3.1 
A5.3.2 
A5.3.3 
A5.3.4 

B1 General 
Certification Body 
requirements 

B2 Certification 
Body requirements 
for auditing and 
certification 

C1 Transparency 

C2 Scheme & 
standard scope 

C3 Accreditation 
and oversight 

B1.1.1 
B1.1.2 
B1.2.1 
B1.2.2 
B2.1.1 
B2.1.2 
B2.1.3 
B2.2.1 

B2.2.2 
C1.1.1 
C1.1.2 

C1.1.3 

C1.1.4 
C1.2.1 
C1.3.1 
C2.1.1 
C2.2.1 
C2.3.1 
C2.4.1 
C3.1.1 
C3.1.2 
C3.1.3 
C3.1.4 
C3.2.1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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A2.1 Legal 
registration 
A2.2 Taxes and 
fees 
A2.3 Trade and 
transport 

A2.1 Legal 
registration 
A2.2 Taxes and fees 

A2.3 Trade and 
transport 

A1.5.4.1 
A1.5.5.1 
A1.5.6.1 
A2.1.1.1 

A2.2.1.1 
A2.2.2.1 
A2.3.1.1 
A2.3.2.1 
A2.3.3.1 
A2.3.3.2 
A2.3.4.1 
A2.3.5.1 
A2.3.6.1 

A1.5.4.1 
A1.5.5.1 
A1.5.6.1 
A2.1.1.1 

A2.2.1.1 
A2.2.2.1 
A2.3.1.1 
A2.3.2.1 
A2.3.3.1 
A2.3.3.2 
A2.3.4.1 
A2.3.5.1 
A2.3.6.1 

A2.1 Legal registration 

A2.2 Taxes and fees 

A1.5.4.1 
A1.5.5.1 
A1.5.6.1 
A2.1.1.1 

A2.2.1.1 
A2.2.2.1 

C4 Certification 
process 

C3.2.2 
C3.2.3 
C3.2.4 
C4.1.1 

C4.1.2 
C4.1.3 
C4.1.4 

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Coverage by the scheme of legal requirements at the forest level  

Strengths 

The  first  part  of  this  study  reviewed  legal  requirements  at  the  forest  level  for  forest 
management certification, evaluating how FSC ensures that Certificate Holders comply 
with all applicable legislation. The study concluded that legal requirements at the forest 
level are largely Covered by both FSC FM and FM CW certification. Of the 27 indicators 
assessed, 24 were concluded as Covered, while 3 were concluded as Partially Covered. 
Furthermore, for most indicators in this study, the findings of the evaluation of the four 
national forest management standards corroborated the findings of the international level 
for forest management certification.  

Legal requirements at the forest level for non-certified material entering the F SC system 
via  Controlled  Wood  due  diligence  systems  were  also  reviewed. These due diligence 
systems are implemented by CoC certificate holders. F ully, all 26 indicators concerning 
legal requirements at the forest level were evaluated as Covered. This indicates that F SC 
ensures that forest organisations within the Country of Harvest which are included within a 
Controlled  Wood  due  diligence  system,  are  comprehensively  evaluated  for  legal 
requirements at the forest level. 

Gaps or areas of lower coverage 

The principal international forest management (FM) standard for the scheme,  Principles 
and Criteria for Forest Stewardship (FSC-STD-01-001 v5.2), is effectively an international 
standard.  FSC  requires  that  this  standard  be  adapted  to  the  national  or  subnational 
context in which it is being implemented by forest organisations. Information provided by 
FSC  shows that, to date, 40 countries have an approved  national standard which has 
been  updated  from  the  previous  version  (version  4-0)  to  the  current  version  of  the 
international Principles and Criteria. For another 38 countries the process is ongoing, to 
be completed in 2021 according to FSC International. However, the delays in updating all 
National  Forest  Stewardship  Standards  (NFSS)  to  meet  the  updated  international 
Principles and Criteria represents a gap in the FSC system. 

Coverage by the scheme of legal requirements at the supply  chain  level  

Gaps or areas of lower coverage 

The study reviewed requirements for legal compliance by Certificate holders which are 
supply chain entities, focussing on the FSC CoC standard. This standard is applicable to 
all certified supply chain entities within the FSC system. Of the 10 indicators evaluated, 
only 1 was concluded as Covered, 7 as Partially Covered, while 2 as Not Covered. This is 
considered a significant gap within the FSC system. The normative requirements of the 
CoC standard do require Certificate holders to ensure the import/export of F SC certified 
products  conforms  to  all  applicable  trade  and  customs  laws.  However,  there  were 
omissions in relation to other areas of trade and transport law.  

A second significant gap is within the due diligence requirements for non-certified material 
entering the FSC system, that form part of the FSC Controlled Wood requirements for 
supply-chain  entities.  Here,  the  risk of illegal trade and transport within the country of 
origin is not considered at all. The FSC Controlled Wood system limits the due diligence 
process to the evaluation of risks of legal non-compliance at the forest level and to the 
evaluation  of  risks  pertaining  to  the  mixing  of  controlled  wood  with  wood  of  illegal  or 
unknown origin. As a result, of the 10 indicators within this principle, all were evaluated as 
Not Covered. 

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Material control 

Strengths 

Of the 7 indicators evaluated in relation to material control, 5 were concluded as Covered 
and 2 as Partially Covered. Via the FSC CoC standard and other normative requ irements, 
the FSC system maintains a system of material control, tracking and traceability, similar to 
other fully developed certification schemes. This system includes systematic processes to 
enable the identification of the country of harvest of the mate rial as well as the species 
included in certified materials or products. Clear systems and measures are required to 
prevent  material  from  non-negligible  risk,  unverified  or potentially illegal sources from 
entering the supply chain and mixing with conforming material. 

Where  there  is  suspicion  or  concerns  regarding  inaccuracy  in  relation  to  volumes  of 
products  or  materials  sold  with  FSC  claims,  FSC  conducts  mechanisms  such  as 
transaction verification investigations, in which the traded volumes  along supply-chains 
are analysed. These programs provide important and valuable support to ensuring the 
integrity of the FSC system in relation to material control.  

Gaps or areas of lower coverage 

However, the validation of volumes transferred from seller to purchaser is not conducted 
systematically by FSC on an ongoing basis across all supply chains, which means that 
risks  exist  of  errors  -  or  even  fraudulent  activity  –  in  relation  to the volumes of FSC-
certified products sold along supply chains. This is considered as a major gap in the F SC 
system. However, it is not a concern specific to FSC, but many of the schemes evaluated 
within  this  study  and  also  a  major  concern  for  material that is not certified under any 
certification scheme. It is also one which FSC is aware  of, and the scheme is exploring 
ways  of  improving  supply  chain  integrity,  although these improvements are still under 
development.  

A further gap to be noted regards reclaimed timber. FSC descriptions of pre -consumer 
material described in Annexes I and II  of the FSC reclaimed materials standard FSC-STD-
40-007,  do  not  entirely  align  with  the  definition  of  waste  material as defined in  – and 
excluded from the requirements of – the EU Timber Regulation and associated guidance 
documents.  This  discrepancy  between  FSC  and  EU  definitions  means  material  might 
enter the FSC system without the required due diligence. 

Other requirements for certificate holders 

Strengths 

FSC was evaluated according to 9 indicators concerning conflict resolution, corruption and 
other  quality  and  procedural  requirements  for  Certificate  Holders.  Of  these,  6  were 
concluded as “Covered”, 2 as “Partially Covered” and one as “Not Applicable”.  

Importantly,  covered  indicators  included  general  requirements  for  certificate  holders 
relating to conflict resolution and the control of corruption are addressed within the F SC 
system.  FSC  has  requirements  to  ensure  that  disputes  –  including  those  relating  to 
customary  tenure  rights  -  are  identified,  recorded  and  managed  in  a  robust  and 
transparent way. This includes the cessation of operations whilst disputes of a significant 
magnitude or duration are being resolved.  

In relation to requirements for risk-based approaches to sourcing (Due Diligence Systems) 
for non-certified material, FSC was concluded as covering all the quality indicators. The 

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scheme  includes  clear  requirements  to  ensure  consistent  implementation  of  the  Due 
Diligence System and ensures that risks are assessed and mitigated prior to shipping and 
sale.  

In  relation  to risk assessments, one important factor is the requirement that certificate 
holders are obliged to use a risk assessment that has been developed by FSC according 
to their own procedures which determine the methodology for developing, maintaining and 
approving risk assessments. 

Requirements for Certification Bodies 

Strengths 

Of the 9 indicators covering quality requirements for Certification Bodies were generally 
evaluated as Covered (7 indicators), based on the normative requirements, with just a 
couple of exceptions (resulting in 2 Partially Covered indicators).  

Covered  indicators  concerned  Certification  Bodies  having mechanisms to ensure that 
auditor  (and  other  relevant  personnel  of  the  Certification  Body)  qualifications  and 
competence, as well as to ensure impartiality in the conformance evaluation process. FSC 
ensures  that  Certification  Bodies  have  and  apply  a  documented  methodology  and 
procedures for the evaluation of conformity of organisations and issuance of a certificates. 
The procedures address topics such as: audit frequency; the requirement for on -site (field) 
visits where applicable; sampling protocols; unannounced or short-notice audits, and other 
aspects of auditing. 

Importantly,  FSC  also  ensures  that  Certification  Bodies  conduct  consultation  with 
stakeholders, as appropriate, for evaluating compliance of certificate holders in relation to 
Forest management audits, as well as some audits for Controlled Wood. 

Gaps or areas of lower coverage 

One  important  gap  was  identified:  there  are  no  normative  requirements  nor  formal 
processes (to be conducted by FSC or Certification Bodies) for identifying Organisations 
sanctioned for engagement in corrupt practices proactively and prior to association with 
FSC.  

Other requirements of the Certification scheme 

Strengths 

In  relation  to  scheme  transparency,  FSC  scored  highly,  with  five  of  the  six indicators 
evaluated as Covered, based on its normative requirements. These concerns, collecti vely, 
issues such as ensuring scheme requirements for Certificate Holders and Certification 
Bodies are publicly and freely available online, as well as providing a publicly availability of 
an up-to-date register of certified/verified organisations. Critically, summaries of Forest 
Management and Controlled Wood audit reports, with relevant findings from the audits, 
are available on the same online register.  

Procedures for handling complaints and grievances are in place, publicly available and 
implemented. 

To ensure consistency of implementation of requirements, the FSC scheme includes a list 
of  the  relevant  national  laws  and  international  conventions  to  which  the  country  has 
ratified, and which hold legal force in the country. Requirements for forest manager s and 

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supply chain entities are also applicable to the organisation’s contractors and outsourcing 
facilities. 

In  relation  to  issues of accreditation and oversight, most indicators were evaluated as 
covered,  based  on  the  normative  requirements.  FSC  has  in  p lace  a  system  for  the 
accreditation and oversight of Certification Bodies to ensure that CBs have in place the 
required procedures, capacity and competencies. The requirements and the process for 
accreditation are publicly available, as is an up-to-date list and details of all accredited 
Certification  Bodies.  Mechanisms  are  in  place  to  ensure  that  relevant  personnel  are 
qualified and competent to evaluate the performance of Certification Bodies.  

Furthermore,  the  competence  and  consistent  performance  of  Cer tification  Bodies  is 
regularly evaluated, employing both stakeholder consultation and in -field evaluation of 
performance. 

Gaps or areas of lower coverage 

FSC ensures that the oversight mechanism for Certificate Holders applies a clear basis for 
establishing  conformance,  raising  corrective  actions  for  non -conformance,  ensuring 
closure within defined timeframes, and certification issue/maintenance decision making. 
Certification bodies are required to define a timeframe (up to 3 months for major non -
conformities and up to the next audit for minor non-conformities) in the case of annual 
surveillance  audits.  This  approach  ensures  that non-conformances in relation to FSC 
requirements are addressed systematically and within a specific timeframe. It is al so an 
approach employed by almost all forest certification schemes. 

However,  the  same  approach  also  raises  a  potential  risk  that  some  non -conformities 
which relate to  – or imply - a legal infringement of legislation, may result in products or 
materials  being  traded  from  the  Certificate  Holder  for  a  period  of  time,  of  which  the 
identified non-conformance was not addressed and verified as closed. These products or 
materials may potentially be interpreted as illegally harvested or non -negligible risk. T his 
itself  carries  a  risk  that  wood  products  might  be  placed  on  the  EU  market,  without 
mitigation measures to reduce the risks having been implemented. 

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Table 6: FSC assessment findings 

Requirem ent Section 

Conclusion 

Sum m ary 

Conclusion 

Sum m ary 

A. 

Requirements  for Certificate  Holders 

A.1  Legal  Requirements  at 
the forest level 

General  findings for A1. 

a - Forest management  certification 

b - Input  from non-certified forest 

A.1a  relates  to  legal  requirements  at  the  forest  level  and,  in  particular, 
forest  management  certification.  It  evaluates  how   the scheme ensures that 
Certificate  Holders  comply  w ith  all  applicable  legislation.  It  covers  full  FSC 
FM  certification 
(FSC-STD-01-001,  FSC-STD-60-004  and  associated 
documents)  and  FM  CW  certif ication  (FSC-STD-30-010  and  associated 
documents). 

Legal  requirements  at  the  forest  level  are  largely  covered  for  FSC  FM 
certification.  Of  the  27  indicators  concerning  legal  requirements  at  the 
forest level,  24 w ere evaluated  as covered, w hile 3 as partially  covered. 

Some  of  these  relate  to  small  ambiguities  or  omissions  in  requirements, 
w here areas of legality defined in the Scheme Assessment Framew ork may 
not be explicitly  specified in standard requirements. 

On  most  occasions,  the four national forest certification system evaluations 
corroborate the findings at the international  level evaluation.   

A.1b  concerns  non-certified  material  entering  the  FSC  system  via  the 
Controlled  Wood  due  diligence  system  w hich  is  implemented  by  CoC 
certificate holders (FSC-STD-40-005  and associated documents).   

It  relates  to  legal  requirements  at  the  forest  level,  but  specifically input 
from  non-certified  forest  (Controlled  Wood).  It  evaluates  if  the  scheme 
ensures  that  entities  w ithin  the  Country  of  Harvest  w hich are included 
w ithin  a  Controlled  Wood  due  diligence  system,  are  evaluated for legal 
requirements  at the forest level. 

All  26  indicators  concerning  legal  requirements at the forest level w ere 
evaluated  as Covered. 

A.1.1  Rights  to  harvest  timber 
w ithin 
gazetted 
boundaries 

legally 

Partially 
covered 

Based  on  the  normative  requirements,  six  out  of  the 
seven  indicators  for  this  criterion  are  Covered  by  the 
scheme.   

Covered 

Based  on  the  normative  requirements  all  seven 
indicators  of  this  criterion  are  evaluated as covered 
by the Scheme. 

The  indicators  concluded  as  Covered  encompass legal 
requirements  concerning  such  areas  as:  land  tenure 
and  management  rights;  the  issuing  of  licences;  legal 
legally 
business 
required 
the 
issuing of harvesting permits. 

registration  and  other 
licenses;  management  planning  and 

relevant 

These  encompass  legal  requirements  concerning 
such  areas  as:  land  tenure  and  management rights; 
the  issuing  of  concession  and  harvesting  licences; 
legal  business  registration  and  other  relevant legally 
required  licenses;  management  planning  and  the 
issuing of harvesting permits. 

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in 

the 

for  one 

requirements 

is  concluded 

indicator 
Partial  coverage 
the  case  of  FM  and  FM  CW 
(A.1a.1.2.1), 
International  FM  standards 
certification.  While 
include 
that  ensure  compliance  w ith 
legislation  regulating  procedures  for  the  issuing  of 
concession  licenses  (w here  they  exist),  they  do  not 
explicitly  include  the  requirement  that  licenses  shall 
only cover legally  gazetted  areas. 

A.1.2  Payments  for  harvest 
including 
rights  and 
duties 
timber 
harvesting 

related 

timber 

to 

Timber 

harvesting, 
A.1.3 
including  environmental  and 
including 
forest 
and 
forest 
conservation, 
biodiversity 
w here  directly 
to 
timber  harvesting 

legislation 
management 

related 

Partially 
covered 

Based  on  the  normative  requirements,  one  indicator 
been  evaluated  as  Covered, 
the  other  Partially 
Covered. 

Covered 

the  normative 

Based  on 
tw o 
indicators  of  this  criterion  are  evaluated as covered 
by the Scheme. 

requirements  all 

The  first  indicator  is  evaluated  as  Partially  covered for 
FM  certification  but  covered  for  FM  CW certification. In 
the  case  of  FM  certification,  w hile  normative 
documents 
ensure 
royalties, 
compliance  w ith 
stumpage  fees  and  other  volume-based  fees,  land 
area  taxes  or  fees  are  not  specifically  mentioned 
(A.1a.2.1.1). 

requirements 

regulating 

legislation 

include 

that 

These  encompass  legal  requirements  concerning 
the payment of royalties and harvesting fees, as w ell 
as value-added  taxes and other sales taxes.     

The  second  indicator  encompassing  legislation  related 
to value-added taxes and other sales taxes, is covered 
for both FM  and FM  CW  certification. 

Partially 
covered 

Of  the  eight  indicators  for  this  criterion  all but one has 
been  evaluated  as  covered,  based  on  the  normative 
requirements. 

Covered 

Based  on  the  normative  requirements  all  seven 
indicators  of  this  criterion  are  evaluated as covered 
by the Scheme. 

The  indicators  concluded  as  Covered  encompass legal 
requirements  concerning:  harvesting  regulations  and 
topics;  protected  areas  and  habitats; 
all  affiliated 
environmental 
other 
environmental  requirements,  as  w ell as health & safety 
and legal  employment. 

assessment 

impact 

and 

In  the  case  of  requirements  to  control  potential  illegal 

89 

legal 

indicators  encompass 

requirements 
These 
concerning:  harvesting  regulations  and  all  affiliated 
topics;  protected  areas  and  habitats;  environmental 
impact 
assessment  and  other  environmental 
requirements,  as  w ell  as  health  &  safety  and  legal 
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activities  by  third  parties  w ithin  the  area  managed  by 
the  operation, 
full  coverage  is  concluded  for  FM 
certification,  but  partial  coverage  is  concluded  for  FM 
CW certification w here the control of illegal activities by 
illegal  conversion  only 
to 
third  parties 
(A.1a.3.1.2). 

limited 

is 

A.1.4  Third  parties’ 
legal 
rights  concerning  use  and 
tenure  that  are  affected  by 
timber  harvesting 

Covered 

All four indicators for this criterion have been evaluated 
as  Covered,  based  on  the  normative  requirements. 
These  encompass  legal  requirements  w hich  concern 
among  other  things:  respect  for  customary  tenure 
rights;  benefit  sharing;  principles  of  'Free,  Prior  and 
Informed  Consent'  in  connection  w ith  granting  rights to 
forest  management,  as  w ell  as  the  tenure  rights  of 
indigenous  and tribal  peoples to forest land. 

Covered 

the  normative  requirements  all 

Based  on 
four 
indicators  of  this  criterion  are  evaluated as covered 
by the Scheme. 

indicators  encompass 

These 
legal  requirements 
w hich  concern  among  other  things:  respect  for 
customary  tenure  rights;  benefit  sharing;  principles 
of  'Free,  Prior  and  Informed  Consent'  in  connection 
w ith  granting  rights  to  forest  management,  as  w ell 
as  the  tenure  rights of indigenous and tribal peoples 
to forest land. 

A.1.5  Trade  and  customs,  in 
so  far  as  the  forest  sector  is 
concerned 

Partially 
covered 

Of  the  six  indicators  included  w ithin  this  criterion,  all 
but  one  has  been  evaluated  as covered, based on the 
normative  requirements. 

Covered 

the  normative 

Based  on 
requirements  all  six 
indicators  of  this  criterion  are  evaluated as covered 
by the Scheme. 

indicators  encompass 

These 
legal  requirements 
concerning:  the  classification  of  species,  quantities 
and  qualities;  trade  and  transport;  offshore  trading 
and  transfer  pricing;  CITES;  customs  regulations 
and  legislation  requiring  due  diligence  or  due  care 
procedures. 

The  indicators  concluded  as  Covered  encompass legal 
requirements  concerning:  the  classification  of  species, 
quantities  and  qualities;  trade  and  transport;  offshore 
transfer  pricing;  CITES  and  legislation 
trading  and 
requiring  due diligence  or due care procedures. 

the 

case  of 

In 
legislation  covering  Customs 
regulations,  full  coverage  is  concluded  for  FM  CW 
certification,  but  partial  coverage  is  concluded  for  FM 
certification.  Whilst  the  international  framew ork  of  the 
scheme  provides  for  full  coverage,  this  has  not  been 
the  National 
follow ed 
Standard  for Romania  (A.1a.5.4.1). 

the  example  of 

through 

in 

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A.2  Legal 
supply 
Certificate  holders 

chain 

requirements 
entities 

a - Legal  requirements  for supply chain entities  – Certificate  holders 

for 
– 

b  -  Legal  requirements  for  supply  chain  entities  –  Non-certified  supply 
chains 

General  findings for A2 

A.2a  relates  to  legal  requirements  for  Certificate  holders  based  w ithin  the 
Country  of  Harvest,  w hich are supply chain entities. The legal requirements 
in question concern trade and customs law s, in so far as the forest sector is 
concerned. 

A.2b  relates to legal requirements for supply chain entities based w ithin 
the Country of Harvest, w ithin the non-certified supply chains. The legal 
requirements  in  question  concern trade and customs law s, in so far as 
the forest sector is concerned. 

This section focuses evaluation on the CoC standard, w hich is applicable to 
all  certified  supply  chain  entities  w ithin  the  FSC  system  (FSC-STD-40-004 
and associated documents).   

Of the 10 indicators w ithin this principle, 1 w as evaluated as Covered, 7 as 
Partially  Covered,  w hile 2 as Not  Covered. 

the  normative  requirements  of 

While 
the  CoC  standard  do  require 
Certificate  holders  to  ensure  the  import/export  of  FSC  certified  products 
conforms  to  all  applicable trade and customs law s, broadly the language of 
the  requirements is such that they either did not fully cover the indicators in 
this  framew ork,  or  there  w ere  some  omissions in relation to specific areas 
of trade law . 

This  section  focusses  evaluation  on  non-certified  material  entering  the 
the  Controlled  Wood  due  diligence  system 
FSC  system  via 
implemented  by  CoC  certificate  holders 
(FSC-STD-40-005  and 
associated  documents)  and  refers  to  the  non-certified  supply  chain 
entities betw een the forest gate and the point of export in the country of 
harvest.  

Of  the  10  indicators  w ithin  this  principle,  all  w ere  evaluated  as  Not 
Covered. 

The  normative  requirements  of  the  Controlled  Wood  standard  FSC-
STD-40-005,  do  not  cover  trade/transport  legal  requirements  applicable 
to supply-chain entities  included  w ithin a certified due diligence  system.   

A.2.1. Legal registration 

Not Covered 

the 
the  one 

lack  of  applicable  normative 
Based 
on 
requirements 
this  criterion, 
for 
concerning  the  existence  of  legal  business registration 
and  other  relevant  legally  required  licenses,  has  been 
evaluated  as not covered (A.2a.1.1.1). 

indicator 

Not Covered 

A.2.2 Taxes and fees 

Partially 
covered 

Based  on  the  normative  requirements  this criterion has 
been  evaluated  as  partially  covered.  This  is  based  on 
the follow ing conclusions for the tw o indicators: 

Not Covered 

91 

The  normative  requirements  applicable  to  supply-
chain entities (w ithin the country of harvest) included 
w ithin  a  due  diligence  system  certified  according  to 
the  Controlled  Wood  standard  FSC-STD-40-005,  do 
not cover this criterion. 

The  one  indicator  is  included  w ithin  this  criterion, 
legal  business 
concerning 
registration  and  other 
required 
legally 
licenses. 

the  existence  of 
relevant 

The  normative  requirements  applicable  to  supply-
chain entities (w ithin the country of harvest) included 
w ithin  a  due  diligence  system  certified  according  to 
the  Controlled  Wood  standard  FSC-STD-40-005,  do 

 
 
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  A  Partial  coverage  conclusion  is made for the 
first  indicator  (A.a2.2.1.1)  w hich  addresses 
compliance  w ith  legislation  covering  payment 
of  all  legally  required  taxes,  royalties  and 
fees.  The  normative  requirements  applicable 
to  supply-chain  certificate  holders  do not fully 
cover this indicator. 
The  second  indicator  (A.2a.2.2.1)  addresses 
compliance  w ith  legislation  covering  value-
added  taxes  and  other sales taxes. Based on 
the  lack  of  normative  requirements  applicable 
to  supply-chain certificate holders, it has been 
evaluated  as Not  Covered. 

 

requirements  applicable 

Normative 
to  supply-chain 
certificate  holders,  do  require  them  to  ensure  the 
import  and/or  export  of  FSC  certified  products 
conforms  to  all  applicable  trade  and  customs  law s. 
Still,  only  one  indicator  w ithin  this  criterion  has  been 
evaluated  as  Covered,  w hilst  the  other  six  indicators 
have  been  evaluated  as  Partially  Covered.  In  relation 
to the partial  coverages: 

not cover this criterion. 

Tw o  indicators  are  included  w ithin  this  criterion, 
concerning  compliance  w ith 
legislation  covering 
payment  of  all  legally  required  taxes,  royalties  and 
fees,  as  w ell  as  value-added taxes and other sales 
taxes. 

Not Covered 

The  normative  requirements  applicable  to  supply-
chain entities (w ithin the country of harvest) included 
w ithin  a  due  diligence  system  certified  according  to 
the  Controlled  Wood  standard  FSC-STD-40-005,  do 
not cover this criterion. 

The  criterion  comprises  seven indicators concerning 
the follow ing topics: 

A.2.3 Trade  and transport 

Partially 
covered 

 

of 

species, 

classification 
qualities 
trade and transport law s 
offshore trading and transfer pricing 
customs regulations 

quantities, 

 
 
 
  CITES 
 

legislation  requiring  due  diligence  /  due 
care procedures 

 

 

 

 

normative  requirements  do  not  fully  cover 
indicator  A.2a.3.1.1  w ith  regards  to legislation 
regulating  how  products are classif ied. 
normative  requirements  do  not  fully  cover 
indicator  A.2a.3.2.1  w hich  concerns  ensuring 
compliance  w ith  required  trading  permits  and 
documents  that  accompany  the  transport  of 
w ood. 
for 
requirements  do  not  explicitly 
legislation 
transfer pricing. 
the  CoC 
reference  CITES  permits  or 

standard  does  not  explicitly 
legislation,  at 

normative 
to 
refer 
trading  or 

regulating  offshore 

A.2a.3.3.1/2, 

indicators 

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 

export  from  the  country  of  harvest,  by  a 
supply  chain  entity.  Hence,  A.2a.3.5.1  has 
been evaluated  as Partially  Covered. 
normative  requirements  do  not  make  explicit 
due 
covering 
legislation 
reference 
diligence/due 
procedures.  Hence, 
A.2a.3.6.1  has  been  evaluated  as  Partially 
Covered. 

care 

to 

For  indicator  A.2a.3.4.1 w hich concerns compliance by 
supply-chain  certificate  holders  in  relation  to  customs 
regulations,  full coverage is concluded. 

Requirem ent Section 

Conclusion 

Sum m ary 

A.3  Requirements  for  material 
control 

A.3.1 Material  control 

Partially 
covered 

Of  the  four  indicators  for  this  criterion  three  have  been  evaluated  as  covered  and  one  as  partially  covered,  based  on  the 
normative  requirements. 

Full  coverage is concluded for indicators covering the follow ing topics: 

 

 

systematic  processes  to  enable  the  identification  of  the  country  of  harvest  of  the  material  (and  w here  applicable  to  a 
higher level  of detail)  as w ell as the species included  in certified materials  or products. 
clear  and  effective  measures  to  prevent  material  from  non-negligible  risk,  unverified  or  potentially  illegal  sources  from 
entering  the supply chain and mixing  w ith conforming  material 

Partial  coverage  is  concluded  because  there  is  limited  validation  of volumes transferred along the supply chain (and A.3.1.1. 4). It 
is  noted  that  the  FSC  system  includes  mechanisms  such  as  transaction  verifications  -  conducted  by  its  certification  body  and 
Accreditation  Services  International  –  w here  there  is  suspicion  or  concerns  regarding  inaccuracy  of  volumes.  This comprises a 
number  of  activities,  including  volume  data  analysis  and  fibre testing. How ever, despite these efforts, FSC CoC certification does 
not  include  systematic  validation  of  volumes  transferred  from  seller  to  purchaser,  w hich  is  considered  as  a  major  gap  in  the 
system. 

A.3.2 Recycled  material 

Partially 
covered 

Of  the  three  indicators  for  this  criterion  tw o  have  been  evaluated  as  covered  and  one  as  partially  covered,  based  on  the 
normative  requirements. 

Partial  coverage  has  been  concluded  because  FSC  descriptions  of  pre-consumer  material  described  in  Annexes  I  and  II  of  the 
FSC  reclaimed  materials  standard  FSC-STD-40-007,  may  not  entirely  align  w ith  the  definition  of  w aste  material  as  described  by 

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the EUTR  and associated guidance  document  (A.3.2.1.1). 

Full  coverage  is  concluded  for  indicators  covering  processes  to  enable  the  identification  of  w aste  and  to  prevent  mixing  of 
reclaimed  material  that w ould qualify for an exemption  under the EUTR  from being  missed w ith material  that w ould not qualify. 

A.4  General  requirements  for 
Certificate  Holders 

A.4.1 Conflict  resolution 

Covered 

The  indicator  for  this  criterion  has been evaluated as Covered, based on the scheme normative requirements. It concerns conflict 
resolution  – specifically that disputes are identified,  recorded and managed  in a robust and transparent w ay. 

A.4.2 Corruption 

Covered 

The  indicator  for  this  criterion  has  been  evaluated  as  Covered,  based  on  the  scheme  normative  requirements.  It  requires  that 
certificate holders do not engage in corrupt practices related to illegal  harvesting. 

A.5  Quality  and  procedural 
requirements 
for  Certificate 
Holders 

A.5.1  Internal  procedures  for 
Certificate  Holders 

Partially 
covered 

Based  on  the  normative  requirements  this  criterion  has  been  evaluated  as  partially  covered.  This  is  based  on  the  follow ing 
conclusions for the tw o indicators: 

  A  full  coverage  conclusion  is  made  for  the  first  indicator  (A.5.1.1).  FSC includes requirements for Certificate Holders to 
have  in  place  -  and  implement  -  systems and procedures covering all requirements of the Scheme. Partial coverage has 
been  concluded  for  the  second  indicator.  The  FSC  Scheme  requires that Certificate Holders regularly review  the proper 
functioning  of  their  ow n  procedures,  in  the  case of certification at the forest level and in relation to the controlled w ood 
DDS  implemented  according  to  standard  FSC-STD-40-005.  How ever,  the  scheme  does  not  require  the  same  of  CoC-
certified companies,  certified to FSC-STD-40-004  only (A.5.1.2). 

A.5.2 
competence 

Qualification 

and 

Partially 
covered 

Partial  coverage  has  been  concluded  for the  indicator w ithin this criterion, because the scheme does not have a requirement that 
organisations  certified  to  the  FM  CW  standard  have  personnel  w ith  sufficient  qualifications  and  competencies  (A.5.2.1). 
Requirements  covering this indicator  exist in all  other parts of the scheme and certification types. 

A.5.3  Risk  based  approaches 
to 
or 
production 

sourcing, 

trade 

Covered 

Of  the  four  indicators for this criterion, three have been evaluated as Covered and one Not Applicable to the FSC Scheme, bas ed 
on the normative  requirements. 

Full  coverage  is  concluded  for  indicators  covering  risk  based  approaches  to  sourcing  non-certified  material  (Due  Diligence 
Systems), w hich concern the need for: 

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 
 

 

clear requirements  to ensure consistent implementation  of the Due  Diligence  System 
a  requirement  that  ensures  that  w henever  there  is  a  change  in  the risk related to illegal harvest, trade or transport in a 
supply chain – or a supply chain covered by a DDS  – the risk shall  be assessed and mitigated  prior to shipping  and sale. 
requirements  to  ensure  that  the  DDS  comprises,  at  a  minimum,  the  follow ing  elements: a quality management system; ii) 
procedures  for  obtaining  access  to  information  pertinent  to  the  identification  of  risk;  risk  assessments,  and  the 
implementation  of mitigations  measures w hen risks are identified 

The  indicator  w hich  is  Not  Applicable  concerns  cases  w here  other  3rd  party  schemes  are  permitted  to  be  used  by  the  due 
diligence  system  as  meeting  specific  due  diligence  requirements.  FSC  Controlled  Wood  standard  FSC-STD-40-005  does  not 
include  the recognition  of other 3rd party schemes. 

Three  of the four indicators  have been evaluated  as Covered,  based on the  normative  requirements.  These concern collectively: 

  mechanisms  to ensure that auditors, and other relevant personnel  of the Certification  Body, are qualified  and competent 
 

requirements  to  ensure  that  auditors,  and  other  personnel  relevant  to  the  conformanc e  evaluation  of  an  organisation 
shall be impartial  to the entity(-ies) under evaluation,  and that the certification decision  process is impartial  also. 
Partial  coverage  has  been  concluded  for  one  indicator  (B.1.1.2)  due  to  the  lack of competence requirements specific to auditors 
evaluating  companies  against  the  Requirements  for  Sourcing  FSC  Controlled  Wood  (FSC-STD-40-005)  w hich  requires  the 
evaluation  of a DDS. 

Four of the five indicators have been evaluated  as covered, based on the normative  requirements.  These concern collectively:  

ensuring that Certification  Bodies apply a documented  methodology  for the evaluation  (assessments and audits) of clients  

 
  minimum  methodologies  and procedures for the evaluation  of conformity of organisations  and issuance of a certificates. 
  Certification  Body  implemented  procedures  for  audits  that  address  topics  such  as:  audit  frequency;  the  requirement for on -
site (field) visits w here applicable;  sampling  protocols; unannounced  or short-notice audits, and other aspects of auditing. 
ensuring  that  Certification  Bodies  conduct  consultation  w ith stakeholder (including rights holders) as appropriate in relation to 
audits. 

 

The  fifth  indicator  (B.2.2.2) has been evaluated as Partially Covered. Mechanisms exist w hich could identify and deal w ith corrupt 
practices  by  Certificate  Holders.  How ever,  there  are  no  normative  requirements,  nor  formal  processes,  for  identifying 
Organisations  sanctioned for engagement  in corrupt practices proactively and prior to association  w ith FSC.   

95 

B. 
Certification  Bodies 

Requirements 

for 

B.1  General  Certification  Body 
requirements 

Partially 
covered 

B.2 
Body 
Certification 
requirements  for  auditing  and 
certification 

Partially 
covered 

C. 
Requirements 
Certification  Schemes 

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C.1  Transparency 

Partially 
covered 

Five  of  the  six  indicators  have  been evaluated as covered, based on the normative requirements.  These concern collectively, the 
follow ing: 

 

 

Scheme  requirements  for  Certificate  Holders  and  Certification  Bodies,  as  w ell  as  other  relevant  information  about  the 
Scheme  must  be publicly and freely available  online. 
publicly availability of an up-to-date register of certified/verified organisations, as w ell as summaries of reports (or full reports) 
w ith relevant findings from audits. 
Procedures  for handling  complaints  and grievances being  in place,  publicly available  and implemented. 

 
The  sixth  indicator  has  been  evaluated  as  Partially  Covered.  The  normative  requirements  applicable  to  supply -chain  certificate 
holders do not fully cover the requirement  to manage  risks of corruption and conflict of interest. 

C.2  Scheme  & 
scope 

standard 

Partially 
covered 

The  tw o indicators evaluated  as covered, concern that:   

 

 

the  scheme  includes  a  list  of  the  relevant  international  conventions  to  w hich  the  country  has  ratified,  and  w hich  hold legal 
force in the country. 
requirements  for  forest  managers and supply chain entities to be applicable to the organisation’s contractors and outsourcing 
facilities. 

One  of  the  four  indicators  w ithin  this  criterion,  one  has  been  evaluated  as  Partially  Covered  and  tw o  have  been  evaluated  as 
Covered,  based  on  the  normative  requirements.  The  fourth  is  not  applicable  because FSC does not recognise nor endorse other 
schemes or systems (C.2.4.1). 

Indicator  C.2.1.1  concerns  standards  being  adapted  to  the  national  or  subnational  context  in  w hich  they  are  being  implemented 
and  containing  a  list  of  applicable  legislation,  or  that  the  Scheme  shall  enable/require  detailed  evaluation  of  applicable  legislation 
in  a  national  context.  This  indicator  has  been  evaluated  as  Partially  Covered,  due  the  delays  in  updating  all  National  Forest  
Stew ardship Standards (NFSS)  to meet  the updated  international  Principles  and Criteria  (FSC-STD-01-001  V5). 

C.3 
oversight 

Accreditation 

and 

Partially 
Covered 

Seven  of  the  eight  indicators  have  been  evaluated  as  covered,  based  on  the  normative  requirements.  Four  of  them  c oncern 
collectively,  different aspects of accreditation: 

 

 

the  scheme  must  have  a  system  for  accreditation  or  oversight  of  Certification  Bodies  to  ensure  that  CBs have in place the 
required procedures, capacity and competencies. 
requirements  and  the  process  for accreditation must be publicly available, as is an up-to-date list and details of all accredited 
Certification  Bodies. 

  mechanisms  to  ensure  that  relevant  personnel  are  qualified  and  competent  to  evaluate  the  performance  of  Certification 

Bodies. 

Three  more indicators  concern collectively, different aspects of oversight mechanisms: 

 

the  specification  of  the  approach  to  be  used  in  oversight,  ensuring  that  the  oversight  mechanism  is  independent  of  the 

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 
 

Certification  Bodies being  assessed.  
the frequency of oversight - or the procedure for determining  the frequency - applicable  in the case of risk-based oversight. 
the  use  of  both  stakeholder  consultation  and  in-field  evaluation  of  performance  during  the  accreditation  of  certification 
bodies. 

One indicator  is evaluated  as Partially  Covered,  concern that the scheme: 

 ensures  that  the  oversight  mechanism  applies  a  clear  basis  for:  establishing  conformance;  raising  corrective  actions  for  non -
conformance,  ensuring  closure  w ithin  reasonable  timeframes,  and  certification  issue/maintenance  decision  making  (C.3.2.2). FSC 
requirements  for  non-conformities  are  structured  in  a  w ay  that  there  is  a  potential  risk  that  a  non-conformity  may  represent  an 
infringement  of  legislation  and  that,  as  a  result,  illegal  w ood  may  enter  the EU market w ithout mitigation measures to prevent this 
from occurring for a period of up to 3 or 12 months 

C.4  Certification  process 

Partially 
covered 

Three  of  the  four  indicators  for  this  criterion  have  been  evaluated  as  Covered,  based  on  the  normativ e  requirements.  These 
encompass  the certification process and compliance  evaluation. 

One  indicator  is  concluded  as  partially  covered,  ow ing  to  the  same issue as described in C.3.2.2 above. There is a potential  risk 
that  a  non-conformity  may  represent  an  infringement  of  legislation  and  that,  as  a  result,  illegal  (or  non-negligible)  w ood  from 
entering  the EU  market  w ithout mitigation  measures to prevent this from occurring for a period of up to 3 or 12 months. 

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12.2 Understanding  FSC labels and claims 

FSC also allows a range of claims depending on the composition of the material in terms 
of the certification status of the materials included in the product. FSC uses the terms 
100%  to  indicate  material  that  all  originates  from  a  certified  source,  MIX  to  indicate 
material  that  originates  from  certified  material  and  non-certified Controlled Wood and 
Recycled, as well as a Recycled claim. Claims are transferred between certified entities 
on the invoice for the material. 

The FSC claims and trademarks are managed using the standard FSC-STD-50-001.26  

For material that originates only from certified forest the 100% claim is used.  

For material that is a mix between certified and Controlled Wood or recycled material the 
MIX  claim can be used. 

26 https://fsc.org/en/document-centre/documents/resource/225  

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For  material  only  originating from recycled sources the Recycled claim is used on the 
following label: 

FSC  also  allows  smallholders,  certified  against  the  Small  or  Low  Intensity  Managed 
Forests  (SLIMF)  standard  to  use  a  separate  label  with  a  claim  related  to  the  SLIMF 
certification. 

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13.  Sustainable Biomass Program (SBP) 

The Sustainable Biomass Program (SBP) is a risk-based certification scheme for sourcing 
of biomass that aims at accepting input from different large and well-known certification 
schemes, or from its own evaluation framework, in order to have one system for certified 
biomass.  The  risk-based  approach means that there are no SBP-certified forests, but 
biomass  is  verified against risk assessments based on SBP criteria. If raw material for 
biomass (so called feedstock) is not sourced through an approved certification schemes, 
SBP’s Standards for feedstock compliance are used instead. This means that the SBP 
framework for risk identification, supplier monitoring, and risk mitigation defined in these 
Standards must be implemented (see more details below). 

SBP was founded in 2013 and was initiated by large energy producers in Europe under 
the name Sustainable Biomass Partnership. Today, the energy producers’ role has faded 
in order to make SBP an independent and impartial certification scheme. At present, the 
board  consists  of  three  stakeholder  representatives from each of the following areas: 
biomass end-users, Biomass Producers and civil society. 

In the SBP Annual Review Report (2020), the SBP declared that by the end of 2019 they 
had 210 certificate holders whereof 167 were Biomass Producers, 35 traders and 8 end -
users. The SBP’s geographical extent of certificate holders included 25 different countries 
in Europe, Asia, Oceania, North and South America. The amount of certified biomass sold 
through the SBP system was 12 million tons (Mt) of biomass (wood chips or wood pellets). 

SBP are committed to following the ISEAL Codes of Good Practice for Standard -setting, 
assurance  and  impacts.  The  SBP  Secretariat  manage  the  Standards  Development 
Process and support the work of the various Working Groups responsible for developing 
the content, with significant input from the Standards Committee, Technical Committee 
and Stakeholder Advisory Group, as well as Certificate Holders, Certification Bodies and 
Accreditation Body. All interested parties shall have the opportunity to participate in the 
Standard  development  process  through  getting  involved  in  the  work  of  the  various 
Working  Groups,  public  consultations,  events  or  simply  through  getting  in  touch  and 
providing  SBP  with  views  and  ideas.  However,  the  SBP  scheme  is  no  member 
organization with different stakeholder chambers that can vote and directly influence the 
standard development. The Standards Committee is finally approving the Standards. 

The Standard committee has six representatives from commercial interests and six from 
civil society interests. There is a Stakeholder Advisory Group whose role is to provide a 
platform  for  stakeholder  input  and  advice  to  support  the  work  of  the  SBP  Standards 
Committee in the development, implementation and maintenance of SBP Standards and 
related  documents,  and  other  relevant  activities.  Certification  Bodies  are  doing 
stakeholder  consultations  during  assessments  and  re-assessments  of  Biomass 
Producers. Traders applying for a certification evaluation is not exposed to stakeholder 
consultation. 

SBP  has  no  regional  or  country  standards  but  implement  all  its  standards  on  an 
international level. Standard indicators at the forest level are addressed in such way that 
they  shall  be  adapted  to  reflect  risks  and  situations  in  specific  regions  where  it  is 
implemented. This is done through the risk assessment process where all indicators are 
evaluated  in  its  local  context  (country  or  regional  level).  Risks  identified  in  the  risk 
assessment must be mitigated by the Biomass Producer before feedstock can be sourced 
from the area. 

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The SBP scheme accepts input from other certification schemes and SBP implements the 
term  “SBP-approved”  scheme,  system  or  claim.  The  forest  management  certification 
schemes currently approved by SBP are: FSC® and PEFC including direct sourcing from 
all  PEFC-endorsed  Forest  Management Schemes (e.g. SFI). SBP also approves non -
certified  input  from  FSC,  PEFC  and  PEFC  endorsed  schemes.  For  example,  FSC 
Controlled Wood and PEFC Controlled Sources, and input from the SFI Fiber Sourcing 
Standard. There are currently no system or procedures, nor written information, relating to 
how  SBP  has  approved the  certification schemes to become SBP eligible input. It was 
decided to approve FSC and PEFC-endorsed forest management schemes back in 2015 
when  SBP  started  up.  According  to  SBP,  their  secretariat  is  currently  working  on 
formalizing this process. 

There  are three ways for material to be accepted into the SBP system (i.e., physically 
enter the system): 

1.  through an SBP Supply Base Evaluation (SBE) covering the entire supply base, 
where  risks  are  identified  in  regional  Risk  Assessments  (see more information 
below) 

2.  through already certified material from SBP-approved schemes: F SC, PEF C and 
PEFC-endorsed  schemes  (e.g.  SFI).  This  material  must  be  received with valid 
claims from these certification schemes. 

3.  controlled material from SBP-approved schemes: FSC, PEFC and PEFC-endorsed 
schemes (e.g. SFI) that are received with valid claims or origins from the Biomass 
Producer’s  own  control  system  in  line with applicable scheme requirements for 
these schemes. 

SBP  certified  (called  SBP-compliant) biomass can only be accepted  as compliant if its 
originates from one of the two first points, but can physically be mixed with, and thus also 
contain, SBP-controlled biomass. In other words, there is no claim to ensure the biomass 
only  contains  100%  SBP-compliant  biomass,  but  it  can  always  be  mixed  with  SBP-
controlled biomass. 

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13.1 Summary  of SBP scheme  assessment findings 

In total, out of the 84 indicators of the scheme assessment framework evaluated within the study, 65 were concluded as “Cover ed”, 13 as “Pa rtially 
Covered” and 5 as “Not Covered”. One indicator was concluded as “Not Applicable”. 

Table 7: Summary of SBP findings. 

SBP – Cov erage of applicable legislation of 
certified material 

SBP – Cov erage of other requirements for certificate holders 

SBP – Cov erage of requirements for scheme gov ernance 

 Criteria 

Indicator 

 Criteria 

Indicator 

 Criteria 

Indicator 

A3.1 Material control 

A3.2 Recycled material 

A4.1 Conflict resolution 
A4.2 Corruption 
A5.1 Internal procedures for Certificate 
Holders 
A5.2 Qualification and competence 
A5.3 Risk based approaches to sourcing, 
trade or production 

A3.1.1.1 
A3.1.1.2 
A3.1.1.3 
A3.1.1.4 
A3.2.1.1 
A3.2.1.2 
A3.2.1.3 
A4.1.1 
A4.1.2 
A5.1.1 
A5.1.2 
A5.2.1 
A5.3.1 
A5.3.2 
A5.3.3 
A5.3.4 

A1.1 Rights to harv est timber   

A1.2 Payments for harv est rights 
and timber   
A1.3 Timber harv esting 

A1.4 Third  parties’ legal rights 

A1.5 Trade and customs 

A2.1 Legal registration 
A2.2 Taxes and fees 

A2.3 Trade and transport 

A1.1.1.1 
A1.1.1.2 
A1.1.1.3 
A1.1.2.1 
A1.1.3.1 
A1.1.3.2 
A1.1.4.1 
A1.2.1.1 
A1.2.2.2 
A1.3.1.1 
A1.3.1.2 
A1.3.2.1 
A1.3.2.2 
A1.3.3.1 
A1.3.4.1 
A1.3.5.1 
A1.3.5.2 
A1.4.1.1 
A1.4.1.2 
A1.4.2.1 
A1.4.3.1 
A1.5.1.1 
A1.5.2.1 
A1.5.3.1 
A1.5.4.1 
A1.5.5.1 
A1.5.6.1 
A2.1.1.1 
A2.2.1.1 
A2.2.2.1 
A2.3.1.1 
A2.3.2.1 

B1 General Certification Body requirements 

B2 Certification Body requirements for 
auditing and certification 

C1 Transparency 

C2 Scheme & standard scope 

C3 Accreditation and ov ersight 

C4 Certification process 

B1.1.1 
B1.1.2 
B1.2.1 
B1.2.2 
B2.1.1 
B2.1.2 
B2.1.3 
B2.2.1 
B2.2.2 
C1.1.1 
C1.1.2 
C1.1.3 
C1.1.4 
C1.2.1 
C1.3.1 
C2.1.1 
C2.2.1 
C2.3.1 
C2.4.1 
C3.1.1 
C3.1.2 
C3.1.3 
C3.1.4 
C3.2.1 
C3.2.2 
C3.2.3 
C3.2.4 
C4.1.1 
C4.1.2 
C4.1.3 
C4.1.4 

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A2.3.3.1 
A2.3.3.2 
A2.3.4.1 
A2.3.5.1 
A2.3.6.1 

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Coverage by the scheme of legal requirements at the forest level  

It should be noted that the coverage of the SBP scheme is dependent, to a large extend, 
on  the  strength  of  the  schemes  they  approve  –  currently  FSC  and  PEFC  endorsed 
schemes. Many of the Biomass Producers use only input from these approved certification 
schemes. Therefore, conclusions from this report need to be supported b y considering 
strengths  and  weaknesses  from  the approved schemes. Wood sourced from land not 
classified as forest land is included in the scope of this evaluation. 

In  general,  the  SBP  scheme  standards  cover  most  requirements  of  the  Scheme 
Assessment Framework including requirements for Certificate Holders, the Certification 
Bodies  and  the  Scheme.  SBP  is  considered  relatively  transparent  and  has  public 
summary  reports  that  includes  most  information  from  the  audit,  for  example  non -
conformities. Also, the Supply Base Reports and Supply Base Evaluations, including risk 
ratings, are publicly available. 

Some issues have been identified that could constitute a weakness in the scheme’s ability 
to meet important aspects of legality quality assurance. 

There is no requirement within the SBP Standards to control illegal activities related to 
offshore trading and transfer pricing. There are two requirements that aims at covering 
EUTR in a general way in Standard 4 (6.1.2 and 6.1.3) and one requirement that attempts 
to cover all applicable laws in the country where the certificate holder conduct its business 
(Standard 4, 6.3.3). However, these requirements are general and not comprehensive 
enough to cover specific issues like offshore trading and transfer pricing without fu rther 
specifications or guidelines. 

Coverage by the scheme of legal requirements at the supply  chain  level  

There are no requirements explicitly covering payment of VAT, other sales taxes or taxes. 
There  are requirements for control of sales invoices and for payment of any fees and 
duties, but VAT or other types of taxes are not explicitly mentioned in these requirements. 
Therefore, this is only considered to be partially (or potentially) covered by the SBP chain 
of custody Standard.  

Material control 

The  SBP  has  implemented  a  data  transfer  system  (DTS)  for  digital  transactions  of 
biomass with SBP-claims. This system must be used in order to transfer valid claims. This 
means  that  SBP  or  auditors  can  see  all transactions in the supply chain and that the 
amount of biomass cannot be inflated further down the supply chain. SBP has also started 
to implement an on-line reporting portal. This portal must be used by certification bodies 
and certificate holders and enables increased digital monitoring of information a dded into 
the audit reports, Supply Base Reports or Supply Base Evaluations. For example, risk 
ratings or information used by the accreditation body will be easy to find and summarise.  

Other requirements of the Certification scheme 

SBP  itself  has  no  system  or  written  procedures  for  how  to  approve  new  certification 
schemes. This is found to be a significant gap in the scheme, since there is no information 
regarding criteria for approval of schemes and many of the chain of custody requirements 
in the SBP Standard 4 rely on the approved CoC-scheme (e.g. requirements related to 
written procedures). It should be noted that SBP has not approved any new schemes after 
approval of FSC, PEFC and PEFC-endorsed schemes, but PEFC endorses new schemes 

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which then also affects SBP. According to SBP, their secretariat is currently working on 
written procedures for approvals of other certification schemes. 

If the certificate holder is not a Biomass Producer, there is no requirement for Certificate 
Holders to review the proper functioning of their own procedures internally and regularly 
(A5).  However,  this  is  not  assessed  as  a  critical  gap  since  annual  audits  from  an 
independent certification body is required. 

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Table 8: Overview of assessments findings for SBP. 

Requirem ent Section 

Conclusion 

Sum m ary 

A. Requirements  for Certificate  Holders 

A.1 Legal  Requirements  at the forest level 

A.1.1  Rights 
boundaries 

to  harvest 

timber  w ithin 

legally  gazetted 

Partially  covered 

There  are  no  requirements  related  to  the  use  of  legal  methods  to  obtain  legal  rights  to  harvest 
(A.1.1.2.1) 

A.1.2  Payments  for  harvest rights and timber including duties 
related  to timber  harvesting 

Partially  covered 

SBP  does  not  specifically  include  mention  of  land  area taxes. The indicator is considered partially 
covered (A.1.2.1.1) 

A.1.3  Timber  harvesting,  including  environmental  and  forest 
legislation 
forest  management  and  biodiversity 
conservation, w here directly related to timber  harvesting 

including 

A.1.4  Third  parties’  legal  rights  concerning  use  and  tenure 
that are affected by timber  harvesting 

Covered 

All indicators of this  criterion are covered by the Scheme 

Partially  covered 

There  is no mention  of FPIC  in the standards (A.1.4.2.1) 

A.1.5  Trade  and  customs,  in  so  far  as  the  forest  sector  is 
concerned 

Partially  covered 

There  is  no  specific  requirement  regarding  offshore  trading  and  transfer  pricing  in  the  SBP 
Standards.  Existing  requirements  are  considered  too  general  to  catch  these  illegal  activities. 
(A.1.5.3.1) 

A.2 Legal  requirements  for supply chain entities 

A.2.1. Legal registration 

Covered 

The  SBP  scheme  requires  all  Certificate  Holders  to  enter  into  a  Trade  Mark  Licence  Agreement 
w ith  SBP  (Standard 3 clause 13.4) and certification agreement w ith a Certification Body  (Standard 
3  section  13).  Signing  both  documents  includes  verification  of  a  Certificate  Holder’s  legal 
registration  and hence SBP  is compliant  in this regard 

A.2.2 Taxes and fees 

Partially  covered 

There  is a requirement  for payment  of any fees, taxes and  duties, mentioned  in this requirement 

There is requirement for control of sales invoices and for payment of any fees and duties, but VAT 

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A.2.3 Trade  and transport 

Partially  covered 

transportation  documentation  is not explicitly mentioned  in any SBP  requirement  (A.2.3.2.1)  

or other types of sales taxes are not explicitly  mentioned  in these requirements  (A.2.2.2.1)  

There  is no requirement  regarding offshore trading  in SBP  Standards.  Or  

There  is no requirement  regarding transfer pricing  in SBP  Standards  (A.2.3.3.1) 

Requirement  only  covers  material  still  defined  as  feedstock  under  the  SBP  system.  Export  of 
biomass  containing  CITES  species is not covered (A.2.3.3.2) 

A.3 Requirements  for material  control 

A.3.1 Material  control 

A.3.2 Recycled  material 

Covered 

Covered 

All indicators of this criterion are covered by the Scheme 

All indicators of this criterion are covered by the Scheme 

A.4 General  requirements  for Certificate  Holders 

Covered 

A.4.1 Conflict  resolution 

A.4.2 Corruption 

Covered 

Covered 

The  indicator  for  this  criterion  has  been  evaluated  as  Covered,  based  on  the  scheme  normative 
requirements.   

The  indicator  for  this  criterion  has  been  evaluated  as  Covered,  based  on  the  scheme  normative 
requirements.   

A.5  Quality  and  procedural  requirements  for  Certificate 
Holders 

A.5.1 Internal  procedures for Certificate Holders 

Partially  covered 

There  is  no  SBP  requirement  after  the  BP  that  covers  w ritten  procedures  for  all  requirements. 
This  relies  on  the  SBP-approved  CoC-system  and  there  are  no  w ritten  procedures  for  how  SBP 
approves schemes.  (A5.1.1) 

There  is  a  standard  revision  process  ongoing  and  that  the  requirement  to  have  documented 
procedures  and  internal  audits  for  all  SBP  CHs  is  included  in  the draft new  Standard 4. This can 
be  checked  from  the  documents  on  the SBP w ebsite:  https://sbp-cert.org/documents/consultation-
documents/live-consultations/rdv1-36/ 

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A.5.2 Qualification  and competence 

Covered 

A.5.3  Risk  based  approaches 
production 

to  sourcing, 

trade  or 

Partially  covered 

If  the  certificate  holder  is  not  a  Biomass  Producer,  there  is no requirement for Certificate Holders 
to review  the proper functioning of their ow n procedures internally  and regularly (A.5.1.2)  

SBP  has no clear procedures on how  to recognize other certification schemes. This is considered 
a major gap since material from other schemes can enter the supply chain through the use of their 
ow n  DDS  (A.5.3.3)  It  should  be  mentioned  that  currently  SBP  only  have  endorsed  FSC  and 
PEFC. 

B. Requirements  for Certification  Bodies 

B.1 General  Certification  Body requirements 

Covered 

All indicators of this criterion are covered by the Scheme 

B.2  Certification  Body 
certification 

requirements 

for  auditing  and 

Covered 

All indicators are met. 

C. Requirements  for Certification  Schemes 

C.1  Transparency 

Covered 

All indicators of this criterion are covered by the Scheme 

C.2  Scheme  & Standard scope 

Partially  covered 

In  SBP  Standards  there  are  no  specific  requirements  addressed  to  a  specific country of harvest 
(C.2.1.1  and C.2.2.1). 

C.3  Accreditation and oversight 

Partially  covered 

C.4  Certification  process 

Partially  covered 

The  SBP  scheme  ensure  ASI  continuously  evaluate  CBs’  performances,  including  reporting  of 
non-conformities  and timelines for follow -up on these. CB’s must follow -up on non-conformities, or 
they  get  suspended.  Requirements  for  non-conformities  are  structured  in  a  w ay  that  there  is  a 
potential  risk  that  a  non-conformity  may  represent  an  infringement  of  legislation  and  that,  as  a 
result,  illegal  w ood  may  enter  the  EU  market  w ithout  mitigation  measures  to  prevent  this  from 
occurring for a period of up to 3 or 12 months  (C.3.2.2). 

Requirements  for non-conformities are structured in a w ay that there is a potential risk that a non-
conformity  may  represent  an  infringement  of  legislation  and that, as a result, w ood may enter the 
EU  market  that could be interpreted  as illegal  or non-negligible  risk ((C.4.1.2 and C.4.1.2) 

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13.2 Understanding  SBP claims 

SBP allows two claims to be used in connection with the biomass supply chains. There 
are no partial claims (reflecting the composition of the certified material in the product), so 
the  material  can  be  either  fully  certified  (SBP  compliant  biomass)  or  controlled  (SBP 
controlled biomass). A mass balance system is used which means that physically, not all 
material or input must be certified. The mass balance can thus be  used to make an output 
claim on a volume corresponding to the same input volume of either SBP compliant or 
SBP controlled biomass. 

To pass the certified claim to a buyer, SBP implements an online Data Transfer System, 
and the claim is only valid if the transaction is shared via this system. 

The  SBP  claims  and trademarks are managed using the standard SBP standard sbp -
standard-4-chain-of-custody-v1-0. 

SBP trademark can be used only off-product and SBP does not allow any on-product use 
of trademarks. Any use of trademark shall be approved by SBP prior its used. 

14.  ISO 38200 

ISO  is  the  International  Organization  for  Standardization.  It was set up in 1947 and is 
located  in  Geneva,  Switzerland.  Its  purpose  is  to  facilitate  and  support  national  and 
international trade and commerce by developing standards that people everywhere would 
recognize and respect.  

ISO  develops  standards  that  can  be  applied  on  a  voluntary  basis.  Standards  are 
developed  for  different  kinds  of  goods,  services  and  systems  through  the  different 
technical  committees  that  constitutes  of  experts  within  the  field  for  which  they  are 
developing standards (iso.org, N.Y(e)). ISO is not a certification scheme.  

ISO achieves this purpose through the participation and support of its members. These 
members come from 165 national standards bodies. 

ISO standards are developed by technical committees. The people who serve on these 
technical  committees  come  from  national  standards  organizations. Consequently, ISO 
standards  tend  to  have  worldwide  support.  Currently,  ISO  has  250  active  technical 
committees, 510 subcommittees, and 2478 working groups. 

The General Assembly is the overarching organ and ultimate authority of ISO (ISO.org, 
N.Y(c)). The ISO Council is the core governance body of the Organization and repor ts to 
the  General  Assembly  where  the  member  organizations  meet  annually.  A  Technical 
Management  Board  (TMB)  is  responsible  for  the  technical  committees  that  lead  the 
standard  development and reports to the Council. The Central Secretariat in Geneva, 
Switzerland coordinates the ISO system and runs day-to-day operations. 

ISO 38200:2018 Chain of custody of wood and wood-based products was developed by 
the  technical  committee  ISO  PC  287  and  was  published  in  2018.  The  International 
Standard  provides  a  set  of  requirements  for  a chain of custody system to enable the 
exchange and tracking of information on wood and wood -based products throughout a 

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supply chain. ISO 38200 requires the implementation of a due diligence system based on 
risk management practices to ensure that materials entering the CoC has a legal origin. 

The standard “ISO 38200:2018 Chain of custody of wood and wood-based products” sets 
requirements  for  a  chain  of  custody  system  to  enable  the  exchange  and  tracking  of 
information on wood and wood-based products throughout a supply chain.  

It includes traceability measures (CoC) as well as due diligence requirements to ensure 
that only legal input material is included in the CoC system.  

ISO 38200 was designed to provide a consistent basis against which the chain of custody 
of  wood  and wood-based products can be assessed. It includes traceability measures 
(CoC) as well as due diligence  requirements to ensure that only legal input material is 
included in the CoC system. The Standard is intended to be used for several purposes 
(based on the ISO 38200:2018 Introduction and section 1. Scope) : 

 

facilitate business-to-business communications by providing a common framework 
that allows businesses to “speak the same language” when describing their chain 
of custody system (regardless of company size) 

  For  purchasers  to  evaluate  the information they receive from suppliers to help 

identify suitable input material 

  For Other standards and certification schemes to use the ISO 38200:2018 as a 

reference regarding chain of custody systems 

ISO 38200:2018 sets requirements for setting up a CoC and due diligence system. The 
due diligence system shall include the elements of information gathering, risk assessment 
and mitigation measures. The organization has to develop documented procedures, as 
well as document and keep records of their implemented mitigation measures. Annexes 
with guidance on applicable legislation, risk indicators and description of CoC is included, 
but are not mandatory to follow.  

Considering  that  ISO  adopts  the  neutrality  principle  when  it  comes  to  conformity 
assessment, its International Standards must allow that such processes are conducted  by 
1st, 2nd and 3rd parties. In practice this means that an organization can claim compliance 
with  the  standard  without  a  3rd party conformity assessment, but to claim certification 
against ISO 38200 requires a 3rd party assessment by a certification body. It is however, 
not required for the certification body to be accredited by an accreditation body to certify 
against ISO 38200. Even if the CB is accredited, the accreditation body will not have to 
follow  the  ISO  standards  on  conformity  assessment  for  accreditation  and certification 
bodies  (e.g. 
ISO/IEC  17011:2017  (Conformity  assessment  –  Requirements  for 
accreditation  bodies  accreditation  conformity  assessment  bodies),  and  ISO/IEC 
17065:2012  (Conformity  assessment  –  Requirements  for  bodies  certifying  products, 
processes and services). 

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14.1 Summary  of ISO 38200 findings 

48 indicators of the evaluation framework are “Partially Covered”, while 11 are “Covered”, and 25 are “Not Covered”.  

Table 9: Summary of ISO 38200 findings. 
ISO – Cov erage of applicable legislation of certified material 
 Criteria 
A1.1 Rights to harv est timber   

Indicator 

ISO – Cov erage of requirements for scheme gov ernance 
 Criteria 
B1 General Certification 
Body  requirements 

Indicator 

A1.2 Payments for harv est rights 
and timber   
A1.3 Timber harv esting 

A1.4 Third  parties’ legal rights 

A1.5 Trade and customs 

A2.1 Legal registration 
A2.2 Taxes and fees 

A2.3 Trade and transport 

A1.1.1.1 
A1.1.1.2 
A1.1.1.3 
A1.1.2.1 
A1.1.3.1 
A1.1.3.2 
A1.1.4.1 
A1.2.1.1 
A1.2.2.2 
A1.3.1.1 
A1.3.1.2 
A1.3.2.1 
A1.3.2.2 

A1.3.3.1 
A1.3.4.1 
A1.3.5.1 
A1.3.5.2 
A1.4.1.1 
A1.4.1.2 
A1.4.2.1 
A1.4.3.1 
A1.5.1.1 
A1.5.2.1 
A1.5.3.1 
A1.5.4.1 
A1.5.5.1 
A1.5.6.1 
A2.1.1.1 
A2.2.1.1 
A2.2.2.1 
A2.3.1.1 
A2.3.2.1 
A2.3.3.1 
A2.3.3.2 
A2.3.4.1 
A2.3.5.1 
A2.3.6.1 

ISO – Cov erage of other requirements for certificate holders 
 Criteria 

Indicator 

A3.1 Material control 

A3.2 Recycled material 

A4.1 Conflict resolution 
A4.2 Corruption 
A5.1 Internal procedures for 
Certificate Holders 
A5.2 Qualification and 
competence 
A5.3 Risk based approaches to 
sourcing, trade or production 

A3.1.1.1 
A3.1.1.2 
A3.1.1.3 
A3.1.1.4 
A3.2.1.1 
A3.2.1.2 
A3.2.1.3 
A4.1.1 
A4.1.2 
A5.1.1 
A5.1.2 
A5.2.1 

A5.3.1 
A5.3.2 
A5.3.3 
A5.3.4 

111 

B2 Certification Body 
requirements for auditing 
and certification 

C1 Transparency 

C2 Scheme & standard 
scope 

C3 Accreditation and 
ov ersight 

C4 Certification process 

B1.1.1 
B1.1.2 
B1.2.1 
B1.2.2 
B2.1.1 
B2.1.2 
B2.1.3 
B2.2.1 
B2.2.2 
C1.1.1 
C1.1.2 
C1.1.3 
C1.1.4 

C1.2.1 
C1.3.1 
C2.1.1 
C2.2.1 
C2.3.1 
C2.4.1 
C3.1.1 
C3.1.2 
C3.1.3 
C3.1.4 
C3.2.1 
C3.2.2 
C3.2.3 
C3.2.4 
C4.1.1 
C4.1.2 
C4.1.3 
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Coverage by the scheme of legal requirements at the forest level  

For users inside the EU it is expected that they meet legal requirements (also the EUT R) 
according to Section 5.3.2 of the standard, and therefore use the definition of legality of 
the  EUTR.  However,  for  ISO  38200  certificates  originating  outside  the  EU,  different 
definitions of the applicable legislation may have been used in the due diligence system, 
which means that there cannot be made a firm conclusion on the legality definition being 
applied on material sourced outside the EU under an ISO 38200 certification. Also, there 
is  no  requirement  in  the standard for the organisation buying material certified to ISO 
38200 to evaluate the legality definition being used by suppliers.  

The standard is clear in requiring that only legally harvested and legally procured material 
can enter the chain of custody system of a company. To avoid illegally harvested and 
procured material a risk assessment shall be developed based on relevant risk indicators, 
and  illegal  harvesting  of  CITES  listed  or  nationally  protected  species  are  specifically 
mentioned. Other relevant categories of law are listed in annexes that provide general 
guidance  on  identifying  applicable legislation. The legality definition of Annex E of the 
standard is a replication of the definition of applicable legislation found in the EU T imber 
Regulation (Regulation 995/2010). However, these annexes are informative and therefore 
not mandatory to follow. 

This fact constitutes a potential gap in the ISO 38200:2018 certified supply chain, that 
could allow material with an inadequate legality definition in the due diligence system, to 
enter the EU market with a certified claim. The standard leaves room for co mpanies to 
define  the  categories  of  relevant  legislation  against  which  they  evaluate legality risks 
under  their  due  diligence  system  that  are  not  necessarily  in  conformance  with  the 
categories of law defined under the EUTR.  

Thus, to know which legislation is evaluated under a company’s due diligence system it is 
necessary to investigate each organisation’s specific due diligence system.  

The main issue in making an overall conclusion on what the scope will cover and how the 
standard is implemented relate to lack of specification of the mandatory requirements on 
what types of legislation shall be considered under the due diligence system, as well as 
detailed  guidance  to  interpret  the  standard  and  the  requirements.  The  Technical 
Committee ISO PC 287 is currently working on developing further guidance related to the 
due diligence implementation. 

The scheme has a definition of recycled material that correspond with the EUTR and there 
are  requirements  in  place  to  ensure  that  evidence  is  collected  to  show  that  inpu t  is 
recycled material and has been legally procured. The definition and handling of recycled 
material are considered to be in conformance with the EUTR.  

Coverage by the scheme of legal requirements at the supply  chain  level  

Information, such as common name of tree species (or scientific name if needed), country 
of harvest, and evidence that applicable legal requirements are fulfilled shall be collected 
for input material, except recycled and certified material. There are clea r requirements for 
DDS  to  be  conducted  when  information  is  changed.  According  to  the  EUTR  certified 
material  is  not  exempt  from  the  requirement  of  applying  due  diligence,  including  the 
requirement to gather information on species and origin or evidence of legal compliance. 
However, this information is not required to be collected for certified material under the 
ISO 38200 standard. So, while information to be collected for non -certified material is in 
conformance with the EUTR, this is not the case for certified material.  

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The organisation must identify the legal requirements applicable to their supply chain and 
document how the requirements are addressed. The coherence of these processes is 
checked during audits. The risk assessment process itself is generally in compliance with 
the EUTR, but it is unclear how it is implemented in practice, as there is little guidance in 
place  for  organisations  (and  for  certification  bodies)  on  how  to  interpret  legislation, 
evaluate risks and apply risk mitigation.  

Material control 

All input material covered by the chain of custody system of ISO 38200 will have to be 
assessed  following  the  requirements of the standard and the ones established by the 
organisation responsible for the CoC Input material shall be classified as verified (by the 
due diligence system, certified, specified (verified material classified following additional 
requirements established by the organisation), as well as recycled material. For recycled 
material  it  shall  be  verified  that  it  is  material  that has been recovered from the waste 
stream, either from the manufacturing process [i.e. post-industrial recycled materials, but 
not in-house scrap] or after consumer use. 

Other requirements for certificate holders 

The  system  requirements  for  certificate  holders  (or companies in compliance with the 
Standard)  that  are  considered  fully  covered  by  the standard relates to having a CoC 
system  (including  a  due  diligence  system)  in  place  to  ensure  compliance  with  the 
requirements of the standard. The organisation shall carry out annual audits to make sure 
that both the requirements of the standard and the organisations own requirements are 
well in place. Also, the organisation shall have the competence needed across all relevant 
personnel and suppliers.  

If  sourcing  certified  material  from  3rd  party  systems,  it  must  be  confirmed  that  the 
certification scheme has requirements to evaluate the legality of forest management that 
are broad enough to cover the organization’s DDS. Evaluation of supply chain risks are 
not mentioned, and it is therefore unclear how supply chain risks on trade and taxes are to 
be covered by certification. 

The risk assessment process is generally in compliance with the EUTR but it is unclear 
how it is implemented in practice as there is a lack of detailed requirements/guidance on 
the evaluation of risks and applying the risk assessment process.  

The  standard  does  not  specifically  mention  that  the  organisation  shall  avoid  getting 
involved  in  corruption,  or  handling  of disputes and conflicts. However,  there are clear 
requirements for the company to operate legally.  

Requirements for Certification Bodies and Certification Schemes 

ISO 38200 is a standard and not a scheme, and there is therefore no mechanism with 
normative requirements in place related to the ISO 38200 standard on how certification 
bodies are accredited and managed. It should be underlined that the ISO 38200 was not 
developed  with  the  purpose  of  certification  of  wood-based  products,  but  as  an 
international standard that can be used for several purposes, including use by certification 
schemes as a reference to CoC systems, and for companies to communicate in the same 
language. 

As ISO 38200:2018 is no scheme, there is no mechanism with normative requirements in 
place related to the ISO 38200 standard on how certification bodies are accredited and 
managed. Certification bodies can operate without an accreditation. Also, it is voluntary for 

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accreditation bodies to accredit against ISO standards on conformity assessments. T his 
means that there is no streamlined approach for the implementation of ISO 38200, and it 
is not possible to evaluate the global application/implementation of the standard through 
publicly available documents. Therefore, there can be differences in the requirement for 
accreditation and for CBs certifying against ISO 38200, both from country to country, as 
well as between certification bodies within one country.  

This  can  allow  for a more flexible use of the standard and provides for alternatives to 
companies who want an alternative to other CoC certification schemes. 

The standard considers outsourcing in terms of the organisations CoC system and clear 
identification of the material being handled under outsourcing. Beyond that, there are no 
mandatory  scheme  requirements  in  place  to  manage  the  process  of  certification. 
According to the Technical Committee, certification bodies commonly use ISO standards 
for developing their systems, but it is not possible to make such conclusion based on this 
standard evaluation.  

There is no international oversight mechanism of the ISO 38200 standard implementation. 
ISO  38200  does  not  define  an  overall  system  in  place  to  monitor  the  overall 
implementation,  and  there  is  no  list  of  CBs  or  certificate  holders  available  at  an 
international level.   

The lack of guidelines and limited information on applying the standard means that it is not 
possible  to  make  an  overall  conclusion  on the overall implementation of the standard 
related to this evaluation framework. This also relate to how competence of certi fication- 
and accreditation bodies are ensured. 

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Table 10: Summary of findings for the ISO 38200 standard 

Requirem ent Section 

Conclusion 

Sum m ary 

A. Requirements  for Certificate  Holders 

A.1 Legal  Requirements  at the forest level 

A.1.1 Rights  to harvest timber  w ithin legally 
gazetted boundaries 

Partially 
covered 

A.1.2 Payments  for harvest rights and timber 
including  duties related to timber  harvesting 

Partially 
covered 

Generally,  indicators  are considered partially  covered as there are requirements  in place to identify applicable  legislation  and 
only to source legal  material.  How ever, the identification  of the specific material  is guidance only and are not detailed.   

Seven indicators are partially  covered. Indicators  are covered by guidance  material  but not required to obtain certification.  

Tw o indicators  are partially  covered. Indicators  are covered by guidance material  but not required  to obtain  certification. 

A.1.3 Timber  harvesting, including 
environmental  and forest legislation  including 
forest management  and biodiversity 
conservation, w here directly related to timber 
harvesting 

Partially 
covered 

Six indicators are partially  covered; tw o indicators are not covered. Requirements  to control potential  illegal  activities by  third 
parties w ithin the forest area managed  by the operation  are not included  in ISO38200,  and neither  is examples  of legal 
employment  related  specifically to the forest sector. Examples  of legal  employment  relate to minimum  w orking age, forced 
and compulsory  labour, and discrimination  and freedom of association. 

All other indicators  are covered by guidance  material  but guidance  is general  and not mandatory  to follow  to obtain 
certification. 

A.1.4 Third  parties’  legal rights concerning use 
and tenure that are affected by timber 
harvesting 

Partially 
covered 

Tw o indicators  are not covered, w hile tw o indicators are partially  covered. 

There  are no requirements  or guidance  material  on benefit sharing or FPIC.   

Tw o indicators  are covered by guidance  material,  but guidance  is general  and not mandatory  to follow  to obtain certification. 

A.1.5 Trade  and customs, in so far as the forest 
sector is concerned 

Partially 
covered 

One indicator  is fully covered, tw o indicators is not covered, and three indicators are partially  covered. 

There  are normative  requirements  in place to comply w ith CITES.   

There  are no normative  requirements,  nor guidance  for classification of material,  nor offshore trading,  and transfer pricing.  

All other indicators  are covered by guidance  material  but there are not mandatory  to follow  to obtain  certification. 

A.2 Legal  requirements  for supply chain entities 

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A.2.1. Legal registration 

A.2.2 Taxes and fees 

A.2.3 Trade  and transport 

A.3 Requirements  for material  control 

A.3.1 Material  control 

Partially 
covered 

Partially 
covered 

Partially 
covered 

Partially 
covered 

Indicators  are covered by guidance  material  but not required to obtain  certification. 

Indicators  are covered by guidance  material,  but guidance  is general  and not mandatory  to follow  to obtain  certification 

Three  indicators are not covered. Three  indicators are partially  covered, and one is fully covered.  

There  is no normative  requirement,  nor guidance for classification of material,  offshore trading,  and transfer pricing. 

There  are requirements  in place to assess the prevalence of supplies of material  harvested illegally  according to restrictions 
and limitations  set by CITES. 

All other indicators  are covered by guidance  material,  but guidance  is general  and not mandatory  to follow  to obtain 
certification 

Four indicators  are partially  covered due to:  

 
 

 

Lack of information  on species and origin  for certified material 
The  risk assessment process is generally  in compliance  w ith the EUTR  but it is unclear how  it is implemented  in practice 
and difficult to conclude fully covered at this point.   
Identification  of applicable  legislation  to be defined by the organization.  Ris k  of legislation  w hich is applicable  under the 
EUTR  is not included  in the DDS  scope of the organization. 

A.3.2 Recycled  material 

Covered 

Three  indicators are covered.  

The  definition  of recycled material  in the ISO  38200  follow s the EUTR  definition.  Collecting  evidence of recycled material  is 
required and are to be verified or covered by the requirement  of the due diligence  system. 

A.4 General  requirements  for Certificate 
Holders 

A.4.1 Conflict  resolution 

Not  covered 

There  is no reference to dispute  management,  and how  to address these. 

A.4.2 Corruption 

Not  Covered 

There  is no reference to corruption of the certificate holder,  in the standard. 

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A.5 Quality  and procedural requirements  for 
Certificate  Holders 

Partially 
covered 

Five indicators  are covered; tw o indicators are partially covered. 

A CoC  system, w hich a DDS  shall  be in place, and annual  audits shall be conducted. Risks  shall be reassessed if there is a 
change in risk in the supply chain. Staff shall  have competence  in place.   

The  risk assessment process for DDS  is generally  in compliance  w ith the EUTR  but it is unclear how  it is implemented  in 
practice, as there is a lack of detailed  requirements/guidance  on the evaluation  of risks and risk assessment. See eval A.1 

Certification  schemes to be included  in the DDS  are required only to have competence  to evaluate  risks at forest level and it 
is therefore unclear how  supply chain risks on trade and taxes are to be covered by certification 

A.5.1 Internal  procedures for Certificate 
Holders 

Covered 

A.5.2 Qualification  and competence 

Covered 

A.5.3 Risk  based approaches to sourcing, trade 
or production 

Partially 
covered 

The  risk assessment process is generally  aligned  w ith the EUTR  but it is unclear how  it is implemented  in practice, as there 
is a lack of detailed  requirements/guidance  on the evaluation  of risks and risk assessment 

B.  Requirements  for Certification  Bodies 

There  are no requirements  for certification bodies in ISO  38200:2018   

B.1 General  Certification  Body requirements 

Partially 
covered 

Four indicators  are covered under ISO  17065.  General  CB  requirements  are in place in ISO  17065,  but the standard is not 
mandatory  to be follow ed by CBs as not embedded  in the ISO  38200.   

If it can be confirmed  that an organisation  is certified by a CB operating  after ISO  17065 general  certification body 
requirements  can be considered to be covered.  

B.2 Certification  Body requirements  for auditing 
and certification 

Partially 
covered 

Tw o indicators  are partially  covered; three indicators are not covered. No detailed  procedures in place for audits.  And there is 
no requirement  for stakeholder  consultation  and organizations  sanctioned  for corruption. 

A documented  methodology  shall for evaluation  shall be applied  by CBs,  as w ell as having  a methodology  in place for 
evaluation  of conformity, Review  and certification decision,  issuance of a certificate, and periodic  surveillance. 

It should  be noted  that the three indicators Not  covered by ISO  17065 or 17011  could be covered by other CASCO 
standards. 17065 and 17011 w ere evaluated  only to exemplify  the ISO  CASCO  standards. 

C.  Requirements  for Certification  Schemes 

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C.1  Transparency 

Partially 
covered 

C.2  Scheme  & standard scope 

C.3  Accreditation and oversight 

Partially 
covered  

Partially 
covered 

C.4  Certification  process 

Partially 
covered 

Four indicators  are not covered; tw o indicators are partly covered. 

 There  are no normative  scheme  requirements  for certification and accreditation  bodies. It is possible to find public 
information  about the development  of ISO  38200. 

There  is no overview  of certified organizations,  summaries  of full audit  reports, it is unclear w ho deals w ith complains. 

There  is no overall  system to manage  risk of corruption and conflict of interest in ISO  17076, 17011  or 38200.   

How ever, the w ay the system operates are sufficient to consider this indicator to be covered for certification c onducted by 
CBs accredited in conformance w ith CASCO  conformity assessment standards. 

Tw o indicators  are not covered, one indicator  is partially  covered, one indicator  is covered.  

Applicable  legislation  is not defined by ISO  38200:2018;  accreditation  body or certification body.   

The  standard considers outsourcing in terms of the organisations  CoC  system and clear identification  of the material  being 
handled  under outsourcing. 

Four indicators  are partially  covered; four indicators are not covered. 

As there are no normative  requirements  for certification and accreditation bodies  and there is no overall  oversight 
mechanism.  There is no list of accredited certification bodies. 

If an accreditation  body accredit against ISO  17000 conformance standards information  of the accreditation  body and 
process shall be public,  requirements  on competence,  regularly evaluate  the CBs, and the indicator  w ould be considered to 
be covered.  

Under  ISO  38200  How ever, this is not required and therefore not possible  to conclude that the indicator  is fulfilled w ithout 
evaluating  the applicable  accreditation  bodies system requirements.   

One indicator  is not covered; three indicators are covered.  

There  is a lack of thresholds for establishing  conformance, and lack of scheme  evaluation  approach and decision  making.  

According to ISO  17065  there are mechanism  in place to ensure impartiality  during  the decision  process, and there are 
requirements  in place for auditors not to evaluate  their ow n w ork.  

It is not possible  the evaluate w hether the actual use of low  and high risk enable  comparison  w ith the negligible  and non-
negligible  risk terms  used in the EUTR.   

The  categories of applicable  legislation  are not defined in the document  as normative. 

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14.2 Understanding  ISO 38200 claims 

The ISO 38200 standard does not enable the use of certified product related claims as 
such.  No  product  claims can be made based on ISO 38200:2018 alone. It is stated in 
section 9.3 of the standard that material cannot be “categorised as certified unless ou tput 
is assigned to a particular certification scheme”  Thus, an organisation can be certified 
under ISO 38200:2018, but the products itself are not sold with a product claim or referred 
to as certified by ISO.  

Organisations applying ISO 38200:2018 (certified or not) shall include specific information 
on invoices and/or delivery notes. This includes output declarations made based on ISO 
38200 in the following form:  

“<Output material name (optional)>, <percentage, if applicable>, if applicable<contains 
GMO><methods(s)>, <first><second><third> party assessment, ISO 38200:2018. “  

Example from standard: “Pulp, 50% recycled and 50% verified, percentage method, first 
part assessment, ISO 38200:2018.” 

ISO 38200 allows for claims of other certification schemes to b e used if in conformance 
with  the  requirements  and  if  the specific certification schemes approve the use of the 
claim. 

The standard itself does not specify requirements or limitations in how to communicate 
about the use of the standard. During an interview with representative from the technical 
committee  it  was  clarified  that  a company can communicate about using the standard 
without  being  certified.  In  his  opinion  this  happens  rarely.  A  company  will  have to be 
certified by a third party to be able to claim that they are certified under ISO 38200:2018. 

This aspect of ISO 38200 means that any claims made using the standard needs to be 
carefully  evaluated  to  understand  what  the  output  declaration  covers.  It  may  cover 
material that is only covered by a due diligence process as described in the ISO 38200 
standard, or it may cover different types of certified or verified material from international 
or national certification schemes and systems.  

15.  OLB Bureau Veritas 

The BV OLB (Origine et Légalité des Bois) verification scheme was developed in 2004 by 
Bureau Veritas Certification (BV), an international independent certification body listed on 
the  Euronext  Paris  stock  exchange.  BV  provides  Testing,  Inspection and Certification 
(TIC) services in a range of fields to help clients around the world meet quality, safe ty, 
environmental protection, and social responsibility requirements.   

The general purpose of the OLB certification is to certify that a forest is managed legally, 
the origin of forest products is controlled, and the transfer of certificate claims along t he 
supply chain is ensured. Chain of custody certification aims to ensure that the certification 
claim is transferred along the value chain.  

The system is based on two main standards:  

  a forest management (FM) standard for forest enterprises, and  

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  a chain of custody (CoC) standard for supply chain entities (processors and trade 

activity companies) 

The version of the OLB FM standard currently implemented by forest enterprises dates 
from 2010 (RF03 OLB EF Version 3.3). This version has gone through several r evisions 
that have not been published to date. At the date of writing this report, the most recent 
review (v.3.4) is its final version before publishing, and it is expected to replace version 3.3 
sometime in 2021.  

The version of the OLB COC standard currently implemented by Supply Chain entities 
dates from 2010 (RF03 OLB CdC v3.5). Companies that want to comply with additional 
requirements  related  to  social  and  environmental  aspects,  may  implement the OLB + 
standard (RF03 OLB+ COC v1.0). As with the FM standard, the COC standard has been 
entirely reviewed and updated to be more aligned with recent developments in the forest 
sector, namely regulations such as the EUTR. At the date of writing this report, the most 
recent review (v.3.6) is its final version before publishing, and it is expected to replace 
version 3.5 sometime in 2021. 

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15.1 Summary  of OLB findings 

In total, out of the 84 indicators of the Scheme Assessment Framework evaluated within the study, 55 were concluded as “Covered”, 15 as “Partially 
Covered” and 6 as “Not Covered”. 8 indicators were concluded as “Not Applicable”.  

Table 11: Summary of OLB findings. 

OLB (a) – Cov erage of applicable legislation of 
certified material  

OLB (b) – Cov erage of applicable legislation of 
non-certified  material  (Supplier  Verification 
Programme) 

OLB  –  Cov erage  of other requirements for 
certificate holders 

OLB  –  Cov erage  of  requirements  for 
scheme gov ernance 

 Criteria 

Indicator 

 Criteria 

Indicator 

 Criteria 

Indicator 

 Criteria 

Indicator 

A1.1 Rights to harv est 
timber   

A1.2 Payments for harv est 
rights and timber   
A1.3 Timber harv esting 

A1.4 Third  parties’ legal 
rights 

A1.5 Trade and customs 

A2.1 Legal registration 
A2.2 Taxes and fees 

A1.1.1.1 
A1.1.1.2 
A1.1.1.3 
A1.1.2.1 
A1.1.3.1 
A1.1.3.2 
A1.1.4.1 
A1.2.1.1 
A1.2.2.2 
A1.3.1.1 
A1.3.1.2 
A1.3.2.1 
A1.3.2.2 

A1.3.3.1 
A1.3.4.1 
A1.3.5.1 
A1.3.5.2 
A1.4.1.1 
A1.4.1.2 
A1.4.2.1 
A1.4.3.1 
A1.5.1.1 
A1.5.2.1 
A1.5.3.1 
A1.5.4.1 
A1.5.5.1 
A1.5.6.1 
A2.1.1.1 
A2.2.1.1 
A2.2.2.1 

A1.1 Rights to harv est 
timber   

A1.2 Payments for harv est 
rights and timber   
A1.3 Timber harv esting 

A1.4 Third  parties’ legal 
rights 

A1.5 Trade and customs 

A2.1 Legal registration 
A2.2 Taxes and fees 

A1.1.1.1 
A1.1.1.2 
A1.1.1.3 
A1.1.2.1 
A1.1.3.1 
A1.1.3.2 
A1.1.4.1 
A1.2.1.1 
A1.2.2.2 
A1.3.1.1 
A1.3.1.2 
A1.3.2.1 
A1.3.2.2 

A1.3.3.1 
A1.3.4.1 
A1.3.5.1 
A1.3.5.2 
A1.4.1.1 
A1.4.1.2 
A1.4.2.1 
A1.4.3.1 
A1.5.1.1 
A1.5.2.1 
A1.5.3.1 
A1.5.4.1 
A1.5.5.1 
A1.5.6.1 
A2.1.1.1 
A2.2.1.1 
A2.2.2.1 

121 

A3.1 Material control 

A3.2 Recycled material 

A4.1 Conflict resolution 
A4.2 Corruption 
A5.1 Internal procedures 
for Certificate Holders 
A5.2 Qualification and 
competence 
A5.3 Risk based 
approaches to sourcing, 
trade or production 

A3.1.1.1 
A3.1.1.2 
A3.1.1.3 
A3.1.1.4 
A3.2.1.1 
A3.2.1.2 
A3.2.1.3 
A4.1.1 
A4.1.2 
A5.1.1 
A5.1.2 
A5.2.1 

A5.3.1 
A5.3.2 
A5.3.3 
A5.3.4 

B1 General Certification 
Body  requirements 

B2 Certification Body 
requirements for auditing 
and certification 

C1 Transparency 

C2 Scheme & standard 
scope 

C3 Accreditation and 
ov ersight 

C4 Certification process 

B1.1.1 
B1.1.2 
B1.2.1 
B1.2.2 
B2.1.1 
B2.1.2 
B2.1.3 
B2.2.1 
B2.2.2 
C1.1.1 
C1.1.2 
C1.1.3 

C1.1.4 
C1.2.1 
C1.3.1 
C2.1.1 
C2.2.1 
C2.3.1 
C2.4.1 
C3.1.1 
C3.1.2 
C3.1.3 
C3.1.4 
C3.2.1 
C3.2.2 
C3.2.3 
C3.2.4 
C4.1.1 
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A2.3 Trade and transport 

A2.3 Trade and transport 

A2.3.1.1 
A2.3.2.1 
A2.3.3.1 
A2.3.3.2 
A2.3.4.1 
A2.3.5.1 
A2.3.6.1 

A2.3.1.1 
A2.3.2.1 
A2.3.3.1 
A2.3.3.2 
A2.3.4.1 
A2.3.5.1 
A2.3.6.1 

C4.1.3 
C4.1.4 

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Coverage by the scheme of legal requirements at the forest level  

The Forest Management (FM)  standard is comprehensive and adapted at the country 
level. Most SAF indicators at the FM level are covered. Only “requirements to comply with 
legal obligations concerning benefit sharing” are not fully addressed.  

The Supplier Evaluation Program, used by companies implementing a credit system in 
their  chain  of  custody  management,  is  less  exhaustive  and  detailed  as  the  OLB  FM 
standard, and does not fully address the following areas:  

 

It does not include requirements to control potential illegal activities b y third parties 
within the area managed by the operation  

  Organisations are not required to have procedures in place to ensure absence of 
corrupt  practices  or  potential  mis-use  of  salvaging  permits  or  other  specific 
ministerial permits, with the intention of circumventing harvest regulations  

  Protection of rare or endangered species, including their habitats and potential 

 

 

habitats is not explicitly included  
It  is  not  specified  regulation  related  to  acceptable  levels  of  damage  and 
disturbance of soil resources, establishment of buffer zones  
It is not required to check obligatory insurances, certificates of competence and 
other training requirements, and payment of social and income taxes  

  Legislation  against  discrimination  and  legislation  allowing  for  freed om  of 

association are not mentioned  

  Requirements to comply with legal obligations concerning benefit sharing are not 

included 

  The terminology 'Free, Prior and Informed Consent' in connection with granting 

rights to forest management is not explicitly  

  There  are  not  specific  requirements  to  comply  with  legislation  regulating  how 
harvested  material  is  classified  in  terms  of  species,  quantities  and  qualities  in 
connection with trade and transport  
It is not detailed how to prove compliance with offshore trading and transfer pricing 
and other customs regulations. 

 

This Supplier Verification Program is implemented by certificate holders themselves. Even 
though the OLB standard requires minimum documentation checks and onsite audits by 
qualified  (as  defined  by  the  own  company)  staff,  the  quality  and robustness of these 
assessments may vary. Also it is not possible from the claim on verified material to identify 
which material is from 100% certified areas and which include material from non -verified 
sources. 

Coverage by the scheme of legal requirements at the supply  chain  level  

At  the  chain  of  custody  level,  the  robustness  of  the  OLB  system  may  be  potentially 
discredited  by  the  fact  that  the  COC  system  allows  –  like  other  forestry  certification 
systems –mixing OLB and non OLB inputs. Non OLB inputs may be:  

1)  certified  against  other  approved  or  acceptable  schemes  (i.e., FSC, PEFC and 
PEFC-endorsed schemes, Preferred by Nature LegalSource and BV DDS). In this 
case,  it  is  the  PEFC  and  FSC  Scheme  Assessment  Reports  that  a re  being 
referred.  

2)  not  certified  but  evaluated  as  part  of  a  “Supplier  Evaluation  Program”.  The 
conclusions of the coverage of this program have been included in this evaluation. 
Note: this option is only allowed for companies implementing a credit system.  

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Material control 

The Chain of Custody standard does not use a B2B volume reconciliation system, thus 
indicating a gap in the ability to track volumes through the supply chain.  

Another gap at the chain of custody level is the endorsement of inputs certif ied against 
other certification schemes (FSC and some PEFC endorsed schemes), without performing 
a  full  assessment  of  the  requirements  of  these  certification  systems compared to the 
EUTR. This may represent a risk that BV does not identify potential lack o f alignment.  

Other requirements of the Certification scheme 

The owner and only certification body of the OLB scheme, Bureau Veritas (BV) is a well -
established independent certification body that requires their auditors have a satisfactory 
level of competence, and has procedures in place to cover scheme related indicators such 
as  Conflict  resolution,  Corruption,  Certification  Body  requirements  for  auditing  and 
certification and Scheme & standard scope.  

Since the scheme does not include accreditation of other certification bodies, most of the 
indicators related to Accreditation and oversight are not applicable, but the lack of external 
oversight represents a weakness. BV has worked on internal procedures to fill this gap 
partly. 

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Table 12: Overview of findings for OLB 

Requirem ent Section 

Conclusion 

Sum m ary 

Conclusion 

Sum m ary 

A.  Requirements  for 
Certificate  Holders 

A.1 Legal  Requirements  at the 
forest level   

A.1.1 Rights  to harvest timber 
w ithin legally  gazetted 
boundaries 

A.1.2 Payments  for harvest 
rights and timber  including 
duties related  to timber 
harvesting 

A – Forest management  certification 

B – Input  from non-certified forests 

Partially  covered 

There  is no specific requirement  related  to 
legally  gazetted areas. 

The  standard requires that the organisation 
has the official legal  rights and valid 
authorisations  for the management  and 
harvesting of the forest management  area but 
does not mention  the requirement  of having 
procedures to ensure the use of legal  methods 
to obtain these. 

Partially  Covered  Gaps identified  in the follow ing areas 

- Organisations  are not required to have procedures in place to 
ensure absence of corrupt practices (part of indicator A.1b.1.1.2) 

- Organisations  are not required to have procedures in place to 
ensure the use of legal  methods  to obtain  official authorisations 
(part of indicator A.1b.1.2.1) 

- It is not explicitly  mentioned  that legally  required  planning 
documents  have been approved prior to implementation  of forest 
harvesting activities (part of indicator  A.1b.1.3.2) 

Covered 

All indicators are covered 

Partially  covered 

All indicators of this criterion are covered. There are no mention 
of land area taxes or sales taxes. (A.1b.2.1.1 and A.1b.2.2.2) 

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Requirem ent Section 

Conclusion 

Sum m ary 

Conclusion 

Sum m ary 

Covered 

All indicators of this criterion are covered  

Partially  Covered 

A.1.3 Timber  harvesting, 
including  environmental  and 
forest legislation  including  forest 
management  and biodiversity 
conservation, w here directly 
related  to timber  harvesting 

The  scheme does not include  requirements  to control potential 
illegal  activities by third parties w ithin the area managed  by the 
operation  (A.1b.3.1.2) 

In  addition,  there are gaps in the follow ing areas: 

- There are no specific requirements  to assess the potential  mis-
use of salvaging permits  or other specific ministerial  permits,  w ith 
the intention  of circumventing  harvest regulations  (part of 
indicator  A.1b.3.1.1) 

- Protection  of rare or endangered  species, including  their 
habitats  and potential  habitats  is not included  (part of indicator 
A.1b.3.2.1) 

-Identification  of protected areas is conducted according to  the 
legal  requirements  is not required for non-mandatory  forestry 
operation  planning  document  (part of indicator  A.1b.3.2.2) 

- It is not specified regulation  related  to acceptable  levels of 
damage  and disturbance of soil resources, establishment  of 
buffer zones (part of indicator A.1b.3.3.1) 

- It is not required  to check obligatory  insurances, certificates of 
competence  and other training  requirements,  and payment  of 
social and income  taxes (part of indicator  A.1b.3.5.1) 

- Legislation  against discrimination  and legislation  allow ing for 
freedom of association are not mentioned  (part of indicator 
A.1b.3.5.2) 

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Requirem ent Section 

Conclusion 

Sum m ary 

Conclusion 

Sum m ary 

A.1.4 Third  parties’  legal rights 
concerning use and tenure that 
are affected by timber 
harvesting 

Partially  Covered 

Requirements  to comply w ith legal  obligations 
concerning benefit sharing are not clearly 
defined (A.1a.4.1.2) 

A.1.5 Trade  and customs, in so 
far as the forest sector is 
concerned 

Partially  Covered 

There  are no requirements  ensuring  that 
certificate holders implement  a due diligence 
system, w here applicable.  (A.1.a.5.6.1). 

Partially  Covered 

There  are gaps in the follow ing areas:  

- Requirements  to comply w ith legal  obligations  concerning 
benefit sharing are not included  (part of indicator  A.1b.4.1.2) 

- The terminology  'Free, Prior  and Informed  Consent'  in 
connection  w ith granting rights to forest management  is not 
explicitly  mentioned  (part of indicator  A.1b.4.2.1) 

- It is not required  to prove respect the tenure rights of 
indigenous  and tribal  peoples to forest land  as w ell as their right 
to FPIC  (part of indicator  A.1b.4.3.1) 

Partially  Covered 

There  are gaps in the follow ing areas:  

- There are not specific requirements  to comply  w ith legislation 
regulating  how  harvested material  is classified in terms  of 
species, quantities  and qualities  in connection w ith trade and 
transport (part of indicator  A.1b.5.1.1) 

- It is not detailed  how  to prove compliance  w ith offshore trading 
and transfer pricing (part of indicator  A.1b.5.3.1) 

- It is not detailed  how  to prove compliance  w ith customs 
regulations  (part of indicator  A.1b.5.4.1) 

- There are no requirements  ensuring that certificate holders 
implement  a due diligence  system, w here applicable 
(A.1.b.5.6.1) 

A.2 Legal  requirements  for 
supply chain entities   

A.2.1. Legal registration 

Covered 

All indicators of this criterion are covered 

Covered 

All indicators of this criterion are covered 

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Requirem ent Section 

Conclusion 

Sum m ary 

Conclusion 

Sum m ary 

A.2.2 Taxes and fees 

Covered 

All indicators of this criterion are covered 

Covered 

All indicators of this criterion are covered 

A.2.3 Trade  and transport 

Partially  Covered 

It is not detailed  the requirement  of having 
import/export  licenses, or product classification 
related  to customs (A.2a.3.4.1). 

CITES  specific requirements  for OLB  inputs 
are not included  in the chain of custody 
standard (A.2a.3.5.1). 

Requirements  for COC  companies  to comply 
w ith declaration  obligations  in the context of a 
Due  Diligence/Due  Care legislation  are not 
included  (A.2a.3.6.1). 

Partially  Covered  Offshore trading  and transfer pricing is not included  in the 

Supplier  Evaluation  Program. 

In  addition,  there are gaps in the follow ing areas: 

- There are not specific requirements  to comply  w ith legislation 
regulating  how  harvested material  is classified in terms  of 
species, quantities  and qualities  in connection w ith trade and 
transport (part of indicator  A.2b.3.1.1) 

- It is not detailed  how  to prove compliance  w ith offshore trading 
and transfer pricing (indicator  A.2b.3.3.1) 

- It is not detailed  how  to prove compliance  w ith customs 
regulations  (part of indicator  A.2.3.4.1)  

Requirem ent Section 

Conclusion 

Sum m ary 

A.3 Requirements  for material 
control 

A.3.1 Material  control 

Partially  covered 

Even  though OLB  does include  a CoC  system, it does not include  any B2B  volume  control or reconciliation,  w hich is considered  a gap 
in terms of securing volume  control along the supply chain (A.3.1.1.4) 

A.3.2 Recycled  material 

Not  covered 

OLB  does not include  any mention  of recycled or reclaimed  material 

A.4 General  requirements  for 
Certificate  Holders 

A.4.1 Conflict  resolution 

Partially  covered 

There  is no requirement  to excluded areas w here tenure is disputed (point ii). 

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Requirem ent Section 

Conclusion 

Sum m ary 

A.4.2 Corruption 

Covered 

All indicators of this criterion are covered 

A.5 Quality  and procedural 
requirements  for Certificate 
Holders 

A.5.1 Internal  procedures for 
Certificate  Holders 

Partially  covered 

The  Scheme  does not include  requirements  for the Certificate  Holders to regularly review  the proper functioning  of their ow n 
procedures (A.5.1.2) 

A.5.2 Qualification  and 
competence 

Covered 

Partially  Covered 

There  are not clear indicators and/or guidance  to recognised material  certified under other certification schemes.  (A.5.3.3).  

Covered 

All applicable  indicators  of this criterion are covered 

Partially  covered 

It is required that the organisation  is not involved  in controversial activities  or prac tices that may impair  its legal  integrity.  But it does not 
directly require auditors to evaluate if companies  have been sanctioned  or otherw ise involved  in corrupt practices (B.2.2.1)  

A.5.3 Risk  based  approaches to 
sourcing, trade or production 

B. 

Requirements  for 
Certification  Bodies 

B.1 General  Certification  Body 
requirements 

B.2 Certification  Body 
requirements  for auditing  and 
certification 

C. 
Certification  Schemes 

Requirements  for 

C.1  Transparency 

Partially  covered 

There  are gaps in the follow ing areas:  

- The procedure explaining  various w ays in w hich stakeholders  can engage  is not freely available  (C.1.1.2)  

- A public version of the FM  report is available,  but only upon request (not directly available  on the internet).  COC  reports are not 
publicly  available  (C.1.1.4). 

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Requirem ent Section 

Conclusion 

Sum m ary 

C.2  Scheme  & standard scope 

Covered 

All applicable  indicators  of this criterion are covered 

C.3  Accreditation and oversight

Partially  covered 

C.4  Certification  process 

Partially  covered 

Requirements for non-conformities are structured in a way that there is a potential risk that a non-conformity may 
represent an infringement of legislation and that, as a result, illegal wood may enter the EU market without mitigation 
measures to prevent this from occurring for a period of up to 3 or 12 months (C.3.2.2). 

OLB does not apply independent accreditation and oversight (C.3.2.3). 

Requirements  for non-conformities  are structured in a w ay that there is a potential  risk that a non-conformity  may  represent an 
infringement  of legislation  and that, as a result, illegal  w ood may enter the EU  market  w ithout mitigation  measures to prevent this from 
occurring for a period of up to 3 or 12 months  (C.4.1.2). 

Non  OLB sources used in the credit system go through a Supplier  Verification Program  less comprehensive  than the OLB FM  standard 
and is implemented  by the certificate holders themselves  (C.4.1.3) 

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15.2 Understanding  OLB claims and labels  

The FM and COC standards include requirements to ensure that wood products sold as OLB 
certified are correctly identified as such, and invoices and transport documentation shall be 
clearly linked to the products and include, among other information, “The n umber and validity 
period of the OLB certificate” (as stated in section 5 of RF03 OLB EF Version 3.4 and 1.4 of 
RF03 OLB CoC v3.6_FR).  

At the chain of custody level, there are no different OLB claims to differentiate OLB outputs 
from a physical separation system or a credit system. 

Companies also have the possibility of using the OLB logo, in which case they must follow 
the rules stated in the documents "OLB Trademark Use Regulations" and "GRAPHIC charter 
of the OLB Logo".  

For the use of the OLB trademarks, the conditions and rules are explained in the procedures 
document “GP01 CdC OLB” (sections 17, 18 and 19). 

OLB and BV trademark uses must be approved by Bureau Veritas Douala for prior approval. 
The  accompanying  invoices  to  products  carrying  the  OLB  or  BV  logo  must  include  the 
species, quantity, OLB product type (product description) and certificate reference (e.g. OLB-
CERT/FC-00000000). 

On  product  OLB  trademark  use  must  include  the  certificate  reference  and the following 
statement (unless the timber product is marked directly through a stencil or by paperwork): 
“Origin and Legality of these timber products are certified by an independent organization, 
according to OLB standards”.  

Off  product  OLB  trademark  use  (i.e.  promotional  or  commercial  documents)  must  also 
include  the  certificate  reference,  in  addition  to  the  following  statement:  “This  forestry 
organization received certification from an independent certification organization, according 
to  OLB  standards,  which  guarantee  the  traceability  and  legality  of  timber  until their first 
processing (and so on)”. 

Preferred by Nature 
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Figure 5: The OLB certified trademark 

Other specific claims can be authorized by Bureau Veritas Douala for specific trademark use. 

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PART IV: Evaluation of schemes related to other 

commodities 

Apart  from  assessing  forest  certification  schemes,  this  study  also  includes  test  of  the 
applicability  of  the  developed  framework  for  non-timber  commodities  with  deforestation 
impact.27 

As  part  of  this  test  the  Scheme  Assessment  Framework  applied  for  forest  and  timber 
certification schemes was reviewed and adjusted to fit agricultural products. One goal was to 
identify gaps in the framework as regards coverage of legality and/or sustainability issues.  

As examples of such agricultural products certification schemes, the following were chosen: 

1.  Palm oil –Roundtable on Sustainable Palm Oil (RSPO), is a third-party certification 
system developed by actors from palm oil industry and environmental and social non-
governmental organisations. RSPO has developed social and environmental criteria 
for certification of palm oil. 

2.  Soy – Round Table on Responsible Soy Standard (RTRS) is a third-party certification 
system developed by a non-profit organisation promoting the production, trade, and 
use of responsible soy.  

3.  Cocoa –UTZ28 Policy for Farm and Chain of Custody Certification has been developed 
by UTZ to provide assurance that cocoa sourced as certified has been produced in a 
sustainable  manner.  UTZ  is  the  largest  certification  program  in  the  world  for 
sustainable cocoa and works with more than 807,000 cocoa farmers in 21 producing 
countries.   

To evaluate the applicability to other commodities, the Scheme Assessment Framework was 
adapted to include additional indicators seen as relevant to evaluating how well certif ication 
schemes  of  agricultural  products  cover  issues  related  to  deforestation,  environmental 
protection,  as  well  as  issues  related  to responsible business practices and protection of 
human rights. 

16.  Methodology 

To test if the Scheme Assessment Framework can be applied broader than only for forest 
and timber certification schemes, it was evaluated how framework would apply to schemes 

27  Communication  on  Stepping  up  EU  Action 
lex.europa.eu/resource.html?uri=cellar:a1d5a7da-ad30-11e9-9d01-01aa75ed71a1.0001.02/DOC_1&format=PDF, page 4   

to  Protect  and  Restore 

the  World’s  Forests  https://eur-

28 Note that UTZ and Rainforest Alliance merged in 2018 and have developed new standards. The UTZ Coco a  st a n d a rd  wa s 
chosen since it has been used widely. The merge process of RA and UTZ will be finalised in July 2021.  

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for  agricultural  crops. Also, it was tested if the framework contains requirements that are 
sufficient to cover the EU objectives of moving beyond addressing illegal logging (in the EU 
FLEGT Action Plan). 

The evaluation of schemes applicable to agricultural commodities have followed the same 
basic  methodology  as  the  one  used for forest and timber products. This means that the 
scheme documents and standards were evaluated against the same legality and scheme 
governance  requirements. 
the  Scheme  Assessment  Framework  was 
supplemented  by additional requirements focusing on areas related to deforestation and 
degradation of natural forest, as well as requirements related to the on-going protection of 
forests and natural ecosystems. 

In  addition, 

The  version  of  the  Scheme  Assessment  Framework  used  to  assess  forest  and  timber 
products  certification  schemes  (see PART II and IV) focuses on how well these schemes 
cover EU Timber Regulation aspects of minimising the risk of illegal harvesting and trade.  
However, in the review of the Scheme Assessment Framework, it was clear that additional 
requirements were needed to provide evaluation of how well certification schemes address 
issues related to avoiding deforestation and degradation of natural ecosystems , as well as 
requirements for responsible business management and protection of human rights.  

These additions were made to align with the current work of the EU to address the global 
problems of deforestation and forest degradation. 

By this analysis, the following criteria was added to the Scheme Assessment Framework: 

1.  Management and business practices are legal and responsible:  T his criterion 
was  added  to allow evaluation of how well a scheme covers responsible business 
practices, such as avoidance of corruption. Avoidance of corruption is an essential 
aspect of responsible management of resources and an important aspect of ensuring 
that  management  of  land  is  conducted  according  to  legal  and/or  responsible 
practices, such as not converting forest or other ecosystems illegally by paying bribes 
to enforcement agencies. 

2.  People’s wellbeing and human rights are respected: This criterion was added and 
includes  indicators  to  evaluate  how  scheme  requirements  ensure  respect  for 
indigenous  peoples,  local  communities,  and  workers’  rights,  as  well  as  include 
requirements  for  remediation.  These  requirements  are  considered  important  for 
schemes to include both as they are fundamental to ensuring human wellbeing, but 
also  because  they  are  important  aspects  of  protecting  for ests  and  natural 
ecosystems.  For example, relocating indigenous people or local communities may 
create demand for opening new forest areas for subsistence use by these groups.  
3.  Nature and the environment are protected: This criterion directly relates to th e 
requirements of schemes to ensure that production of agricultural commodities does 
not  contribute  to  deforestation  or  conversion  of  natural  ecosystems,  as  well  as 
protecting  the  environment.  In  this  criterion  indicators  are included related to the 
schemes  requirements  for  certificate  holders  to  identify  and  protect  natural 
ecosystems,  including  to  avoid  deforestation  and  conduct  restoration  efforts  to 
mitigate negative impacts. Also included are indicators related to requirements for 
certificate holders to manage waste and chemicals in a safe way and manage water 
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and  soil.  In  adding  criteria  beyond  simply  avoiding  deforestation,  the  additional 
indicators are seen as important in responsible management and protection of natural 
resources,  and  to  minimise  adverse  impacts  to  the  environment  accrued  from 
agricultural production. 

The full list of the requirements added, are found in Appendix 2 of this report. 

As  can  be  seen  from above the scope of the new requirements extend beyond a simple 
indicator for “no deforestation”. This has been done in order to evaluate how other aspects of 
sustainability, such as responsible business practices, and protection of human rights, are 
covered by the schemes in question. The reason for including this as parts of the study is  
that  these  issues  are  seen  as  integral  aspects  of  sustainability  and  may  have  direct or 
indirect  impacts  on  the  ability  of  certified  organisations  to  protects  forests  and  natural 
ecosystems in the long term.  

Assessing how agricultural certification schemes cover these issues, and how effective the 
selected  indicators  added  to  the  Scheme  Assessment  Framework  are  in  evaluating  the 
schemes requirements is the key objective of this part of the study. 

17.  Overview of schemes 

In the following an overview of the schemes included in this study is provided. 

The three schemes were selected as they were considered to be relevant for commodities 
that  have  had  and  have  significance  for  ongoing  deforestation  and  degradation  of  the 
environment.  Also the three schemes were selected as they cover three crops that have 
primary geographical expansion in three regions where tropical forest is being converted and 
degraded: Latin America, SE Asia and Africa. 

17.1 Roundtable  on Sustainable  Palm Oil (RSPO) 

RSPO is not-for-profit organisation that unites stakeholders from the 7 sectors of the palm oil 
industry:  oil  palm  producers,  processors  or  traders,  consumer  goods  manufacturers, 
retailers,  banks/investors, and environmental and social non -governmental organisations 
(NGOs), to develop and implement global standards for sustainable palm oil. 

The RSPO has developed a set of environmental and social criteria which companies must 
comply with in order to produce Certified Sustainable Palm Oil (CSPO). The RSPO has more 
than 4,000 members worldwide who represent all links along the palm oil supply chain.  

Governance 

The Roundtable on Sustainable Palm Oil (RSPO) is a global, multi-stakeholder initiative on 
sustainable palm oil. Members of RSPO, and participants in its activities come from many 

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different backgrounds, including plantation companies, processors and trader s, consumer 
goods manufacturers and retailers of palm oil products, financial institutions, environmental 
NGOs and social NGOs, from many countries that produce or use palm oil. The RSPO vision 
is to “transform the markets by making sustainable palm oil the norm". 

The RSPO is managed by a Board of Governors comprised of 16 members, designated by 
the  General  Assembly  for  2  years.  The  Board of Governors is supported by 4 Standing 
Committees.  Each  Standing  Committee  is  comprised  of  members  from  the  Board  of 
Governors (including Alternate Board of Governors) as well as RSPO members. T he Board 
of Governors is also supported by advisors. 

RSPO Certification 

Sustainable palm oil production is comprised of legal, economically viable, environmentally 
appropriate,  and  socially  beneficial  management  and  operations.  At  the  heart  of  RSPO 
certification are the RSPO Principles and Criteria (P&C) for Sustainable Palm Oil Production, 
the  global  guidelines  for  producing  palm  oil  sustainably.  The  Principles and Criteria are 
further adapted for use by each country through National Interpretations.  

Palm oil producers are certified through verification of the production process to the RSPO 
Principles & Criteria for Sustainable Palm Oil Production by accredited Certifying Bodies. Al l 
organisations  in  the  supply  chain  that  use  RSPO  certified  sustainable  oil  products  are 
audited to prevent overselling and mixing palm oil with conventional (or non -sustainable) oil 
palm products. 

Standards  Setting Process 

RSPO Principles and Criteria are revised every five years. The standards setting process is 
done  following  best  practices  as  stipulated  by  ISEAL.  The  process  of  revision  of  the 
standards  will  follow  the  Standard  Operation  Procedures  for  Standards  Setting  which 
undergoes several rigorous steps, especially stakeholder consultations. Similar process is 
also  undertaken  for  all  RSPO generic documents under the RSPO Certification scheme, 
including the development and revision of National Interpretation.  

Certification standards 

All  of  the  RSPO  Principles  and  Criteria  apply  to  the  management  of  oil  palm,  oil  palm 
plantations  and  associated  mills.  Independent  mills  shall  be  certified  against  the 
requirements of the RSPO Supply Chain Certification Standard. Where ava ilable, national 
interpretations of the international indicators and guidance shall be followed.  

The oil palm products may go through many production and logistical stages between oil 
palm  plantations  and  the  end  product.  Any  individual  batch  of  oil palm  products can be 
traded through one of four supply chain models that are approved by RSPO:  

Identity Preserved (IP)   

 
  Segregated (SG)  
  Mass Balance (MB)   

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  Book and Claim (BC) 

For the first three of these, Identity Preserved, Segregated and Mass Balance, sup ply chain 
controls from the plantation through to the end product are required, as defined in the RSPO 
Supply Chain Certification Standard. 

Certification and Accreditation  Bodies 

No public claims relating to compliance with the RSPO Principles and Criteria  can be made 
without  third-party  certification  by  an  independent,  accredited  Certification  Body.  The 
Certification  Body  will  certify  sustainable  palm  oil  production,  as  stated  in  the  RSPO 
Certification Systems. Growers assessed for certification once every 5 years, and if certified, 
will be annually assessed for continued compliance. After 5 years the main assessment will 
be repeated.  

Any CB that wishes to offer a service of certification assessment against RSPO certification 
standards must be specifically accredited by the Accreditation Body (AB) that is operating on 
behalf of the RSPO.  

The  Accreditation  Bodies’  documented  systems  and  procedures  shall  include  annual 
monitoring  and  reviews  of  CBs’  competence  and  implementation  of  all  RSPO -specific 
requirements. The AB shall publish its finalized P&C witness and compliance audit reports of 
accredited CBs on its website.  

17.2 Round  Table on Responsible  Soy Standard (RTRS) 

The RTRS, founded in 2006 in Zürich, Switzerland, is a non-profit organisation promoting the 
growth of production, trade, and use of responsible soy. It works through cooperation with 
those in, and related to, the soy value chain, from production to consumption.  

As  a  multi-stakeholder  platform for responsible soy, RTRS implemented a programme of 
activities  during  2019  that  enabled  the  organisation  to  become  an  ISEAL  Member  in 
December 2020. RTRS is the first certification system in the soy sector to comply with ISEAL 
eligibility criteria and become Community Member.  

Governance  

RTRS seeks to bring together stakeholders from three constituencies: Producers; Industry, 
Trade and Finance; and Civil Society Organizations. 

The General Assembly is RTRS’ highest decision-making body. It includes participating and 
observer members, although only participating members have voting rights. 

In  order  to  guarantee  the  flexibility  of  the  RTRS,  the  General  Assembly  delegates  its 
operational activities and most of the decisions to the Executive Board.  

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The Executive Board is the resolution-making body of RTRS with powers as delegated by 
the General Assembly Meeting or the RTRS Statutes. The three constituencies are equally 
represented  in  the  Executive  Board:  Producers;  Industry,  Trade  and  Finance;  and  Civil 
Society.  Each  has  a  maximum  of  five  representatives.  Each  constituency  has  the  same 
voting rights. They are elected by the General Assembly on an annual basis and hold their 
role of representatives for a two-year period. 

The RTRS Secretariat is responsible for executing the decisions made by Executive Board.  

RTRS standard  for responsible soy  production 

The  RTRS  Standard  for  Responsible  Soy  Production Version 1.0 was developed during 
2007-2010, is presented as a series of Principles, Criteria, Indicators and Guidance and is 
designed to be used by soy producers to implement responsible production practices , and by 
certification  bodies  for  field  verification.  No  public  claims  relating  to  compliance  with the 
RTRS  Principles  and  Criteria  can  be  made without independent, third party certification, 
carried  out  by  a  certification  body  that  has been authorized by  RTRS, and according to 
RTRS certification requirements.  

The  RTRS  Standard  for  Responsible  Soy  Production  includes  five  principles  and  106 
indicators: 

  Principle 1: Legal Compliance and Good Business Practices 
  Principle 2: Responsible Labour Conditions 
  Principle 3: Responsible Community Relations 
  Principle 4: Environmental Responsibility 
  Principle 5: Good Agricultural Practices 

Chain of Custody  Standards 

The RTRS Chain of Custody (CoC) Standard describes the requirements for the different 
traceability  systems  an  organization  can  implement  to  keep  control  of  RTRS-certified 
material inventories, either soybeans or soy by-products. It can be applied across the entire 
supply  chain  and  it  is  mandatory  for  organization  wishing  to  receive, process and trade 
RTRS certified soy.  

No public claims relating to compliance with the RTRS Chain of Custody Standards can be 
made without independent, third party certification, carried out by a certification body that has 
been authorized by RTRS, and according to RTRS certification requirements. 

The RTRS Chain of Custody Standard offers several chain-of-custody systems to producers, 
processors and users of responsible soy, soy derivatives and soy products, including mass 
balance and physical segregation. 

RTRS Accreditation  System  and Certification Bodies 

Certification  Bodies  are  responsible  for  auditing  and  certifying RTRS standards through 
qualified  RTRS  Lead  Auditors.  Certification  Bodies  are  in  turn  accredited  by  National 

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Accreditation  Bodies.  There  is currently 8 certification bodies and 3 accreditation bodies 
responsible for accrediting certification bodies. 

Only  accreditation  bodies  which  have  been  formally  endorsed  by  RTRS  may  accredit 
certification  bodies  (CB)  to  carry  out compliance assessments and award certificates for 
RTRS Responsible Soy Production. 

17.3 UTZ  Policy for Farm and Chain  of Custody Certification 

UTZ is a certification program for sustainable farming of coffee, tea, cocoa and hazelnuts. 
UTZ  entered  coca  in  2007.  UTZ  is  the  largest  certification  program  in  th e  world  for 
sustainable  cocoa  and  works  with  more  than  807,000  cocoa  farmers  in  21  producing 
countries. UTZ certified cocoa products are available in 128 countries worldwide, and five of 
the  top  ten  chocolate  manufacturers,  including  Nestlé,  Ferrero, Hersh ey and Mars have 
committed to buy 100% certified cocoa. In 2017, UTZ certified cocoa was sold to make 29 
billion milk chocolate bars. 

In  2018  UTZ  and  Rainforest  Alliance  merged  in  2018  to  develop  a  combined  set  of 
agricultural  certification  standards;  the  process  will  be  finalised  on  1st  July  2021.  In this 
process UTZ/RA has developed new standards, also for cocoa. However, since these are 
not fully implemented yet, it was chosen to focus on the UTZ cocoa here as example.  

The UTZ program includes several approaches to tackle deforestation. For a farmer to be 
certified, he must grow his fruit on land that has been classified as agricultural land or has 
been approved for agricultural use. There are also other requirements that ensure that no 
cultivation is carried out in protected areas such as national parks or within a radius of 2 km 
unless  there  is  a  special management plan. Another way of combating the problem is to 
show the farmers suitable cultivation methods. The UTZ program requires cocoa farmers to 
replant part of their land each year in order to maintain the productivity of aging plantations 
and to discourage farmers from cutting down trees for new areas. 

Governance 

The task of the UTZ Standards Committee task is to adopt, based on information and da ta 
provided by the stakeholders, new Codes of Conduct as well as revise existing codes. T he 
task of the UTZ Product Advisory Committees (PACs) is to support and advise both the UT Z 
Supervisory  Board  and  UTZ  staff  on  the  development,  implementation  and  revi sion  of 
product  specific  programs.  Members  of  the  PACs possess knowledge of the production, 
trade, retail, and/or development of a brand. 

The UTZ Standard 

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All  UTZ  certified  products  are  produced  according  to  the  UTZ  standards.  The  standard 
operates  through  two  sets  of  requirements  –  Core  Code  of  Conduct  (which  covers  the 
growing and harvesting process), and Chain of Custody (which covers products from the 
moment they leave the farm to when they arrive on the shelves).  

These  standards  outline  requirements  for  good  agricultural  practices,  environmental 
protections, as well as worker conditions. The standard encourages continuous improvement 
over a four-year period and requires an annual on-farm audit.  

The requirements in the Code of Conduct version 1.1 29 for group and multi-group certification 
apply  to  all  agricultural  producer  groups  and  their  members  which  produce  and  sell 
commodities as UTZ certified. To get certified, farmers and farmer groups have to comply 
with the rules in the Code. The Core Code for group and multi-group certification is divided 
into four blocks:  

  Block A. Management  
  Block B. Farming Practices  
  Block C. Working Conditions  
  Block D. Environment.  

Each block is introduced by leading principles and includes a set of control points.  

In addition to the Core Code of Conduct, UTZ have modules for individual commodities. T he 
Cocoa  Module30  shall  be  used  by  all  cocoa  producers and producer groups who wish to 
obtain Code of Conduct certification. The Module contains requirements applicable to cocoa 
production up until cocoa beans are dried. 

The code of conducts contains the following key aspects of requirements: 

  Farm management: This ensures, among other things, that farmers are trained in 

UTZ procedures and keep detailed records of their products. 

  Good agricultural practices: This is where good farming practices are outlined, like 

reducing the use of pesticides and ensuring the soil remains fertile. 

  Social requirements: This includes for example creating safe working conditions 

and making sure that no child labour is used in production. 

  Environmental  requirements:  A  wide  variety  of  environmental  practices  are 
enforced such as efficient use of water and energy and protection of natural habitats.  

UTZ Chain of Custody  Standard 

29 https://utz.org/wp-content/uploads/2015/12/EN_UTZ_Core-Code-Group_v1.1_2015.pdf     

30 https://utz.org/wp-content/uploads/2015/12/EN_UTZ_Cocoa-Module_v1.1_2015.pdf  

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The Chain of Custody Standard is a set of requirements designed to provide confidence that 
UTZ certified products are physically or administratively (in the case of mass balance) related 
to UTZ. 

Supply  chain  actors  can  choose  between  the  following  traceability  levels,  listed  f rom 
“strongest” to “weakest”: 

Identity Preserved (IP): physical traceability with producer information  

 
  Segregation (SG): physical traceability  
  Mass Balance (MB): administrative traceability 

UTZ Code of Conduct certified producers/producer groups can only  operate under the IP 
traceability  level.  The  mass  balance  traceability  level  is  only  applicable  to  cocoa  and 
hazelnut, and not to any other UTZ certified product. The first buyer is the first actor in the 
UTZ supply chain who can operate at the MB traceability level. 

Certification 

The certification option determines which Core Code of Conduct shall be complied with, who 
is  responsible  for  compliance,  and  how  the  sample  for  the  certification  audit  shall  be 
determined.  

Certification Bodies 

UTZ works in partnership with nearly 60 UTZ approved certification bodies (CBs) who are 
responsible for conducting independent, third party audits to certify companies and farmers 
against  the  UTZ  standards. 31  Certification  bodies  ensure  that  the  performance  of  their 
auditors is assessed annually including through in-field trainings and/or mock-audits.32    

18.  Findings 

The assessment of the selected schemes shows that they all include requirements that cover 
deforestation and conversion. This means that none of the schemes allow forests or other 
ecosystems to be converted to agricultural production. The schemes do use different cut-off 
dates for any conversion happening historically on land under management.  

All  three  schemes  also  include  requirements  that  cover  most  of  the  other  requirements 
included in the adapted Scheme Assessment Framework, indicating that these stan dards all 

31 List of Approved certification bodies can be found on https://portal.utz.org/ux_CBM_Public/Home.aspx  

32  More  information  on  policy  for  farm  and  chain  of  custody  certification  in  cocoa  can  be  found  here https://utz.org/wp-
content/uploads/2020/04/POLICY-FOR-FARM-AND-CHAIN-OF-CUSTODY-CERTIFICATION-IN-COCOA-.pdf  

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apply a broad and comprehensive range of requirements aimed at ensuring protection of 
environmental values, as well as human rights. 

It was found during the assessment of the schemes that the approach to evaluating scheme 
requirements,  also  applied  for forest and timber certification schemes, can be applied to 
other schemes with success.  

In  the  following  the  findings  from  testing  the  additions  to  the  Scheme  Assessment 
Framework  on  the  three  schemes  are  discussed  (See  Appendix  2  for  a  full  list  of   the 
requirements added to the Scheme Assessment Framework). 

18.1 Responsible  business  practices 

Requirements related to responsible business management was also added to the Scheme 
Assessment Framework. These requirements of the Assessment framework focus evaluating 
how  certification  schemes  ensure  that  CH’s conduct business in a legal and responsible 
manner, including how the potential risks of corruption is addressed. Corruption is, as has 
also  been  discussed  for  the  forest  and  timber  related  schemes,  an   important  aspect of 
ensuring legality and sustainability. 

From the three schemes included, it was found that only RSPO includes direct mention of 
measures  to  prevent  corruption  in  their  guidance  to  Criterion  1.2  in their principles and 
criteria for sustainable palm oil. RTRS also include requirements related to legal business 
practices, but the standards do not go beyond basic legal requirements for registration and 
legal land ownership. The UTZ Core code of Conduct have limited requirements related to 
management of land, but does not directly address issues related to responsible business 
practices as such.  

It is concluded that managing corruption at all levels of supply chains and at all levels of the 
certification process is key to ensuring the credibility and integrity of certification schemes. 

18.2 Respect for human  rights 

As, mentioned above, respect for human rights was included in the additions to the Scheme 
Assessment Framework to evaluate how well schemes cover requirements to protect human 
rights, including indigenous peoples, local communities, and workers’ rights. This aspect of 
sustainability, or responsible land management, is seen relevant as it pertains to the ability of 
the  certified  organisation to ensure that production does not harm huma n rights or push 
indigenous  peoples,  local  communities,  or  workers  to  exploit  natural  ecosystems  for 
subsistence. This may be the case where production of agricultural crops replaces local or 
indigenous  people’s  resources,  used  for  subsistence,  thus  creating  an indirect or direct 
pressure on alternative land areas to be used for their needs. 

All  three  of  the schemes includes in this study contains requirements for workers’ rights, 
regulating health and safety, freedom of association, avoidance of discrimina tion, working 
hours and wages.  

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RSPO  and  RTRS  also  contains  requirements  that  relates  to  protection  of  the  rights  of 
indigenous  peoples,  and  to  ensuring  that  resources  are  not  appropriated  from  local 
communities thereby endangering their livelihoods. The UTZ Core Code of Conduct does not 
include any requirements related to indigenous peoples and only have one indicator related 
to the absence of conflict with local communities. 

In this category, it was found that the schemes differ significantly in the level of detail and the 
scope of the requirements they include.  

It was also found that the adaption of the Scheme Assessment Framework contains relevant 
indicators that should be considered in further work on evaluating certification schemes.  

18.3 Protection of the environment 

An important issue for this Study was to evaluate how the Scheme Assessment F ramework 
can be used to evaluate how well certification schemes cover issues related to deforestation 
and degradation of natural ecosystems. As mentioned above, requirements were added to 
the Scheme Assessment Framework to evaluate to how scheme standards are used to avoid 
deforestation by certificate holders, as well as protection of environmental values.  

The discussion below focuses on the no-deforestation  issue, as well as issues related to 
protection of the environment beyond stopping deforestation. 

18.3.1 No deforestation, no conversion 

All three schemes assessed include clauses to avoid deforestation. However, it is noted that 
there are significant differences in the way “no deforestation” is defined. When assessing the 
no-deforestation  clauses in agricultural commodity certification schemes it is important to 
evaluate  how  each  scheme  defines  deforestation  and  what  types  of  cut -off  dates  are 
allowed, as these are key to understanding the details behind the objectives of the scheme.  

RSPO have implemented a system where conversion of forest is, in principle allowed, but is 
contingent on the certificate holder protecting High Conservation Values and applying  the 
High Carbon Stock Approach (HCSA).  

The RSPO standard includes the following requirements: 

“7.12.1 (C) Land clearing since November 2005 has not damaged primary forest or 
any area required to protect or enhance HCVs. Land clearing since 15 November 
2018 has not damaged HCVs or HCS forests. A historic Land Use Change Analysis 
(LUCA) is conducted prior to any new land clearing, in accordance with the RSPO 
LUCA guidance document. 

7.12.2 (C) HCVs, HCS forests and other conservation areas are identified as  

follows: 

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a)  For  existing  plantations  with  an  HCV  assessment  conducted  by  an  RSPO -
approved assessor and no new land clearing after 15 November 2018, the current 
HCV assessment of those plantations remains valid 

b) Any new land clearing (in existing plantations or new plantings) after 15 November 
2018  is  preceded  by  an  HCV-HCS  assessment,  using  the HCSA Toolkit and the 
HCV-HCSA Assessment Manual. This will include stakeholder consultation and take 
into account wider landscape-level considerations.”33  

As  can  be  seen  the  certificate  holder  can  clear  forest  and  other  natural  ecosystems 
contingent on applying the HCV and HCSA assessments. 

The RTRS standard for responsible soy production applies a cut-off date of June 2016, after 
which no conversion may have taken place for an area to be certifiable. In addition, RTRS 
differentiates between 4 different categories of land, depending on the importance of land for 
biodiversity (hot spots). For category 1, the category with the highest biodiversity value, no 
certification is possible, unless the land-manger can prove that the land was converted prior 
to May 2009:  

“4.4.2  After  3rd  June  2016,  no  conversion  is  allowed  in  any  natural  land  (see 
Glossary),  steep  slopes  and  in  areas  designated  by  law  to  serve the purpose of 
native conservation and/or cultural and social protection.”34   

It should be mentioned that the RTRS have three modalities for certification, of which only 
one  guarantees  the  absence  of  soy  linked to deforestation. These three modalities are: 
segregation, mass balance and country material balance. Only segregation allows for fully 
tracing and segregating the material flow to ensure that 100% of the soya comes from non -
conversion parcels. The other two modalities allow instead for a mixture of certified and non -
certified  soya.  However,  segregation  still  represents  a very low volume of certified soya, 
because of being more expensive than using a mass balance system. Also, RTRS is only 
one of many say certification scheme currently in use – see ZEF Policy Brief for a detailed 
discussion on soy certification schemes. 35   

In  the  UTZ  code  of  conduct  –  code  of  conduct  for  individual  and  multi-site  certification, 
include a clear cut-off date for deforestation of natural forest, being 2008. However, there is 
an additional clause opening the option for conversion of secondary forest: 

“I.D.113  
occurred since 2008.  

No  deforestation  or  degradation  of  primary  forest  occurs  or  has 

33 https://www.rspo.org/resources/archive/1079  

34 https://responsiblesoy.org/documentos/rtrs-standard-for-responsible-soy-production-v31?lang=en  

35 https://www.zef.de/uploads/tx_zefportal/Publications/Policy_brief_28_en.pdf   

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No deforestation or degradation of secondary forest occurs unless: -a 
I.D.114  
legal  land  title  and/or  landowner permission is available,  -government permits are 
available (if required), and  -there is a report produced by an environmental expert 
confirming  that  the  appropriate  clearing  techniques  are  used,  and  that  there  is 
compensation with reforestation activities of at least equal ecological value.”36   

As can be seen from above “no-deforestation” or “no conversion” requirements are concepts 
that are interpreted in different ways by different schemes. 

This point is important to future evaluation of other schemes and in setting requirements or 
expectations for importers of agricultural commodities where “deforestation free” is a corner 
stone of objectives. There is a need for clarifying exactly what “deforestation” means in terms 
of types of forest, as well as cut-off dates for conversion. 

18.3.2 Protection of environment and biodiversity 

To evaluate how well certification schemes address other issues related to environmental 
protection,  several  requirements were added to the Scheme Assessment  Framework. As 
seen above these requirements include soil, water and waste management, identification of 
High Conservation Values, as well as requirements for restoration in cases where Certificate 
Holders have contributed to conversion of degradation of forests and other ecosystems. 

The RSPO standard contains a comprehensive range of requirements for protection and 
management of environmental values in Principle 7 of the RSPO standard. The following 
aspects are included at a criterion level: 

  Effective Integrated Pest Management  
  Pesticide Use  
  Waste management  
  Soil health fertility  
  Soil conservation (erosion and degradation)  
  Soil survey and topographic information  
  Peat  
  Water quality and quantity  
  Energy Use  
  Pollution and GHGs  
  Fire  
  High Conservation Value and High Carbon Stock (HCV and HCS) 

These requirements are comprehensive and cover relevant environmental issues that are 
related to on-going protection and management of natural ecosystems, and biodiversity.  

36 https://utz.org/?attachment_id=3621  

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The  RTRS  standard  also  contains  a  range  of  requirements  related  to  environmental 
protection, including identification of environmental impacts, reduction of pollution, protection 
of water and soils, reduction of GHG emissions and protection of on -farm biodiversity. Again, 
the range of issues include in the standard appears comprehensive.  

As the two other schemes, the UTZ Cocoa Code of Conduct and the Core Code of Conduct, 
also  covers  environmental  protection  in  a  way  that  is  found  to  be  comprehensive  and 
incorporate  fundamental  requirements  for  certificate  holders  relating  to  protection  and 
management of environment and biodiversity. 

In general, the scheme standards contain comprehensive and detailed requirements for a 
wide range of environmental protection issues. However, the fact that different schemes use 
different  interpretations  of  “no  deforestation”  implies  a  lack  of  a  common  ground  for 
establishing what that means on the ground. Also, some schemes have been seen to change 
their  rules  for  deforestation,  e.g.,  by  moving  the  cut-off  date  to  more  recent  dates,  to 
accommodate industry needs. It therefore remains to define clearly what “no deforestation”, 
“no illegal deforestation”, “zero deforestation” or “no net deforestation” requirements should 
contain and how it should be defined, e.g., for use by the EU. 

It  should  also  be  underlined that the practical implementation of the scheme’s normative 
requirements may vary considerably. 

18.3.3 Chain of custody 

Chain of custody along the supply chain and verification of compliance is also important to 
lend  credibility  to  zero-deforestation  commitments.  Schemes  use  different  types  of  CoC 
models, such as those described above.  

The use of different CoC models means that products certified by the same scheme may 
have varying properties. For example, it is different to buy certified material through a book 
and claim model than buying through an identity preserved model. This means that any use 
of  certified  material  to  meet  specific  commitments,  as  for  example  a  no -deforestation 
commitment, must address the issue of chain of custody or traceability in each specific case.  

All three of the schemes included in this study allow several options for chain of custody, 
where the highest level is Identity Preserved, whereas as lesser levels of assurance provide 
less ability to ascertain the origin of the material.  

In  relation  to  the  Scheme  Assessment  Framework,  it  was  found  that  the  requirements 
included  to  evaluate  scheme  performance  for  chain  of  custody  are  also  relevant  for 
agricultural commodities.  

18.3.4 Scheme Governance and auditing 

The  certification  schemes  apply  a  similar  approach  to  certification  compared  to  forest 
certification schemes. They all use a comparable set-up in terms of auditing, accreditation 
and  scheme  governance  as  the  forest  certification  sch emes.  Therefore,  the  Scheme 

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Assessment  framework,  can  provide  the  same  level of analysis for these issues, as was 
done for the forest and timber related schemes. 

The three schemes included in this study all requires independent auditors accredited by an 
independent Accreditation Body, to conduct audits of the Certificate Holders.  

18.3.5 Performance, challenges and opportunities 

As also discussed for the forest and timber related certification schemes and standards, the 
actual  performance  of certification schemes may lag behind the original intentions of the 
written  standards.  For  palm  oil,  soy  and  cocoa  certification  there  have  been  numerous 
reports  on  the  shortcomings  of  the  schemes  and  their  failure  to  live  up  to  their  stated 
objectives in various aspects of sustainability.37 38 39 40 41 

This study has not analysed the legitimacy of the claims made in these and other reports, but 
note  that  there  most  likely  are  challenges  in  these  certification  schemes  related  to 
performance on the ground that should be considered for further assessment of these. 

It would be reasonable to expect that agricultural certification schemes, based on the same 
structures and operated along the same lines as forest and timber certification schemes, 
would be vulnerable to similar weaknesses. 

Further work should therefore needs to gather and carefully consider information related to 
the  performance  of  certification  schemes  in  order  to  allow  for  the  evaluation  of  their 
performance on the ground.  

19.  Scheme  Assessment  Framework  for  agricultural 

commodities 

The schemes tested in this study all included a comprehensive range of environmental and 
social  requirements  that  are  all  relevant  for  protecting  forests  and  natural  resources. 
However, several issues are considered relevant to consider  for further work in assessing the 
integrity of agricultural certification schemes when it comes to evaluating to what degree they 
can  be  used  as  assurance  of  commitments  to  avoid  deforestation,  as  well  as  how  they 
address the additional aspects related to sustainability discussed in the previous sections. 

37 http://changingmarkets.org/wp-content/uploads/2018/06/THE_FALSE_PROMISE_OF_CERTIFICATION_FINAL_WEB.pdf   

38 https://www.pnas.org/content/115/1/121  

39 https://www.amnesty.org/download/Documents/ASA2151842016ENGLISH.PDF  

40 https://www.solidaridadnetwork.org/news/responsible -soy-10-years-on/  

41  https://www.washingtonpost.com/business/2019/10/23/chocolate -companies-say-their-cocoa-is-certified-some-farms-use-
child-labor-thousands-are-protected-forests/  

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Deforestation free, zero-deforestation, zero net deforestation? 

Forests are defined in many ways, based on their characteristics and diversity of flora and 
fauna. The United Nations Environmental Programme recognizes more than 800 definitions 
of forests42 The Food and Agriculture Organization developed common criteria for forests for 
the Global Forest Resources Assessment (FRA), noting that a forest should have a minimum 
area, a minimum potential tree cover and a minimum tree height (see FRA 2010). However, 
each country is free to define the thresholds within these criteria. 

There are also several ways to define deforestation. One considers the loss of tree cover as 
an  indicator  of  deforestation 43  and  another  considers  the  change  in  use  of  the  land. 44 
According  to  the  land-use  definitions, even if the forest is cleared, it is not measured as 
deforestation  until  that  area  is  converted  to  agriculture,  developed,  or  used  in  another 
fashion. 

To add to the confusion, most satellites that watch landscapes from above are not yet able to 
automatically distinguish between a natural forest and tree plantations. What may appear as 
forest clearance might be a harvested plantation.  

Zero Deforestation versus Zero Net Deforestation 

Terms often used to describe the absence of deforestation are “zero deforestation” and “zero 
net deforestation”. Zero deforestation means no forest areas are cleared or converted, while 
zero  net deforestation allows for the clearance or  conversion of forests in one area if an 
equal  area  is  replanted  elsewhere.  Zero  net  deforestation  opens  op  the  challenge  of 
determining what an appropriate replacement for a certain area of forest is – this considers 
e.g., biodiversity, species composition, age composition, carbon stock etc.  

An  essential  point  to  this  discussion  is  then  what  ability  a  scheme  might  have  to  avoid 
deforestation  and  claim  “deforestation  free”  or  “zero  deforestation”  as  a  claim  on  the 
products. For such claim to have integrity, and to outsiders to accept this as valid, a clear 
definition of what “deforestation free” or “zero deforestation” means. As can be seen from the 
three  examples  of  certification  schemes  included  here  different  schemes  apply different 
requirements for what  type of natural vegetation can be converted, when such conversion 
may have taken place and under what circumstances conversion may be allowed.  

There  is  a  risk  that  operations  that  get  certified  are  the  ones  that  already  meet  the 
certification requirements, or at least have to change relatively little to achieve certification, 
whereas those that have to make significant changes do not, and also lack the incentives to 
invest in change – this is particularly true for soy, where certification is still a niche market. 45 

42 https://home.comcast.net/~gyde/national.definitions.of.forest.pdf   

43 https://earthenginepartners.appspot.com/science -2013-global-forest  

44 https://www.fao.org/docrep/006/ad665e/ad665e06.htm  

45 https://forestsnews.cifor.org/58107/blinding-consumers-to-the-true-cost-of-soy?fnl=en  

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Therefore, the use of certification to ensure deforestation free supply chains may miss the 
overarching target of reducing deforestation on a wider scale. 

Can the Scheme Assessment  Framework  be applied to other commodities? 

As mentioned in the above sections, the Scheme Assessment Framework was adapted to 
include additional requirements to evaluate agriculture certification schemes. It was found 
that  the  adapted  Scheme  Assessment  Framework  does  provide  useful  insights  into  the 
coverage of issues relevant to deforestation.  

It  is  also  considered  relevant  to  include  the  additional  areas  of  assessment  related  to 
responsible  business  practices,  protection  of  human  rights,  as  well  as  requirements  for 
protection  of  biodiversity  and  natural  vegetation,  as  these  have  direct  and  indirect 
implications for the scheme’s ability to prevent deforestation and forest degradation.  

One  issue  that  requires  further  consideration  is  the  ability  of  the  Scheme  Assessment 
Framework to better address and cover issues related to the on-the ground performance of 
certification schemes. This is relevant in general to all types of certification schemes and 
should be considered for future work on scheme assessment. 

It is also found that the issues added to the Scheme Assessment Fra mework for evaluation 
of  deforestation  and  other issues of sustainability in other commodities would be equally 
relevant to include in an assessment of forest certification schemes. Especially the issue of 
how  certification  schemes  manage  conversion (for example of natural forest to industrial 
plantation) would have high relevance for the EC in relation to the future work on avoiding 
deforestation. 

It  is  therefore  suggested  that a common framework could be developed that contains all 
relevant legality and sustainability requirements and could be used for further analysis. 

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PART V: Recommendations  

This section contains a series of recommendations based on the findings of this study.  

For Operators and Monitoring Organisations 

To ensure that certified wood-products meet key legal requirements it is recommended to 
carefully  evaluate  the  information  about  the  product  and  the  certification  information 
associated  with  it.  This  means  that  Operators,  when  sourcing  certified  material,  are 
recommended to apply the following process. 

The process of due diligence needed on certified wood -products, should in theory be less 
involved than the effort and resources an Operator would need to apply to uncertified wood -
products. The due diligence process has two key parts: 

First, check that the certification associated with the wood-product is valid, auth entic 
and is included within the scope of the certification. 

The  following  steps  may  be  taken  to  verify  the  validity,  authenticity  and  scope  of  any 
certificate. Details on information available for individual scheme – or how that information 
can  be  accessed  -  can  be  found  in  the  specific  Scheme  Assessment  reports  and  the 
overview report on certification schemes. 

1.  Authenticity - Verify that the certificate and certificate license codes are authentic by 
assessing  the  certificate  and  any  license  codes  communicated  by  the  supplier, 
usually on invoices or other sales or delivery documentation. The codes should match 
each other - and should match the information available via online databases. Also 
check  for    scheme  logos,  labels  and  trademarks  are  correct  and  used  in  the 
appropriate  manner.  Faulty  or  incorrectly  used  logos  or  labels  can  indicate 
manipulation of certificates. 

2.  Validity  -  Operators  should  assess  the  validity  of  the  certificate,  by  checking the 
certification license code against publicly available register of the certification scheme 
(if available). Most certificates have a period for which they are valid, so the end date 
of  validity  can  be  verified.  Also  it  should  be  assessed  if  the  certificate  has been 
suspended  or  terminated  during  any period of time relevant to due diligence. If a 
register of all scheme certificates is not publicly available, such information may be 
obtainable by writing to the Scheme owner.  

3.  Relevance - Check that the certificate was issued to the relevant legal entity from 
which you are buying the wood-products in question. This can be done by verifying  
the names and addresses of the legal entities you are purchasing from, are the same 
as those listed for the certificate holder. 

4.  Scope - Check that the certificate covers the products you are buying. Most schemes 
certifications  are  limited  in  that  the  scope  of  the  certification  does not include all 
products  and  species manufactured or traded by the comp any. Operators should 
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check if the products they are sourcing as certified are, in fact, included within the 
scope of the certificate held by the selling entity.  

5.  Claims  – verify the claim type of the certification. This will include assessing if the 
claim on the product is a 100% certified claim, a controlled wood/sources claim, or a 
claim that comprises some form of mixing (like a credit or mass-balance system). This 
is important for the second part of the due diligence on the material.  

Secondly verify that the certification scheme covers critical leg al r eq uirements an d  
assess the risk of illegality in the country of harvest. 

This step of the process includes a comparing the results of this, or a comparable, study to 
understand any gaps or weaknesses in the legality coverage, against information on the risks 
of timber-legality non-compliance which may exist in the country of harvest of the material or 
wood-product in question.  

6.  Scheme coverage – check that the certification scheme covers all critical legal issues. 
This process includes verifying that the type of certification in question (see the first 
part)  covers  relevant  legality and governance issues. In this process the Scheme 
Assessment Reports of this study can be used to provide an indication of wher e a 
specific scheme has gaps or shortcomings. The following aspects of schemes was 
addressed  in  this  study  and  should  be considered when assessing the scheme’s 
coverage: 
  Scheme  coverage  of  timber  legality  legislation  is  important to ensure that the 
scheme requirements applicable to the certificate holder encompass applicable 
legislation. E.g. the applicable legislation of the EUTR.  

  Chain of custody requirements are implemented to control the risk of mixing in the 

supply chain. 

  Scheme  quality  assurance  systems  ensure  the  certificate  holders  and  CBs 

implement the standard requirements applicable to them effectively.  

7.  Legality  Risks  –  assess  the  risk  of  illegality  in  the  country  of  harvest.  This  step 
includes conducting a risk assessment of legality issues in the country of harvest or 
accessing an existing risk assessment or information from credible third parties. T he 
risks of illegality should be identified in any due diligence process, to a level that will 
enable Operators to make informed decisions on their risk mitigation obligations.  

8.  Comparison of gaps and risks - where gaps have been identified in the certification 
scheme in question. The gaps identified in the certification scheme should be dealt 
similarly as the risks identified in the country of harvest., In this situation, the Operator 
is recommended to identify this and make plans to mitigate these. Conversely, where 
gaps have been identified in the certification scheme in question, but these are not 
associated  with  a  corresponding  non-negligible risk in the country of harvest, the 
Operator may be not required to conduct additional risk mitigation actions. 

9.  Mitigation – Where gaps have been identified in the certification scheme (e.g. legality 
issues  not  addressed  by the scheme) and risks have been  identified in the same 
category  of  legality  in  the  country  of  harvest.,  there  should  be  implemented  risk 

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mitigation actions. Risk mitigation actions should be appropriate to the nature of the 
identified risks. 

10. Documentation – As with other due diligence processes, the actions to assess and 
conducts due diligence on certified materials, should be documented. In this context, 
this would mean the following:  
 
 
 

recording the source used to assess the certification scheme 
recording the source used to assess timber legality risks in the country of harvest 
the  results  of  the  comparison  of  the  certification  scheme  gaps/shortcomings 
against the country risk assessment. 

  The recording of the risk mitigation actions taken, where gaps exist. 

For Competent Authorities 

Competent Authorities should continue to recognise g oo d p r actice in  the fo restr y 
sector 

The EUTR recognises “certification or other third party verified schemes” as good practice in 
the forestry sector.46 The Competent Authorities should recognise that certification schemes 
are an important tool for Operators to assess and mitigate risks in their supply chain. This 
process has the potential for Operators to achieve a high level of confidence in their suppl y 
chain  with  minimal  use  of  resources  and  effort.  This  is  an  optimal  solution  from  a cost -
efficiency perspective.  

Other approaches such as documentation checks conducted by the Operator themselves 
and  carry  additional  risks of not capturing risks and carr y additional operational costs to 
Operators.  The  long  supply  chains  of  importers  in  the EU significantly compromise their 
ability to gain access to the information required for them to conduct effective risk mitigation 
within a reasonable – and commercially viable – timeframe. The financial cost necessary to 
conduct effective due diligence, the availability of in-house technical competencies and the 
lack of fluency in the languages of the country of harvest and supply-chain entities are also 
limiting factors. 

Therefore, for many companies certification is in the best option, in terms of assurance and 
cost efficiency, currently available to reduce risk. However, Competent Authorities must still 
understand the strengths and weaknesses of certification schemes to fully appreciate their 
value for the industry. When conducting checks on Operators relying on certification for risk 
mitigation,  inspectors should have a good impression of where the most notable gaps or 
weaknesses lie within a certification scheme. The inspector should recognise that such gaps 
may not always translate into risks of legal non-compliance of the applicable legislation in the 
country of harvest.  

46 Whereas clause 17, Regulation EC 995/2010 

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In addition to considering the above points, the CA’s should be aware of and understand the 
due diligence process for certified material as recommended above. This means that CA 
staff should understand the details of the certification systems in question, understand the 
gaps of the system in question, and understand the risks relevant to specific co untries of 
origin. CA’s should therefore be skilled in applying the same methodology for due diligence 
on certified material, as the Operator is expected to conduct, and be experienced enough to 
evaluate  the  due  diligence  work  of  operators  in  order  to  verify  the  correctness  and 
completeness of this work. 

For the European Commission 

Clarify definitions on the scope of legality  

In the development phase of the Scheme Assessment Framework for this study, there was 
significant debate among consulted stakeholders about the exact scope of legislation that 
can be included as part of the definition of the applicable legislation, as found in the EUTR. It 
was quickly acknowledged that no consensus on the scope of applicable legislation, could be 
attained during the implementation of this study. 

It  is  recommended that the EC provides a more comprehensive definition or guidance to 
what is covered by the five categories of applicable legislation, as mentioned in the EUTR.  

Clarify definitions in relation to reclaimed and waste material. 

Certification schemes take different approaches to how reclaimed material is defined and 
categorised. In some cases, categories of reclaimed material are assumed to be explicitly 
aligned with the EUTR definition of waste. This means they could be exempt from the scope 
of the EUTR. In other cases, this may be implicit, or standard industry practices may assume 
alignment. 

The EC is recommended to provide improved guidance in relation to the definition of waste 
material – and/or provide more or better examples of the kinds of materials which might be 
included/excluded from the requirements of the EUTR. 

Create a publicly accessible register of European Commission responses to requests 
for clarification or interpretations in relation to the EUTR 

Preferred by Nature has consulted European Commission several times for clarification on 
technical matters or interpretations relating to the EUTR. The EC has responded, but it is not 
clear to what extent these clarifications are known by or disseminated to  other stakeholders.  

It is recommended that the EC create a publicly accessible register of official responses to 
requests for clarification or interpretations in relation to the EUTR. This will help to ensure a 
consistent interpretation of the EUTR by all stakeholders. 

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Support an ongoing process for scheme assessment. 

The following observations are made: 

  The  stakeholder  consultation  identified  other  certification  schemes  of  interest  to 
European operators, albeit with reduced volumes of certified products  being placed 
on the European market. This means that some schemes were not included, that may 
be used by the timber industry, though most likely in relatively small volumes.  

  Even  for the schemes evaluated, these are adapting and evolving on an ongoing 

basis. 

  Few Operators have the resources or technical know-how to evaluate certifications 
schemes. There is a huge efficiency advantage to performing this role ‘centrally’ to 
reduce the technical and financial barriers to Operators conducting reasonable due 
diligence. 

For the service of Operators, Monitoring Organisations and Competent Authorities, the EC 
has  recommended  to  facilitate  the  evaluation  of  more  certification  schemes   relevant to 
European Operators and maintain such evaluations up to date, as schemes  and standards 
change.  This  will  also  help  to  ensure  a  consistent  interpretation  of  the  EUTR  by  all 
stakeholders. 

The EC is recommended to facilitate training on the findings – and lessons – of this study for 
Competent Authorities. 

For forest certification schemes 

Certification  schemes  are  encouraged  to review the findings of an individual certification 
scheme  assessments  and  consider  addressing  any  weaknesses  or  gaps  identified. Key 
issues identified in several schemes are detailed in the following paragraphs. 

Accelerate the use of new technologies to strengthen chain of custody systems  

Accelerate  the  use  of  new  technologies  and  platforms  to  strengthen  chain  of  custody 
systems,  including  those  that  can  identify  incongruities  in  data  at  a  scale  otherwise  not 
possible via analogue methods of data analysis. However, it is also imperative these new 
technologies are supported by systems and procedures which ensure follow-up, investigation 
and actions to address contradictions in data. 

Address gaps surrounding supply-chain legality in the country of harvest 

Address gaps in coverage in relation to standards requirements for supply -chain entities. 
This coverage should address legality in relation to trade and customs in so far as the forest 

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sector  is  concerned.47  It  should  apply  to  both  Certificate Holders in COC-certified supply 
chains and entities included within the scope of due diligence systems.  

Address gaps in relation to scheme transparency 

In the context of the EUTR, certification-scheme transparency is important to Operators and 
other organisations relevant to the proper application of the regulation. Schemes can take 
several measures to strengthen scheme transparency. Measures may include one or more of 
the following: 

  Ensure the public availability online of Scheme requirements, in terms of normative 

requirements for both Certificate Holders and for Certification Bodies  

  Aid  evaluations  by  Operators  and  other  stakeholders  through  publicly  available 

impacts information about their schemes and aspects relevant to the EUTR.  

  Ensure  that  an  up-to-date  register  of certified or verified organisations is publicly 

 

available. This must be updated in ‘real-time’ as far as this is possible.  
Improve  and/or  broaden  the  quality  of  data  available  publicly,  which  would  be o f 
interest  to  Operators  in  conducting  due  diligence.  Ensure  basic  information  on 
certified or verified organisations, includes the following: 
  Scope of certification, including: 

  Specific products or product groupings 
  Relevant species 
  Additional  information  on products comprising of recycled material (type of 

reclaimed material, quantities) 

  Claim  or  claims methods or systems used? (e.g., Credit system, controlled 

 

sources/wood, etc.…) 
Information about forest area(s)/location(s) within scope and specific areas  
excised from the certification for whatever reason.  

  Periods of suspensions or terminations of the certifications to allow operators to 

 

become aware of non- certified companies. 
Information relating to materials sourced via a controlled sources/wood syste m or 
DDS, such as the location of the forests/suppliers, the risk conclusions reached 
by the certificate holder conducting due diligence, and the risk mitigation actions 
implemented. 

  The names and locations of members or facilities included within a group/ multisite 

certificates. 

  Ensure public summary reports are made available on the internet, derived from the 
actual  audits  of  Certificate  holders.  Such  information  provides  a  window  into  the 
actual performance of the certificate holder.  

Address gaps in relation to how the scheme addresses and responds to risks of 
corruption 

47 Only relevant for trade and transport in the country of harvest. 

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Schemes can take several measures to strengthen how it addresses and responds to risks of 
corruption. Measures may include one or more of the following: 

 

 

 

Including direct normative requirements to ensure that licenses, right of land tenure, 
and  management  rights  have  been  issued  according  to  the  legally  prescribed 
procedure and the absence of corrupt practices.  
Include  requirements  to  ensure  that  certificate  holders  do  not  engage  in  corrupt 
practices related to illegal harvesting.  
Include  mechanisms  to  identify  companies  sanctioned  for  engagement  in corrupt 
practices. Ensure there are normative requirements and formal processes in force for 
identifying organisations sanctioned for engagement in corrupt practices proactively 
or otherwise. 

  Ensure  the  implementation of a clear and transparent complaint mechanism at all 

levels of the certification process. 

  Ensure  effective  and  robust  stakeholder  consultation  as  part  of  the  certification 
process. This is done by some schemes, but not all, and should be emphasised as an 
aspect  of  certification  systems,  that  would  be  very  difficult  to  replicate  by  due 
diligence processes of Operators themselves. 

Scheme Assessment Framework agricultural 
commodities 

A  separate  part  of  this  study  evaluated  if  the Scheme Assessment Framework could be 
applied  to  assess  how  certification  schemes  for  agricultural  commodities  perform  with 
regards to preventing deforestation. 

It  was  found  that  the  Scheme  Assessment  Framework  has  to  be  adapted  to  include 
requirements  for  certification  schemes  going  beyond  legality,  such  as  issues  related  to 
responsible business practices, respect for human rights and protection of the environment 
(including  no  deforestation).  It  is  also  underlined  that  some  schemes  do  not  have  any 
requirements on non-certified materials being used in mass-balance CoC systems. 

Further to this, it is recommended that an adaptation of the Scheme Assessment framework 
could be finalised to develop one Scheme Assessment Framework that could work for all 
commodities and include a broad range of sustainability aspects and would also be relevant 
for forest certification schemes. 

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Appendix  1:  EUTR  regulations  and  guidance  on  using 
certification schemes 

REGULATION  (EU)  No  995/2010  OF  THE  EUROPEAN  PARLIAMENT  AND  OF  THE 
COUNCIL   

of 20 October 2010  

laying down the obligations of operators who place timber and timber products on the market  

[…] 

(19) In order to recognise good practice in the forestry sector, certification or other third party 
verified schemes that include verification of compliance with applicable legislation may be 
used in the risk assessment procedure. 

[…] 

Article 6  

Due diligence systems  

1. The due diligence system referred to in Article 4(2) shall contain the following elements:  

[…] 

(b) risk assessment procedures enabling the operator to analyse and evaluate the risk of 
illegally harvested timber or timber products derived from such timber being placed on the 
market.  

Such procedures shall take into account […] relevant risk assessment criteria, including:  

—  assurance  of  compliance with applicable legislation, which may include certification or 
other third-party- verified schemes which cover compliance with applicable legislation, 

[…] 

COMMISSION  IMPLEMENTING  REGULATION  (EU) No 607/2012  

of 6 July 2012  

on the detailed rules concerning the due diligence system and the frequency and nature of 
the checks on monitoring organisations as provided for in Regulation (EU) No 995/2010 of 
the European Parliament and of the Council laying down the obligations of operators who 
place timber and timber products on the market 

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[…] 

Article 4  

Risk assessment and mitigation  

Certification or other third-party verified schemes referred to in the first indent of the second 
paragraph of Article 6(1)(b) and in Article 6(1)(c) of Regulation (EU) No 995/2010 may be 
taken into account in the risk assessment and risk mitigation procedures where they meet 
the following criteria:  

(a) they have established and made available for third-party use a publicly available system 
of  requirements,  which  system  shall  at  the  least  include all relevant requirements of the 
applicable legislation;  

(b) they specify that appropriate checks, including field-visits, are made by a third party at 
regular intervals no longer than 12 months to verify that the applicable legislation is complied 
with;  

(c) they include means, verified by a third party, to trace timber harvested  in accordance with 
applicable  legislation,  and  timber  products  derived  from  such  timber, at any point in the 
supply chain before such timber or timber products are placed on the market;  

(d) they include controls, verified by a third party, to ensure that timber or timber products of 
unknown origin, or timber or timber products which have not been harvested in accordance 
with applicable legislation, do not enter the supply chain. 

[…]  

Article 5  

Record keeping by operators  

1.  Information  concerning  the  operator’s  supply  as  provided  for  in  Article  6(1)(a)  of 
Regulation  (EU)  No  995/2010  and  application  of  risk  mitigation  procedures  shall  be 
documented  through  adequate  records,  which  shall  be  stored  for  five  years  and  made 
available for checks by the competent authority.  

2. In applying their due diligence system operators shall be able to demonstrate how the 
information gathered was checked against the risk criteria provided for in Article 6(1)(b) of 
Regulation (EU) No 995/2010, how a decision on risk mitigation measures was taken and 
how the operator determined the degree of risk. 

[…]  

COMMISSION  NOTICE C(2016)-755 

of 12.2.2016  

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GUIDANCE  DOCUMENT  FOR THE EU TIMBER REGULATION 

6.  THE  ROLE  OF  THIRD-PARTY-VERIFICATION  SCHEMES IN RISK ASSESSMENT AND 
RISK MITIGATION 

[…] 

A. Background information  

Voluntary forest certification and timber legality verification schemes are often used to meet 
specific customer requirements for timber products. Typically, these include a standard that 
describes management practices that must be implemented within a forest management unit, 
comprising: broad principles, criteria and indicators; requirements for checking compliance 
with the standard and awarding certificates; and separate chain -of-custody certification to 
provide assurance along the supply chain that a product only contains timber, or a specified 
percentage of timber, from certified forests.  

When  an  organisation  that  is  not  the  forest  manager,  manufacturer  or  trader,  nor  the 
customer requiring certification, carries out an assessment and awards a certificate, this is 
known as third-party certification. 

Certification schemes generally require third-party organisations to be able to demonstrate 
their  qualifications  to  perform  assessments  through  a  process  of  accreditation that sets 
standards for the skills of auditors and the systems that the certification  organisations must 
adhere to. The International Organisation for Standardisation (ISO) has published standards 
covering both requirements for certification bodies and assessment practices. Proprietary 
timber  legality  verification  schemes,  though  often  provided  by  organisations  that  offer 
accredited certification services, generally do not require accreditation themselves.  

A  requirement  for  compliance  with  legislation  governing  the  management  of  the  forest 
management unit is generally part of forest management certification standards. Systems 
management  standards,  such  as  those  for  environmental  management  or  quality 
management,  generally  do  not  include  such  a  requirement,  or  the  latter  might  not  be 
rigorously checked in assessment.  

B. Guidance  

In  considering  whether  to  make  use  of  a  certification  scheme  or  legality  verification  as 
assurance  that  the  timber  in  a  product  had  been  legally  harvested,  an  operator  must 
determine  whether  the  scheme  incorporates  a  standard  that  includes  all  the  applicable 
legislation. This requires some knowledge of the scheme the operator is using and how it is 
applied in the country where the timber was harvested.  

Certified products generally carry a label with the name of the certification organisation that 
has set the criteria for the certificate and has set the requirements for the auditing process. 
Such  organisations  will  normally  be  able  to  provide  information  on  coverage  of  the 
certification and how it was applied in the country where the timber was harvested, including 
such details as the nature and frequency of field audits.  

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The operator should be satisfied that the third-party organisation that issued a certificate was 
sufficiently qualified and is in good standing with the certification scheme and the relevant 
accreditation body.  

Information about how schemes are regulated can usually be obtained from the certification 
scheme. Some schemes allow certification when a specified percentage of the timber in a 
product has met the full certification standard. This percentage is usually stated on the label. 
In such cases, it is important that the operator obtains information about whether checks on 
the non-certified portion have been performed and whether those checks provide adequate 
evidence of compliance with the applicable legislation.  

Chain-of-custody certification may be used as evidence that no unknown or non -permitted 
timber enters a supply chain. These are generally based on ensuring that only permitted 
timber is allowed to enter the supply chain at ‘critical control points’, and a product can be 
traced to its previous custodian (who must also hold chain -of-custody certification) rather 
than back to the forest where it was harvested. A product with chain -of-custody certification 
may contain a mix of certified and other permitted material from a variety of sources. When 
using chain-of-custody certification as evidence of legality, an operator should ensure that 
permitted  material  complies  with  applicable  legislation  and  that  controls  are  sufficient to 
exclude other material.  

It is important to note that an organisation may hold chain-of-custody certification as long as 
it  has  systems  in  place  to  segregate  certified,  and the allowed percentage of, permitted 
material and non-permitted material, even if it is not producing any certified product at that 
time. When operators rely on certification as assurance and purchase from suppliers with 
chain-of-custody certification, they must check that the chain of custody certification covers 
the specific product they are purchasing.  

In the process of assessing the credibility of a third-party-verification scheme, operators may 
use the following questions (note that the list is not exhaustive):  

  Are all requirements under Article 4 of the Commission implementing Regulation (EU) 

No 607/2012 fulfilled?  

  Is the certification or other third-party-verification scheme compliant with international 

or European standards (e.g. the relevant ISO-guides or ISEAL codes)?  

  Are there substantiated reports about possible shortcomings or problems of th e third-
party-verification schemes in the specific countries from which the timber or timber 
products are imported?  

  Are the third parties that perform the checks and verifications referred to under Article 
4  (b)(c)  and  (d)  of  the  Commission  implementing  Regulation  (EU)  No  607/2012 
independent accredited organisations? 

[…] 

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Appendix  2:  Requirements  added  to  assessment  of 
other commodities  

The following outlines the additions that were made to the Scheme Assessment framework in 
order to include evaluation of deforestation and other aspects of sustainability, that was not 
included  in  the  version  of  the  Scheme  Assessment  framework  used  to  evaluate  forest 
certification schemes with focus on legality and the EUTR. 

19.1.1 Responsible business management 

Though  not  directly  related  to  how  well  a  scheme  addresses  potential  deforestation  by 
certificate  holders, it was considered relevant to include requirements in the Assessment 
Framework focusing on responsible business management in general. These requirements 
of the Assessment Framework focus evaluating how certification schemes ensure that CH’s 
conduct  business  in  a  legal  and  responsible  manner,  including  how the potential risk of 
corruption is addressed. Corruption is, as has also been discussed for the forest and timber 
related schemes, an important aspect of ensuring legality and sustainability.  

To  evaluate  this  the  following  Criteria  and  Indicators  were  added  to  the  Assessment 
Framework: 

Table 13: Business management indicators 

A.1B.1 Management  and business practices are legal  and responsible. 

The  operations of land managers  and the practices of businesses are conducted in compliance 
w ith applicable  legislation,  and in a responsibly manner. 

A.1B.1.1 

Planning  and 
operations  meet 
legal 
requirements. 

A.1B.1.2 

Corruption  is 
effectively 
avoided 

A.1B.1.1.1.  The  scheme shall include  requirements  that ensures compliance 
w ith legal  requirements  related to disclosure of information. 

A.1B.1.1.2.  The  scheme shall include  requirements  that ensures compliance 
w ith legal  requirements  for land clearance or land-use  changes. 

A.1B.1.2.1  The scheme  shall include  requirements  that ensures compliance 
w ith legal  requirements  relating  to bribery, fraud and corruption. 

A.1B.1.2.2  Scheme  shall include  requirements  that ensure that certificate 
holders do not engage  in  payment  of or accepting of bribes or other forms of 
corruption. 

From the three schemes included, it was found that only RSPO includes direct mention of 
measures  to  prevent  corruption.  This is covered in their guidance to Criterion 1.2 of the 
principles and criteria for sustainable palm oil. 

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It  is  concluded  that  ensuring  that  certification  schemes  include  clear  and  auditable 
requirements for certificate holders, as well as for Certification Bodies to avoid and manage 
risks of corruption would be an important part of future work to evaluate certification systems. 

19.1.2 Peoples wellbeing and human rights are respected 

The following criteria and indicators were added to the Scheme Assessment Framework: 

Table 14: People and human rights indicators 

A.1B.2 Peoples  w ellbeing and human  rights are respected. 

The  organisation  shall respect legal  obligations  related  to the rights of indigenous  peoples and local 
communities.   

A.1B.2.1 

The  rights of 
Indigenous  Peoples 
are respected 
according to the UN 
Declaration  on the 
Rights  of Indigenous 
Peoples   and the ILO 
Indigenous  and Tribal 
Peoples  Convention 

A.1B.2.1.1  The scheme  shall include  requirements  that ensures compliance 
w ith legally  recognised Indigenous  People  rights. 

A.1B2.1.2  The scheme  shall require certificate holders  to identify indigenous 
peoples  affected by land-use or other operations   

A.1B.2.1.3  The Scheme  shall require the certificate holder  to define and 
identify Indigenous  Peoples  and their rights in accordance w ith ILO 
Convention  169 and the United  Nations  Declaration  on the Rights  of 
Indigenous  Peoples.  This shall  happen even if the national  regulations  of the 
host state fails to fully recognize these rights, fails to recognize certain 
indigenous  groups as collective rights-holders  or uses terminology  or 
classifications w hich excludes the term indigenous. 

A.1B.2.1.4  Scheme  shall  include requirements  to ensure that certificate 
holder is not engaged  in  any unresolved  claims  by Indigenous  Peoples  of 
collective land  titling  or, if there are claims,  these shall be managed  through 
a transparent process to resolve them. 

A.1B.2.1.5  Scheme  shall  require that certificate holder carry out a human 
rights due diligence  process in accordance w ith principles  17-21 of the UN 
Guiding  Principles  on Business and Human  Rights  , to identify actual or 
potential  adverse impacts  on Indigenous  Peoples,  at the earliest possible 
stage and prior to any activity w hich may  affect indigenous  peoples. 

A.1B.2.2 

Community  rights are 
respected 

A.1B.2.2.1  Scheme  shall  require certificate holder to identify communities 
affected by the operations  of the Organisation. 

A.1B.2.2.2  The scheme  shall include  requirements  that ensures compliance 

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A.1B.2.3 

Remediation 
measures  are 
implemented  as 
appropriate**.   

w ith legally  recognised customary and community  rights. 

A.1B.2.2.3  The scheme  shall require certificate holders to identify and 
respect the rights of local communities,  w here these are not  legally  defined. 

A.1B.2.2.4  The scheme  shall require certificate holders to identify and 
protect sites and resources w ithin the area of operation,  fundamental  for 
satisfying the basic needs of local  communities. 

A.1B.2.2.5  The scheme  shall require certificate holders to identify and 
protect sites, resources, habitats and of cultural,  archaeological,  or historical 
significance, and/or of critical cultural, ecological,  economic  or 
religious/sacred  importance  for the traditional  cultures of local communities. 

A.1B.2.3.1  The scheme  shall require certificate holders to remediate  any 
adverse impacts  to Indigenous  Peoples’,  communities’  or w orkers’ rights, to 
w hich the certificate holder have  contributed.  The organisation  shall provide 
for remediation  through an adequate,  legitimate  and culturally  appropriate 
remedial  mechanism  w hich shall be defined in agreement  w ith the affected 
parties’ legitimate  representatives. 

A.1B.2.3.2  The scheme  shall require certificate holders to establish  an 
effective grievance mechanism  that adheres to the Effectiveness Criteria  of 
the UN  Guiding  Principles  on Business and Human  Rights. 

A.1B.2.3.3  The scheme  shall require certificate holders to develop  a plan for 
remediation  that includes clear geographic  and time  bound targets for 
implementation.  Remediation  plans shall be: 

developed  in consultation  w ith stakeholders; 
developed  and implemented  in collaboration  w ith relevant  experts; and 

 
 
  made  available  to the public 

A.1B.2.3.4  The Scheme  shall ensure that outcomes  of the mutually  agreed 
remediation  process shall  as a minimum: 

 

 

 

Ensure  a prompt  cessation of violating  actions and provide a credible 
guarantee  that they are not repeated.   
If possible,  provide  full restitution  and w here full restitution is not 
possible provide just, fair and prompt  compensation. 
Benefit entire communities  or groups rather than individual  people.     

A.1B.2.3.5  The scheme  shall require certificate holders to divest its interests 
in land to avoid remediation  or until  outstanding  grievances are fully 
resolved, or obligations  have been legally  transferred to another party (e.g., 
the new  ow ner). 

A.1B.2.3.6  The certification scheme  shall include  requirements  to ensure 
that w here the Organisation  has or is acquiring  interests in commodity -
producing  properties, it shall remediate  past harms,  unless this responsibility 
is legally  held  by another party. 

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Nature and the environment are protected 

To evaluate how the Assessment Framework would function to include evaluation of these 
issues, the following criteria and indicators were added: 

Table 15: requirements for deforestation and protection of the environment  

A.1B.3 Nature  and the environment  are protected. 

Measures  shall be implemented  to ensure that forests and other natural  ecosystems are not 
converted to other land uses or degraded  due to the impacts  of operations.  Also, action  shall be 
taken  to protect the environment  through  conservation measures, as w ell as measures to reduce 
the negative impacts  on soil and w ater resources. 

A.1B.3.1 

Natural  ecosystems 
are protected from 
degradation  and 
conversion. 

A.1B.3.1.1   The  scheme shall require certificate holders to include 
requirements  that ensures compliance  w ith legal  requirements  relating  to the 
conversion of natural  forests or other natural  ecosystems. 

A.1B.3.1.2   The  scheme shall require certificate holders to include 
requirements  that ensures compliance  w ith legal  requirements  for the use of 
fire as a land  preparation  and management  tool. 

A.1B.3.1.3  the Scheme  shall include  requirements  to ensure that 
deforestation of natural forests or conversion of other natural  ecosystems is 
not taking  place. 

A.1B.3.2 

High  Conservation 
Values (HCVs) are 
identified  and 
protected. 

A.1B.3.2.1  The scheme  shall require certificate holders to include 
requirements  that ensures compliance  w ith legal  requirements  relating  to 
biodiversity protection,  protected sites, and protection  of 
endangered/protected  species. 

A.1B.3.2.2  The scheme  shall require certificate holders to ensure that 
animals  that are endangered  or protected  are not hunted, killed  or held 
captive. 

A.1B.3.2.3  The scheme  shall require certificate holders to conduct an 
assessment to identify the presence of HCVs.     

A.1B.3.2.4  The scheme  shall require certificate holders to develop  and 
implement  strategies to protect the identified  HCVs. 

A.1B.3.2.5  The scheme  shall require certificate holders to develop  and 
implement  strategies to enhance  the identified  HCVs.   

A.1B.3.2.6  The scheme  shall require certificate holders to conduct 
identification,  protection, and enhancement  activities relevant to HCVs , in 
consultation  w ith relevant and/or affected stakeholders  and experts. 

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A.1B.3.2.7  The scheme  shall require certificate holders to regularly monitor 
any changes in the status of High  Conservation  Values and adapt 
management  to secure continued  protection.  The monitoring  shall be 
proportionate  to the scale, intensity  and risk of activities. 

A.1B.3.4 

Chemicals  are used 
cautiously w ith 
minimal  negative 
impacts 

A.1B.3.4.1  The scheme  shall include  requirements  that ensures compliance 
w ith legal  requirements  relating  to chemical  use and storage. 

A.1B.3.4.2  The scheme  shall include  requirements  that ensures compliance 
w ith legal  requirements  relating  to the use and storage of petroleum-based 
products. 

A.1B.3.4.3  The scheme  shall require certificate holders to meet  the 
requirements  of the WHO  International  Code  of Conduct  on Pesticide 
Management  – Guidelines  on Highly  Hazardous  Chemicals. 

A.1B.3.4.4  The scheme  shall require certificate holders to ensure that 
chemical  drift, run-off or spills are effectively controlled. 

A.1B.3.4.5  The scheme  shall require certificate holders to apply chemicals 
w ith know n risks for pollinators  or other animals  only if:  

Less toxic pesticides are not available.   
Exposure  to natural  ecosystems is minimised;  and   

 
 
  Contact  of pollinators  w ith these substances can be minimised. 

A.1B.3.4.6  The scheme  should require certificate holders to promote 
organic or low  chemical  use production  and actively seek to replace 
chemicals  w ith alternative  components/ingredients 

A.1B.3.5.1   The  scheme shall include  requirements  that ensures compliance 
w ith legal  requirements  relating  to w aste and residue management. 

A.1B.3.6.1  The scheme  shall include  requirements  that ensures compliance 
w ith legal  requirements  for use of w ater (surface or ground  w ater).  

A.1B.3.6.2  The scheme  shall require certificate holders to optimise  use of 
w ater and reduce potential  negative impacts  on production  and the 
surrounding  environment. 

A.1B.3.5 

A.1B.3.6 

Waste is reduced 
and managed 
appropriately**. 

Water resources are 
protected and used 
efficiently**. 

A.1B.3.7 

Soil  is conserved 
and managed 
appropriately. 

A.1B.3.7.1  The scheme  shall include  requirements  that ensures compliance 
w ith legal  requirements  related to soil management. 

A.1B.3.7.2  The scheme  shall require certificate holders to reduce w ater and 
w ind erosion through  practices such as ground covers, mulches,  re-
vegetation  of steep areas, terracing, filter strips, or minimisation  of herbicide 
use to protect soils. 

A.1B.3.7.3  The scheme  should require certificate holders to select and 

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implement  tillage  and cultivation  practices that maintain  or improve  the 
physical, chemical,  and biological  condition  of soil and minimise  soil erosion. 

A.1B.3.7.4  The scheme  should require certificate holders to manage  crop 
nutrients and soil fertility through rotations, cover crops, and the application 
of plant and animal  materials. 

A.1B.3.7.5  The scheme  should require certificate holders to manage  plant 
and animal  materials  to maintain  or improve  soil organic matter  content in a 
manner  that does not contribute  to contamination  of crops, soil, or w ater by 
plant  nutrients, pathogenic  organisms,  heavy metals,  or residues of 
prohibited  substances. 

A.1B.3.7.6  The scheme  should require certificate holders to reduce soil 
compaction  through no-till  or reduced-tillage  farming,  low  pressure tyres, 
and/or restrictions on vehicle size and access times  and locations. 

A.1B.3.8 

Natural  ecosystems 
are restored as 
appropriate**.   

A.1B.3.8.1  The scheme  shall require certificate holders to analyse and 
evaluate  the deforestation  or ecosystem degradation  impacts  in areas 
affected by the operation,  including  the analysis and evaluation  of current 
land uses and land  tenure/ow nership, and identification  of affected 
stakeholders. 

A.1B.3.8.2  The scheme  shall require certificate holders to select a suitable 
site or landscape for restoration  based on the analysis. 

A.1B.3.8.3  The scheme  shall require certificate holders to include 
engagement  of stakeholders,  to include  considerations of long-term  goals of 
forest restoration  and include  the interests of all  stakeholder  groups in the 
restoration analysis. 

A.1B.3.8.4  The scheme  shall require certificate holders to develop  and 
implement  a restoration  management  plan,  including:   

• 

• 
• 
• 
• 
• 
• 

preparing  a topographic  land-use map,  including  a 
designation  of ecosystem functions and assessment of 
accessibility 
existence of natural  regeneration  and needs for planting. 
agreeing  on restoration/rehabilitation  objectives 
selecting  the restoration/rehabilitation  method 
choosing the species to be used 
establishing  a nursery; and   
assessing possible  positive and negative social and 
environmental  impacts. 

A.1B.3.8.5  The scheme  shall require certificate holders to assess capacity-
building  needs and plan and implement  the necessary training. 

A.1B.3.8.6  The scheme  shall require certificate holders to establish  realistic 
time  schedules and plan for financial requirements 

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A.1B.3.8.7  The scheme  shall require certificate holders to monitor 
restored/rehabilitated  areas, and conduct maintenance  activities as required. 

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Appendix 3: Glossary of terms  

Accreditation 

 
  Oversight 

 
Assessment 
  Main  evaluation 
Initial  audit 
 
 
Full  system audit 
  Certification  Audit  

 
 
 

 
 
 

Annual audit   
Surveillance  audit 
Audit 

Active 
Issued  
Valid 

Pre-assessment 
 
Pre-evaluation 
 
Scoping 
 
 
Pre-audit 
  Gap analysis 

  Certification 
Verification 
 
  Registration 

  Certification  body (CB) 
  Conformity 
(CAB) 

assessment 

body 

  Certifier 
 
 
 

Assessor 
Assurance provider 
Third-party  auditor 

  Client 
  Certified  client 
 
Applicant 
Audit Client 
 
  Certificate  holder 
 

Auditee 

Assessment  of  a  certification  body’s provider’s demonstration of competence 
to carry out specific assurance tasks. 

These  terms  often  refer  to  the  first  full  scale  evaluation  performed  for  a 
company  w ho  desires  to  be  certified/  verified.  In  ISO  documents  the  term 
audit  is  used  for  both  first  and  subsequent  audits  w ith  the  most  common 
terms  being  initial  audit  or  certification  audit.  Full  system  audit  is  used 
primarily  for  management  systems  auditing  and  consists  of  Stage  1  audit 
(document  review   and  initial  review ),  w hich  can  be  replaced  by  pre-
assessment  (see  below );  and  Stage  2  audit  w hich  is  an  on-site  audit of full 
management  system implementation. 

These  terms  often  refer  to  repeatedly  conducted  evaluations  to  monitor 
continuous  conformance  of  the  auditee  to  the  requirements.  Preferred  by 
Nature  uses the term ‘annual  audit’  for annual  surveillance audits.   

These terms  define the status of a certification. 

Sometimes  (in  case  of  larger  or  more  complex  auditees), assessors perform 
an  initial  short  and  general  evaluation  to  identify  the  main  shortcomings  that 
can potentially  result in a negative  recommendation  after the main  evaluation. 

The  term  is  used  a  bit  differently  in different situations; how ever, it generally 
refers to the w hole process of granting a certificate/ verification statement by 
an  independent  third-party  assessor.  The  process  starts  formally  w ith  an 
application  and  ends  after  the  certification/  verification  decision  has  been 
made  and  certificate/  verification  statement  has  been  issued.  In  the  broader 
context,  annual  surveillance  activities  are  part  of  the certification/ verification 
process. 

A  certification  body  is  an  independent,  impartial  and  competent  legal  entity 
that  carries  out  certification  auditing.  Although  it  is  not  alw ays a requirement 
that  the  assessor  be  accredited,  professional  certification  bodies are usually 
considered  to  be  those  w ho  have  gained  accreditation  for  the  auditing 
services they offer. 

Although  these  terms  are  sometimes  used  interchangeably,  they  are  not 
necessarily  synonyms.  Applicant  refers  to  a  company  that  has  applied  for 
certification,  but  has not yet received it. An  audit client may request an audit; 
the  auditee  is  the  organisation  being  audited.  In  some  cases,  these  can  be 
different  (e.g.  a  company  ordering  an  audit  for  its  supplier).  With  auditing 

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Supplier  (in product certification) 

 
  Organisation 
  Company 

Standard 
 
 
Audit criteria 
  Requirements 
  Certification  requirements 
  Normative  document 
  Norm 
  Checklist 
  Non-conformance 
  Non-conformity 
  Non-compliance 

services, the general  term  client seems to be the most  w idely used term. 

In  the  COC  certification,  the  certificate is often issued to the organisation that 
has  direct  management  responsibility  for  the  Chain  of  Custody system under 
its control. 

In  FM  certification,  the  certificate  is  often  issued  to  the  organisation that has 
ow nership  or  management  control  over  the  applicable  forest  management 
units.  

These  terms  refer  to  documented  requirements  that  must  be  fulfilled  by  the 
auditee  in  order  to  receive  a  certificate.  Audit  criteria is the definitive, formal 
common  ISO  term  for  any  set  of  requirements  against  w hich  the  auditee  is 
audited.  Standard  is a term used more commonly  in everyday language. 

These  terms  refer  to  non-fulfilment  of  a  requirement.  In  simpler  terms  this 
means  that  some  part  of  the  standard  has  not  been  correctly  fulfilled. 
Nonconformity  is  the  definitive  term  in  ISO  documents.  Similar  options  are 
fulfilment  of  requirements  (conformance,  conformity, 
used 
for  positive 
compliance).  Compliance 
legal 
requirement,  w hereas conformance is referring to voluntary requirements. 

is  most  often  used  as 

reference 

to 

  NCR  (non-conformity  report) 
  CAR  (corrective action request) 

These  tw o terms are commonly used by various auditing systems to describe 
the documentation  of non-conformances.   

 

Suspension 

 

Termination 

  Certification 

  Certification  Scheme 

Suspension  refers  to  the  temporary  ceasing  of  a  certification  validity.  A 
suspension  may  occur  under  specific  situations, such as w here a certificate 
holder  fails  to  meet  certification  requirements  as part of an annual audit or to 
meet  certification requirements  detailed  in a certification agreement. 

Termination  refers  to  the  definitive  end  of  a  certification.  A  termination  may 
occur  prior  to  the  end  of  the  certification  period  (i.e.  prior  to  the  expiration 
date). 

This  is  the  process  w hereby  an  independent  third-party  (called  a certifier or 
certification  body)  assesses  the  quality  of  forest management in relation to a 
set  of  predetermined  requirements  (the  standard).  The  certifier  gives  w ritten 
assurance  that  a  product  or  process  conforms to the requirements specified 
in the standard 

3rd  party  scheme  providing  assurance  of  conformance  to  a  normative 
standard. 

The  organisation  determines  the  objectives  and  scope  of  the  certification 
system and applicable standards, as w ell as the rules for how  the Sy stem w ill 
operate  and  the  standards  against  w hich  conformance  w ill  be  assessed.  In 
most  cases  this  is  the  standard-setting  organisation,  but it may also act as a 
Certification  body.  

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  Competent  authority 

  Complaint 

 

 

Forest  Management  Enterprise 
(FME) 
Forest Management  Unit 

 

Species 

 

Supply  chain 

  Due  Diligence  System  (DDS) 

Organisation,  company  or operation  responsible  for forest management 

A  spatial  area  or  areas  submitted  for  certification  w ith  clearly  defined 
boundaries  managed  to  a  set  of  explicit  long  term  management  objectives 
w hich are expressed in a management  plan 

A  group  of  living  organisms  consisting  of  similar  individuals  capable  of 
exchanging  genes  or  interbreeding.  The  species  is  the  principal  natural 
taxonomic  unit,  ranking  below  a genus. 

The  route  of  forest  products  and  entities  that  take  legal  ow nership  of  the 
forest  products  from  the  forest  –  w here  the  material  is  harvested  –  to  the 
Organisation  that takes final ow nership of the material 

A  set of steps or actions taken to ensure that due  diligence is exercised. The 
due  diligence  system  may  consist  of  w ritten  guidelines  and  procedures  that 
describe the due diligence  process in detail. 

 

Publicly  available 

Obtainable  by any person, w ithout unreasonable  barriers of access  

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Appendix 4: References  

in 

Different 

Standards 

  Aureliu-Florin, et al 2016. An Analysis of Forest Management Non -Conformities to 
Countries. 
FSC 
https://www.researchgate.net/publication/311651193_An_Analysis_of_Forest_Manag
ement_Non-Conformities_to_FSC_Standards_in_Different_European_Countries   
  Brown, D., Schreckenberg, K., Bird, N., Cerutti, P., Del Gatto, F., Diaw, C., Fomété, 
T., Luttrell, C., Navarro, G., Oberndorf, R., Thiel, H., Wells, A., 2008. Legal Timber, 
Verification and Governance in the Forest Sector. Overseas Development Institute. 
Available at: https://www.odi.org/sites/odi.org.uk/files/odi-assets/publications-opinion-
files/3472.pdf   

European 

  Buliga,  B.  and Nichiforel, L.. 2019. Voluntary forest certification vs. stringent legal 
frameworks: Romania as a case study. Journal of Cleaner Production, Volume 207, 
10 
329-342. 
https://www.sciencedirect.com/science/article/abs/pii/S0959652618330294?via%3Dih
ub    

January 

Pages 

2019, 

  China  Forestry Development Report (2013, 2014,2015 and 2017). State Forestry 
at: 

Administration, 
http://124.205.185.8/lysjk/indexJump.do?url=view/moudle/searchData/firstStage&k 
ey=%E4%B8%AD%E5%9B%BD%E6%9E%97%E4%B8%9A%E5%8F%91%E5%B1 
%95%E6%8A%A5%E5%91%8A .    

Available 

  China  Forestry  Statistics  Yearbook  2018  (page  176).  National  Forestry  and 

Grassland Administration.  

  China.com.cn. (2009). Collective Forest Tenure Reform and Forest Crisis. [online]. 
China Web Report. Available at: http://www.china.com.cn/news/zhuanti/hblps/2009 - 
05/08/content_17745715.htm  [Accessed 13 November 2019] 7)    

  Dasgupta, 

2017.Does 

forest 

certification 

really 

work? 

https://news.mongabay.com/2017/09/does-forest-certification-really-
work/#:~:text=Based%20on%20a%20review%20of,environment%20than%20forests
%20managed%20conventionally.   

  EIA Environment (2015). Holzindustrie Schweighofer & Illegal Timber: Holzindustrie 

Schweighofer & Illegal Timber - YouTube  

  European  Commission  (2020).  February  infringements  package:  key  decisions. 
Retrieved via: https://ec.europa.eu/commission/presscorner/detail/en/inf_20_202    
  FERN 2001. “Behind the logo - An environmental and social assessment of forest 
at: 

certification 
https://www.fern.org/fileadmin/uploads/fern/Documents/Behind%20the%20logo.pdf  

schemes”. 

Available 

  FSC, 2015. Due Diligence Evaluation for the Association with FSC . FSC-PRO-10-

004 V2_D2 CLEAN FINAL (1) 

  FSC 2011. FSC evaluation of the impacts and implementation of the Controlled Wood 
https://ic.fsc.org/download.fsc-controlled-wood-evaluation-discussion-

System. 
draft.296.htm  

  FSC,  2020.  FSC  Russia  Acts  to  Combat  Illegal  Salvage  Logging  in  the  Count ry. 
https://fsc.org/en/newsfeed/fsc-russia-acts-to-combat-illegal-salvage-logging-in-the-
country   

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  Liviu  Nichiforel,  Philippe  Deuffic,  Bo  Jellesmark  Thorsen,  Gerhard  Weiss,  Teppo 
Hujala,  Kevin  Keary,  Anna  Lawrence,  Mersudin  Avdibegović,  Zuzana  Dobšinská, 
Diana  Feliciano,  Elena Górriz-Mifsud, Marjanke Hoogstra-Klein, Michal Hrib, Vilém 
Jarský,  Krzysztof  Jodłowski,  Diana  Lukmine,  Špela  Pezdevšek  Malovr h,  Jelena 
Nedeljković,  Dragan  Nonić,  Silvija  Krajter  Ostoić, Klaus Pukall, Jacques Rondeux, 
Theano Samara, Zuzana Sarvašová, Ramona Elena Scriban, Rita Šilingienė, Milan 
Sinko, Makedonka Stojanovska, Vladimir Stojanovski, Todor Stoyanov, Meelis Teder, 
Birger  Vennesland,  Erik  Wilhelmsson,  Jerylee  Wilkes-Allemann,  Ivana  Živojinović, 
Laura  Bouriaud  (2020).  Two  decades  of  forest-related  legislation  changes  in 
European countries analysed from a property rights perspective, Forest Policy and 
Economics, Volume 115, 2020 https://doi.org/10.1016/j.forpol.2020.102146.   

  Perera, P. and Vlosky R.P. 2006. A History of Forest Certification. In Louisiana Forest 
at: 

Products  Development  Center  Working  Paper 
http://www.lfpdc.lsu.edu/publications/working_papers/wp71.pdf  

#71.  Available 

  Ping,  L.  and  Yufang  S.  (2014).  Large-Scale  Land  Acquisition  for  APP  Forest 
Plantations:  Field  Findings  and  Recommendations.  Washington,  DC:  Rights  and 
at: 
pp. 
Resources 
https://rightsandresources.org/wpcontent/uploads/RRIReport_APP_web1.pdf   
[Accessed 13 November 2019]  

Available 

Initiative, 

3-37. 

  Preferred  by  Nature, 2019. FSC™ no Silver Bullet against Illegal Timber Trade in 
Ukraine. https://preferredbynature.org/newsroom/fsctm-no-silver-bullet-against-illegal-
timber-trade-ukraine   

  Trishkin,  M.,  Karjalainen,  T.  and  Kangas,  J.  2019.  An  Analysis  of  the  Non -
in  Northwestern  Russia. 

conformities  of  Certified  Companies  Operating 
https://www.mdpi.com/1999-4907/10/12/1061/pdf  

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Annex 1: Forest-related certification schemes 
An overview 

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Table of Contents 

1. 

Introduction.................................................................................................... 176 

1.1. Table of contents ........................................................................................ 176 

2.  Executive Summary ...................................................................................... 178 

3.  Background ................................................................................................... 187 

4.  Key features of certification .......................................................................... 190 

4.1. Product or process certification................................................................. 190 
4.2. Voluntary (private) or mandated (government) certification ................... 191 
4.3. Certification as an objective evaluation.................................................... 192 
4.4. Financing of certification schemes ........................................................... 193 

5.  Actors involved in certification schemes...................................................... 195 

5.1. Scheme owners or managers  ................................................................... 195 
5.2. Accreditation bodies .................................................................................. 196 
5.3. Certification bodies .................................................................................... 197 
5.4. Certificate holders ..................................................................................... 197 
5.5. Other stakeholders  .................................................................................... 198 

6.  Requirements for certificate holders  ............................................................ 200 

6.1. Standards ................................................................................................... 200 
6.1.1. Principles, criteria, indicators .................................................................. 201 
6.2. Procedures, policies and other normative documents ............................ 203 

7.  Defining the scope of a certificate................................................................ 204 

7.1. Certificate requirements............................................................................. 204 
7.1.1. Sustainable forest management (FM) ..................................................... 204 
7.1.2. Legal forest management or harvesting .................................................. 205 
7.1.3. Due diligence schemes .......................................................................... 206 
7.1.4. Traceability or Chain of Custody (CoC) of timber products ...................... 207 
7.2. Organisational or area based scope ........................................................ 209 
7.3. Products or supply-chain scope ............................................................... 209 

8.  The certification process .............................................................................. 211 

8.1. Auditing conformance ................................................................................ 211 
8.1.1. Conducting audits .................................................................................. 212 
8.1.2. Audit reports .......................................................................................... 212 
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8.1.3. Non-conformities.................................................................................... 213 
8.1.4. Certification decision .............................................................................. 213 
8.1.5. Certificate validity................................................................................... 214 
8.2. Claims and communication of certified status  ......................................... 214 
8.2.1. Trademark use ...................................................................................... 215 

9.  Management of Certification Bodies ............................................................ 216 

9.1. Accreditation and Oversight ...................................................................... 216 
9.2. Impartiality and conflicts of interests (COI)  .............................................. 216 

10. 

Scheme management............................................................................... 218 

10.1. Transparency ............................................................................................ 218 
10.2. Appeals and complaints .......................................................................... 218 
10.3. Standard setting ....................................................................................... 219 

11.  Certification schemes and the EUTR ....................................................... 220 

11.1. EUTR requirements .................................................................................. 220 
11.2. Assessing certification schemes.............................................................. 221 
11.2.1. Comparing forest-related schemes against the EUTR ........................... 221 
11.3. Understanding certificates  ....................................................................... 225 

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Introduction 
This  report  results  from  the  European  Commission  project  “Study  on  Certification  and 
Verification Schemes in the Forest Sector and for Wood-based Products”, implemented by 
Preferred by Nature in 2020.  

The overall objective of the project is to create a point of reference for all interested and 
concerned  parties  in  forest  and  wood-based  product  certification,  to  (1)  improve  the 
understanding of certification programs in the context of the implementation of the EU Timber 
Regulation (EUTR); (2) creating a resource of knowledge on certification schemes; and (3) 
helping  Competent  Authorities,  Monitoring  Organisations,  Operators  and  Traders  (as 
identified under the EUTR) in their understanding of the potential benefits and shortcomings 
of forest certification schemes.  

This report presents a general overview of private sector certification schemes to enable 
relevant  operators,  competent authorities, forest managers and owners to enhance their 
understanding of this topic. Furthermore, the study will allow these actors to understand the 
significance of a scheme-issued certificate or a certification claim on a product and how used 
appropriately in the context of the EUTR.  

Sustainable forest management certification and ‘timber-legality verification’ schemes will be 
assessed  against  the  same  framework in this report. The schemes can be differentiated 
based on their institutional setup (see section 12.2 of this report). Still, they are all voluntary, 
non-governmental and market-based, with auditing performed by an independent party.  

Certification and verification schemes are described under in the EUTR under Article 6(1)(b) 
and Article 6(1)(c) of Regulation (EU) No 995/2010”. 48 49 While some distinction can be made 
between  certification  and  verification  systems  despite  sharing  important  elements,  the 
authors  of  this  report  have  made  the  decision  to  refer  to  both  terms  commonly  as 
“certification”. 

However,  it  is  important  to understand the difference between voluntary ce rtification and 
government-backed mandatory legality verification systems developed within the context of 
national  policies  or  bilateral  agreements  such  as  the  EU  FLEGT  Voluntary  Partnership 
Agreements (VPAs). These state-mandated legality verification systems are omitted in this 
report. 

1.1 Table of contents 

Section  1  to  3  comprises  an  Introduction,  Executive  Summary  and  a  brief  historical 
background on the development of forest-related private-sector certification schemes. 

48 Regulation 995/2010. https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:295:0023:0034:EN:PDF  

49 Implementing Regulation 607/2102, Article 4. https://eur-lex.europa.eu/eli/reg_impl/2012/607/oj  

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Section  4  details  key  features  and  major  distinctions  found  in  certification  schemes.  A 
distinction is made between how various standards and schemes establish conformance by 
taking a system-based or performance-oriented approach.  

Section 5 describes the principal actors engaged in certification schemes, including their 
roles within the scheme set up.  

Section 6 discusses the main requirements of a certificate holder and how requirements are 
structured to compose a standard.  

Section 7 draws up the discrete elements that form the scope of a certification scheme. Most 
certification schemes apply a similar approach when assessing conformance among their 
certificate holders.  

Section 8 reviews key aspects of the auditing process and explains commonly used terms.  

Section 9 examines accreditation, oversight and safeguarding of the auditing process and 
issues such as impartiality.  

Section 10 discusses other aspects of the certification schemes, such as institutional and 
procedural arrangements, including transparency, complaints, and standard sett ing issues. 

Section 11 covers certification schemes and its role under the EUTR as a component in due 
diligence systems. It also investigates which considerations should be made when evaluating 
scheme performance against the requirements of the EUTR. 

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2. Executive Summary 

Forest-related  certification  schemes  may  help  operators  comply  with  the  EU  Timber 
Regulation (EUTR). It is explicitly stated in the regulation text that certification schemes may 
be taken into account in risk assessment and mitigation proce dures. Still, it is important to 
emphasise  that  the  regulation  does  not  exempt  certified  products  from  the  EUTR 
requirements. While it may be useful for operators to source certified products, they need to 
understand the strengths and limitations of forest-related certification schemes in the context 
of complying with the EUTR requirements. 

Despite many similarities, each forest-related certification scheme comprises its own set of 
requirements,  a  discrete  set  of  certification  and  accreditation  procedures,  differing 
approaches to quality assurance and a varying degree of transparency. T hese differences 
result  in  a  high  level  of  complexity  for  certificate  holders,  who  in  some  cases  may  be 
simultaneously certified under several different certification schemes. This may lead to a lack 
of understanding of the limitations of the individual certification scheme and cause certificate 
holders to fail to understand that compliance with a voluntary forest certification scheme does 
not  necessarily  equal  compliance  with  all  applicable  laws  in  the  country  in  which  they 
operate.  

This report seeks to give its readers a much more comprehensive understanding of forest -
related certification schemes, their design, structure, and applicability with the EUTR.  

Image 1: Overview  of forest-related certification 

Key features of forest-related certification  

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This  paper  focuses  on  legal  and/or  sustainable  forest  management  certification  and 
traceability systems for forest products 50 and class them according to key differences in the 
certification  process.  It  may  be  helpful  to  distinguish  between  four  distinct  types  of 
certification,  depending  on  the  process  and  object  of  certification.  However,  many 
certification schemes share characteristics of more than just one of the following types of 
certification.   

  Product certification is when the object of certification is the product itself. Product 
certification seeks to ensure that a product meets predetermined specifications, such 
as a certain quality level and composition. While most forest certification schemes are 
not  product  certification  systems  per  se  since  the  product  itself  is  not  subject  to 
evaluation.  The  schemes  permit  on-product  certification  claims  for  marketing 
purposes.    

  System  certification  is  when  the  object  of  certification  is  a  system  of  procedures 
designed to deliver a uniform product or outcome. Under a system certification, the 
assessment  focus  on  policies,  processes,  and  systems  in  place  rather  than  the 
product or performance. The ISO 9000 family of quality management systems is an 
example of a system certification regime.  

  Process  certification  focuses  on specific steps in a production process to acquire 
desired product properties. Chain of custody (CoC) certification can be described as 
a  process  certification,  as  the  goal is to ensure traceability in the production flow 
through auditing. 

  Performance-based  certification 

than  process. 
Performance-based certification allows for flexibility in achieving a given outcome to 
meet certain thresholds or objectives.  

focuses  on  outcome  rather 

Most forest certification schemes contain elements of both performance -based and system 
certification. Some criteria and indicators may set specific thresholds that need to be met by 
the  certificate  holder,  while  other  criteria  and  indicators  may  require  certain  systems  or 
procedures to be in place. 

50 Certification systems dedicated to product specific attributes, such as wood quality or formaldehyde e m issi o n s f ro m  wo o d  
products, have omitted from this report. 

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Image 2: Overview of Overview and roles of actors in certification schemes 

Actors commonly involved in forest-related certification schemes  

The following types of entities are usually present within a certification scheme:  

  The  Scheme  owner  is  responsible  for  the  development,  administration,  and 
maintenance of a scheme. Their role usually involves developing a set of normative 
requirements  (standards)  and  ensuring  that  the  standards  are  regularly  revised, 
appropriately  interpreted  and  implemented.  Scheme  owners  also  establish  the 
requirements  and  procedures  for  certificate  holders  and  develop  an  assurance 
system to ensure the proper functioning of the scheme.  

  Accreditation  bodies  are  tasked  with  accrediting  other  organisations (certification 
bodies)  to  deliver  qualified  certification  services  under  a  predetermined  set  of 
requirements.  Accreditation  bodies  should  regularly  evaluate  certific ation  bodies' 
performance  to  ensure  their  continuous technical competence and integrity when 
conducting conformity assessment work. An accreditation body may be included in a 
scheme’s institutional setup, in which case the scheme owner will usually choose  the 
accreditation  body.  One  or  more  accreditation  bodies  may  provide  accreditation 
services under a certification scheme. However, not all certification schemes function 
with an independent accreditation body, as some scheme owners directly accredit 
certification bodies.  

  Certification bodies (CBs) are the third-party entities that deliver certification services, 
principally through auditing practices. A certification body usually employs individual 
auditors. Their role is to ensure that certificate holders conform to the applicable set 
of requirements whilst following the relevant procedures set up by the scheme owner 
for  CBs.  Some  private-sector  legality  verification  schemes  are,  however,  also 
delivering certification activities themselves.  

  Certificate holders are the organisations committing to the conformity assessments 
against one or more standards. As auditors regularly assess the certificate holders, 
they are generally referred to as the “auditee”. However, some certification bodies 
distinguish  between  the  ‘certification client’ and the ‘auditee’, i.e. the organisation 
being audited.  

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  Stakeholders  may  play  different  roles  within  the  functioning  of  a  scheme.  The 
development of a standard can rest entirely in the hands of the scheme owner, or it 
may be developed through a collective effort involving different types of stakeholders.  

Common characteristics shared by forest-related certification schemes  

  Schemes are international but not governed by sovereign states  

o  Although  environmental  policies  have  historically  been  promoted  through 
government involvement via regulatory mechanisms, almost all forest-related 
certification schemes are voluntary arrangements backed by a mix of private 
enterprises, business associations, and/or civil society organisations. Though 
public agencies may be involved at some level, they are usually not part of the 
scheme's decision-making bodies.  

  Schemes develop their own standards 

o  As  similar  international  initiatives  without  governmental  support,  forest 
certification  schemes  can  apply  to  multiple  countries  without  any  formal 
association between the sovereign states included in their scope. A notable 
trait of these non-governmental initiatives is their ability to develop standards, 
guidelines, product specifications and requirements in production methods to 
a common standard above what is required by national laws. 

  Schemes are voluntary  

o  Because of the sponsorship by non-governmental institutions, international 
initiatives  are  proprietary  systems  where  certificate  holders  participate 
voluntarily.  This  aspect  is  shared  across  all  present  sustainable  forest 
management certification and timber-legality certification schemes.  

  Access to a scheme requires adherence to the requirements of the scheme  

o  Schemes use standards to ensure a uniform application of requirements, and 
prospective scheme participants will have to undergo an application proces s. 
Depending on the applicants' place in the supply chain, it may set different 
requirements. The evaluation process may be more performance-based at the 
forest level, including implementing legal or sustainable forest management 
practices.  For  operators  in  the  supply  chain,  Chain  of  Custody  (CoC) 
requirements  tend  to  be  more  system-based  in  nature,  usually  providing 
normative requirements related to traceability and claims about the status of 
certified products.  

  Certification bodies shall be independent and impartial 

o  The  governing  bodies  of  certification  schemes  are  aspiring  to  maintain 
independence  and  objectivity  in  certification  decisions.  The  impartiality  of 
auditors, who evaluate conformance against a given standard, are core to this 
mission.  To  ensure  objectivity  in  conformance  evaluations,  certification 
schemes  rely  upon  an  independent  third  party  to  conduct  conformity 
assessments and make certification decisions. In third-party audits, the auditor 

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is without any conflict of interest to the auditee and performs the audit to verify 
conformance with requirements.  

 

It is the certificate holders who pay for certification schemes 

o 

It is a key principle in forest certification schemes that the certificate holders 
fund the costs associated with third-party auditing. A motive for forest owners, 
operators and traders to participate in private certification is the prospect of 
gaining market access or selling certified goods at a premium, compared to 
competing products. The third-party auditing service fee may be charged to 
the  third-party  auditor,  who  in  turn  reimburse  the  certification  body  or  is 
charged directly to the certification body. 

Definition of standard requirements for certificate holders 

The key part of a certification scheme is the requirements to which a certificate holder shall 
conform. The normative requirements listed within standards are usually structured within a 
hierarchy according to the importance of the requirements. A common approach is the use of 
principles,  criteria,  indicators  (see  section  6).  In  addition  to standards, most certification 
schemes provide additional guidance, policies, procedures and interpretative documents to 
support the functioning of the scheme.  

Understanding the scope of a certificate 

Organisations usually need to define the scope of forest or forest products and activities that 
the certification body shall evaluate. An organisation may wish to certify only a subset of its 
forest operations or products.  

A forest management certification may focus on a single site or multiple sites, usually made 
up  of  individual  Forest  Management  Units  (FMU)  owned  or  managed  by  a  forest 
management  enterprise  (FME).  Depending  on  the  scheme,  specific  rules  may  apply  to 
multisite  certification.  Special  conditions  or  separate  no rmative  requirements,  policies 
certification,  or  procedures  may  also  apply  to  the  FMUs  that  are  excluded  from  the 
certification scope not included within the certification.  

For processing or trade organisations, the scope of their CoC certificate may be l imited to 
certain products composed of certified raw material. It is left to the discretion of the certificate 
holder to determine what products to include in the scope of certification.    

It is important to keep in mind that the chain of custody in forest-related certification does not 
necessarily provide an ability to trace wood products back to their specific FMUs or forests of 
origin. CoC standards, however, do contain requirements designed to prevent any mixing or 
substitution of products or materials with uncertified material in the supply chain. Each link in 
the supply chain must implement those requirements for the whole system to function.  

The certification process 

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The  evaluation  of  the  certificate  holder’s  conformance  with  the  relevant  requiremen ts 
(standards)  is  conducted  through  audits.  Audits  often  involve  on -site  visits,  where 
representatives (auditors) of the Certification Body conduct an evaluation of the performance 
of  the  certificate  holder  (or  prospective  certificate  holder),  by  reviewing   documents, 
conducting inspections, inventory assessments, interviews with staff and/or consultation with 
stakeholders. The frequency of audits is detailed within the scheme’s rules and procedures.  

Certification  schemes  usually  set  rules  on how audits should be conducted. Certification 
Bodies  are  typically  required to apply a documented methodology for the assessment of 
organisations. In forest certification, an important distinction between schemes is whether 
stakeholder consultation shall be a part of the audit or not.  

Most schemes require the outcome of the audit findings to be documented as a confidential 
audit  report. A scheme may also require that a part of the report, typically a summary of 
findings, be made publicly available to ensure transparency regarding the performance of 
certificate holders and certification decisions. Transparency about audit findings is important 
and  a  notable  differentiator  between  certification  schemes.  The  publication  of  summary 
reports of certification audits can be valuable in relation to the EUTR, as they may provide 
relevant information regarding the performance of certified organisations and the scope of 
activities under evaluation.    

Non-conformances  can  be  considered  the  failure  to  implement  and maintain systems or  
procedures or not meeting a performance threshold that may jeopardize the well -functioning 
and  effectiveness  of  the  certification  scheme.  Non-conformances  can  be  classified 
depending on their gravity and scale. Different categories of non -conformance may have 
different deadlines for corrective measures to be implemented or may have a different impact 
on a certification decision.  

Based on the conclusion of an audit, a recommendation will be made on whether to issue or 
maintain the validity of a certificate. The certificate will usually have a fixed period of validity, 
with  five  years  being  the  norm,  after  which  the  certificate  would  need  to  be  renewed. 
Renewal  of  a  certificate  will  usually  entail  a  full  assessment  of  the  certificate  holders 
compliance with the applicable standards. 

Image 3: Overview of the traceability system / transfer of claims through the supply chain  

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Certification claims and communication 

Forest certification schemes usually permit certificate holders to market certified products 
towards consumers in the form of labels on the product itself (also known as ‘on -product 
claims’) and/or communication to consumers about the certified status of t he product or the 
certificate  holder  (also  known  as  ‘off-product  claims’).  Certification  labels  have  raised 
complexity as many certification schemes use different on-product labels, depending on the 
type  of  input  material  used  (reclaimed  material  for  examp le)  and/or  the  method  of 
segregating/mixing certified and uncertified material (mass balance/threshold systems) within 
the supply chain. A basic understanding of the meaning of the different certification labels is 
necessary to understand their applicability under the EUTR.  

Some certification schemes restrict the use of certain types of product claims to business -to-
business  communication  only,  thus  not  permitting  those  certification  claims  towards 
consumers.  An  example  of  this is  FSC Controlled Wood (non-certified material of known 
origin, with a low risk of stemming from unacceptable harvesting practices), which may only 
be marketed in business-to-business communication. In contrast, FSC Certified Wood (wood 
products originating from a certified forest or wood products containing both FSC certified 
material  and FSC Controlled wood) may carry on-product claims (FSC 100% or FSC Mix 
logos) directed towards consumers. 

Unlike sustainability certification schemes, timber legality certification schemes do not usu ally 
permit certificate holders to make on-product claims on their certified products.  

Accreditation of Certification Bodies 

Accreditation is the process of evaluating and approving certification bodies to function under 
the scheme rules. The goals of providing robust and objective conformance assessments 
imply  consistency  over time, locations, and between certification bodies with similar audit 
conclusions reached  – independently of the time, location, auditor, or certification body in 
question. Many approaches for calibration, guidance or interpretation have been employed 
by certification schemes to prevent or rectify threats to credibility and objectivity  – often in 
line with ISO or ISEAL guidelines.  

Schemes usually include requirements to ensure that certification bodies, auditors, and other 
personnel relevant to the conformance evaluation of an organisation are impartial in their 
decision  making.  Risks  to  impartiality  and  conflicts  of  interest  can  be  prevented  and 
monitored in various ways. 

Transparency 

Schemes  differ  in  their  level of transparency, some aspects of which are fundamental to 
allow operators, competent authorities and other organisations to evaluate the applicability of 
the certification scheme to their due diligence system. Examples of  where transparency is 
important to include: 

  The provision of information on certificate scope (forests, manufacturing facilities) and 

validity via publicly available official databases; 

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 

 

Information of relevance to buyers of certified products (species and origin, reclaimed 
content); 

Information  on  the  different  aspects  of  how  a  scheme  is  functioning  (normative 
scheme requirements for certificate holders). This is important for the evaluation of 
the applicability of a scheme to the EUTR. 

A good assurance system must also have detailed and consistently implemented procedures 
to  handle  appeals  and  complaints.  A  complaints  procedure  allows  the  expression  of 
dissatisfaction over the functioning of a scheme, scheme-related entities (certification bodies, 
accreditation bodies) or scheme participants (certificate holders).  

Certification Schemes and the EUTR 

The EUTR includes provisions to recognise third-party verification as a tool to mitigate risks 
in supply chains. Implementing Regulation 607/2012 details four  conditions necessary for 
certification  schemes  to  be  considered,  when  implementing  risk  assessment  and  risk 
mitigation: 

1.  they shall have established and made available for third-party use a publicly available 
system  of  requirements,  which  system  shall  at  the  least  include  all  relevant 
requirements of the applicable legislation;  

2.  they shall specify that appropriate checks, including field-visits, are made by a third 
party  at  regular  intervals  no  longer  than  12  months  to  verify  that  the  applicable 
legislation is complied with;  

3.  they shall include means, verified by a third party, to trace timber harvested following 
applicable legislation, and timber products derived from such timber, at any point in 
the supply chain before such timber or timber products are placed on the market;  

4.  they shall include controls, verified by a third party, to ensure that timber or timber 
products of unknown origin or timber or timber products that have not been harvested 
according to applicable legislation do not enter the supply cha in. 

The EUTR guidance document (Commission Notice of 12.06.2016 - Guidance document or 
the EU Timber Regulation) further details the role of third-party verification schemes in risk 
assessment and risk mitigation.  

These points form the basis for evaluating schemes in relation to the EUTR and defining the 
factors that can affect scheme performance and credibility. Each scheme includes different 
requirements, procedures, and assurance systems. Each will need to be evaluated by the 
individual  operator  sourcing  certified  products  to  determine  its  value  as  an  indicator  of 
negligible risk.  

The operator needs to ensure that the certification scheme can provide a sufficient level of 
risk mitigation as desired. Looking at certification schemes through the lens of d ue diligence 
is  therefore  about  understanding  the make-up and functioning of the schemes and their 
potential areas of strength and potential weaknesses to understand how these might impact 
existing risks in timber supply chains. 

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Comparing forest-related schemes against the EUTR 

Often the first information available to an operator about a certified product is a copy of the 
certificate itself – or a link to its publicly available online certificate database. Whether related 
to  certification  schemes’  standards  and  requirements,  or  the  schemes’  institutional  and 
procedural  arrangements, the following list provides some key elements which should be 
considered  for  evaluation  to  understand  the  strengths  and  potential  limitation  of  those 
schemes, given their use by operators to comply with EUTR requirements:  

  Scheme normative requirements and the definition of legality 
  Alignment with EUTR definitions, such as that for reclaimed material 
  Chain of custody (CoC) requirements 
  Certification claims and their specific meaning in relation to the EUTR 
  Robustness of the scheme quality assurance systems 
  Validity of certification (1-5 years) 
  Level of scheme transparency in findings, audit results and complaints 
  Stakeholder engagement in the certification scheme as indicators of the robustness 

and credibility of the scheme. 

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3. Background 

Concerns regarding deforestation, illegal logging, poor forest management and land rights of 
forest-dependent peoples – particularly in tropical timber-producing countries - emerged in 
the mid-1980s to early 1990 and was promoted by campaigns lead by NGOs and Indigenous 
peoples’  organisations  (FERN,  2001).  At  the  same  time,  the  concept  of  sustainable 
development  was gaining popularity in the wake of the 1987 Brundtland’s report and the 
United Nations Conference on Environment and Development (‘Earth Summit’) of 1992 in 
Rio de Janeiro, Brazil. In 1990, international negotiations aimed at setting up a global forest 
treaty were launched, but this process failed as the international community never reac hed a 
consensus on the content of a binding multilateral instrument on forests and the necessary 
definition of sustainable forest management and mechanism to enforce it (Perera & Vlosky, 
2006). 

In parallel, discussions between the forest products sector, consumers of wood products, 
environmental  and  human-rights  NGOs  led  to  the  development  of  a  non-governmental 
market-based  approach.  It  was  designed  to  provide  a  credible  way  of  identifying  well -
managed forests and timber products coming from those forests, while meeting the different 
needs  and  interests  of  actors  involved  (FERN,  2001).  This  started  the  development  of 
voluntary certification and soon after led to the creation of the Forest Stewardship Council 
(FSC) in 1993, as an early ‘front-runner’. Set up as an independent non-profit organisation 
with a global reach, FSC brought innovative decision-making processes accommodating to 
different  interests  and  shaped  the  form  that sustainable forest management certification 
would take through its ‘Principles for Forest Stewardship’ (Brown et al., 2008). 

In the next few years, competition in the field of voluntary certification emerged, mainly from 
national and regional initiatives: In the USA with the Sustainable Forestry Initiative (SFI) in 
1994, in Canada with the Canadian Standards Association in 1996 and the Pan-European 
Forest Certification (PEFC) in 1999 (Perera & Vlosky, 2006, Brown et al., 2008).  

The  multiplication  of  such  national  or  regional forest certification schemes soon brought 
debates over mutual recognition. Based on its successfully working with European industry, 
small forest owners and other stakeholders, PEFC re-launched in 2003 as a global initiative 
called  “Programme  for  the  Endorsement  of  Forest  Certification  schemes”,  working  as  a 
bench-marking scheme endorsing national certification schemes, such as SFI and CSA. By 
2019,  48  national  schemes  in  total  have  been  endorsed under PEFC. PEFC is now the 
certification scheme with the largest area of certified forest, followed by FSC, with a round 
325 million hectares and 210 million hectares certified, respectively. 

Given the timeframes required to achieve certification for Forest Management Enterprises 
(FME), as well as the time taken to build a critical mass of certified forest, a gap emerg ed 
between the available volumes of certified timber and the demand for certified material. One 
early obstacle to growth of the certified forest area, was the challenges faced by particularly 
wood chip and fibre industries, as the requirement to physically segregate certified and non-
certified material is very costly and untenable. Another obstacle was faced by producers of 
assembled  products,  for  whom  it  could  be  very  challenging  to  acquire  all  product 
components from certified forests. The result in both cases was an either-or situation, where 
either  all  or  nothing  of  a  production  could  be  marketed  as  certified.  To  address  these 
challenges, different procedures for mixing certified and uncertified material were introduced, 

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the two most common of which is the mass balance system (credit system) and the threshold 
system (percentage system). One consequence of introducing these mixing systems, was a 
drastic increase in the complexity of the certification schemes. 

Having  gained  wide  acceptance  internationally,  forest  certification  has  also  been  facing 
important challenges in relation to its first objective of halting deforestation through promoting 
sustainable forest management.  

Schemes have not always succeeded in certifying large areas of tropical forest, wit h the area 
of tropical natural forest under a certification scheme being relatively low in comparison to 
temperate natural forests and plantations. In 2002, tropical natural forests amounted to only 
8% of the total of certified forests (Purbawiyatna & Simula, 2008) and the overall percentage 
appears  to  have  changed  little  since  then. 51  Most  certified  forests  are  located  in  North 
America and Europe, where certification has greatly helped in steering forest management 
toward  more  sustainable  practices.  This  is  attributed  to  multiple  reasons  such  as  poor 
governance and corruption, but also the potentially considerable cost of certification and a 
lack of human, financial or technical capacities at the disposal of the organisations to engage 
in a certification process (Perera & Vlosky, 2006). 

Another challenge facing certification schemes is ensuring that smallholders of private forest 
can engage in forest certification without barriers and on equal terms with industrially - or 
publicly  owned  forests and plantations (Perera & Vlosky, 2006). Again, these challenges 
remain the high financial burden associated with certification and potential technical barriers 
to overcome. Many efforts have been made in this regard by certification schemes, such as 
the development of specific – or reduced – requirements for smallholders and the possibility 
for group or regionally-based certification.   

In  the  meantime,  government-led  action  to  fight  unsustainable  forest  management  and 
deforestation emerged with several regulatory measur es taken by countries or regions to 
restrict  the  entry  into  their internal market of products issued from illegal harvesting and 
trade. In this regard, the United States of America amended its Lacey Act in 2008, Australia 
adopted the Illegal Logging Prohibition Act in 2012 and the European Union launched its 
Forest Law Enforcement, Governance and Trade Action plan in 2003 and adopted its Timber 
Regulation (EU 995/2010) 52 in October 2010.53  

These  new  regulatory  measures  represent  a push to ensure the legality  of timber being 
traded domestically and internationally. They mainly took the form of obligations of timber 
businesses trading in forest products to exercise ‘due diligence’ or ‘due care’ in relation to the 
potential risk of illegality in the country of harvest or during their trade.  

The regulatory shift towards securing legality before aiming at sustainability, combined with 
the challenges of sustainability certification schemes, led to the development of certification 
or verification schemes geared toward ensuring the legality of timber.  

51 Global Canopy (2017) Certification Schemes Failing to Protect Tropical Forests 

52 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32010R0995  

53 The EUTR entered into force in March 2013. 

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This new crop of schemes encompasses the certification of legal harvesting directly at the 
forest level and may include the certification of legality in trade and transport at different 
points  in  the  supply  chain.  Other  schemes  focus  on  certification  of  the  robustness  and 
performance of due diligence practices conducted by an organisation on its timber supplies.  

These  latter  schemes  have  mainly  been developed by organisations already involved in 
delivering certification services for precursor schemes (for instance Bureau Veritas (OLB), 
Control Union (TLV), SCS (Legal Harvest) and NEPCon/Preferred by Nature (LegalSource).  

In  parallel,  other  certification  schemes  have  emerged  in  relation  to  more  specific  forest 
product groups or processes. Examples include the Sustainable Biomass Program (SBP)54  
as a scheme for sustainable biomass production, schemes for sustainably produced, non-
timber  forest  products  (e.g.  FairWild55,  the  International  Standard  for  Sustainable  Wild 
Collection of Medicinal and Aromatic Plants, etc.), as well as the ISO Standard sp ecifically 
for the traceability of timber products (ISO 38200/2018).56 

54 https://sbp-cert.org/  

55 https://www.fairwild.org/  

56 https://www.iso.org/standard/70179.html  

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4. Key features of certification 

Certification can be defined as the action or process of providing someone or something with 
an  official  document  attesting  to  a  status  or  level  of  achievement. 57  However,  not  all 
certificates function alike, and it important to understand the difference between different 
types  of  certificates  -  and the certification schemes that issue them  - to understand how 
these  can  be  used  as  part  of  a  due  diligence  process  to  mitigate  risks  of  illegal timber 
entering the supply chain. 

Certification refers to a variety of systems, either voluntary or mandated, which may focus on 
sustainability issues or limited to product legality only, or be limited to evaluating the system. 
As such, certification schemes can be divided into separate classes and types. Below is a 
brief overview of these different types and categories. 

1.1 Product or process certification 

Product  certification  describes  when  the  object  of certification is the product. Product 
certification  will  ensure  that  specific  requirements  are  met  (minimum-quality,  strength, 
composition of raw materials). Outside of forest-related certification, product certificatio n is 
often  used  in  the  manufacturing  industry  and  building  construction  sectors.  Product 
certification  may  cover  “System  certification”,  “Process  certification”  and  “Performance 
certification”. 

Process  certification  normally  focuses  on  specific  steps  in  the  production  process  to 
acquire specific product properties, such as expiration dates for food. This might be e.g. a 
minimum  temperature  or  pH level for a minimum period of time during processing before 
reaching these properties. Chain of Custody (CoC) cer tification would normally fall under 
“Process certification” where the processes of ensuring traceability in the production flow are 
certified. 

Whether focussing on the product or the process, another important distinction to make, is 
how  different  standards  or  schemes  determine  conformance,  taking  a  system-based  or 
performance-oriented approach.  

System  certification  describes  when  the  scheme  evaluates  the  existence  of  a  system 
aimed at achieving a specific goal. System standards evaluate the policies, pr ocesses and 
systems  in  place,  but  not  necessarily  or  primarily  the  performance  or  outcomes  of  the 
systems.  System-based standards focus on the processes rather than the outcome, with 
criteria  set  in  relation  to  a  management  systems  and  procedures  for  imple menting 
performance. These will therefore assure systems are in place (policies, procedures, etc.) 
and functioning, without focussing on specific thresholds or the results those systems are 

57 https://dictionary.cambridge.org/dictionary/english/certification   

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actually  achieving.  As  described  by  FERN  2001,  “system-based  standards  are  useful, 
particularly for large, complex companies managing a wide variety of impacts. However, a 
growing body of literature shows that implementation of system-based standards is not, on 
its own, enough to improve performance” (FERN, 2001). The ISO family of standards is a 
good  example  of  system-based  standards,  such  as  the  ISO  14000  standards series for 
environmental management systems. 

Performance -based  certification  focuses  on  the  necessity  to  reach certain thresholds, 
outcomes or objectives, while perhaps giving a certain flexibility on how these are achieved. 
Forest  certification  standards  are  usually  performance  oriented  to  some  level  (with 
requirements for specific actions or practices to be conducted, thresholds to be reached, or 
outcomes achieved). Minimum performance thresholds are defined by the scheme, and the 
auditing process focusses on the outcomes and if forest management activities reach that 
given performance level.  

In practice, both approaches are complementary and most of the for est-related standards 
include both systems and performance-related elements (FERN, 2001). 

2.1 Voluntary  (private) or mandated  (government)  certification 

Certification  schemes  may  be  either  voluntary  (usually  private  initiatives)  or  mandated 
(usually  government  run  initiatives).  Historically,  regulation  of  environmental  issues  has 
primarily been focussing on the use of regulatory mechanisms that impose requirements or 
restrictions on industries. However, the use of voluntary commitments as an alternative to 
traditional  regulatory  mechanisms  for  controlling  environmental  and  social  impacts  has 
become increasingly common since the inception of e.g the FSC in 1993.  

Regulations  comprise  binding  norms  adopted  by  the  legislative  or  executive  branch  of 
government within a determined political entity. These apply to all entities and individuals 
concerned  by  the  legal  system  in  place.  Violation  of  regulations  usually  leads  to 
administrative  and  judicial  proceedings  such  as  fines,  withdrawal  of  privileges,  rights  or 
sanctions.  

A voluntary certification scheme is usually developed by private entities. They can be private 
enterprises, business associations, civil society organisations, or a combination of different 
actors.  Governmental  bodies  can  be  represented  but  are  usually  not the only decision-
making actors within the scheme. Voluntary certification schemes may be backed, supported 
or  encouraged  by  governmental  bodies or public institutions (for instance India’s Timber 
Legality  Assessment  and  Verification  Scheme  -  VRIKSH  or  China’s  Timber  Legality 
Verification  System  -  CTLVS),  but  there  is usually a formal split between the legal entity 
running the scheme and public bodies. Certification schemes can have a global reach and 
apply to several countries without any formal association with sovereign states. 

Certification schemes may differ in their setup and approach depending on the overarching 
goal  of  the  individual  scheme,  be  that  for  example  1)  to  ensure  conformance  with  the 
applicable legislation in a given sector; 2) to ensure sustainable management practices; or 3) 
to ensure adherence to a given quality standard within a sector.  

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initiatives  develop  and  provide 

their  own  rules,  guidelines  or 
Non-governmental 
characteristics for products, processes and production methods, for which compliance is not 
mandatory  within  a  given  legal  system.  Certification  schemes  are  usually  proprietary 
systems,  in  that  entities  are  free  to  adhere  to  them  and  to  commit  to  comply  with  a 
certification scheme’s requirements. 

There  is  rather  a unique case of one country announcing its intention to make a private 
certification scheme mandatory for all its forests concessions: in 2018 Gabon announced that 
all  forest  concessions  will  require  to  be  FSC-certified  by  2022.58 This policy is still in the 
process  of  implementation,  and  could  be  considered  to  blur  lines  between  private 
instruments  and  public  regulations.  However,  the  FSC  scheme  would  continue  to  be 
controlled  and  managed  by  FSC  itself,  as  scheme  owner  and  as  a  non -governmental 
organisation. 

The  general  category  of  certification  also  encompasses what the EUTR is describing as 
“voluntary verification systems”. 59 In this case, sustainable forest management certification 
and timber-legality certification schemes share an important common element bein g their 
voluntary aspect.  

Broadly, government-led verification systems usually lead to the issuance of “licenses” linked 
to a single operator or product shipment rather than a “certificate” issued to the certified -
organisation (certificate-holder) and a “certification claim” applied to a product sold under that 
certification.  

This distinction applies to government-led mandatory legality verification systems elaborated 
within  the  context  of  bilateral  agreements  –  such  as  EU  FLEGT  Voluntary  Partnership 
Agreements (VPAs) and their Timber Legality Assurance Systems (TLAS). With regards to 
such public legality verification systems, once fully implemented, FLEGT licences issued as 
part of a functioning TLAS and are automatically compliant with the EU Timber Regu lation.60   

Operators  implementing  due  diligence  systems  must  be  able  to  differentiate  between 
mandated  government-led  initiatives  and  voluntary,  non-governmental  (private  sector) 
initiatives. 

3.1 Certification as an objective evaluation   

Objectivity is a key principle in certification schemes, and the institutions backing them are 
making  great  efforts  to  stay  independent  and  preserve  objectivity  in  conformance 
assessments. This is partly attained by having independent auditors evaluate con formance 
against  a  set  of  requirements  or  criteria  (standard). To achieve this in the evaluation of 
conformance, certification schemes incorporate the concept of an independent ‘third -party’ 

58 See: https://news.mongabay.com/2018/10/the-legal-institutionalization-of-fsc-certification-in-gabon-commentary/     

59 COMMISSION NOTICE C(2016)-755 of 12.2.2016, Part 6. 

60  This is notably the case of Indonesia implementing its own legality assurance system leading to the issuance of FLEGT 
licenses that can legally be imported into the EU without further due diligence.  

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organisation conducting the evaluation. The term ‘third -party’ can best be understood by 
describing all three main classes of an audit process:   

First-party audits (often known as internal audits) occur when an organisation itself will audit 
a  process,  product  or  procedure,  in  order  to  ensure  it aligns with a set of re quirements 
determined by the organisation itself (these may be fully elaborated by the organisation itself 
or  taken  from  an  external  source).  In  this  case  the  auditor  may  be  an  employee  of the 
organisation or an external consultant employed by the organisa tion to perform the audit. 
The  outcome  of  this  process  is  often  recommendations  or  corrective  measures  the 
organisation should implement as it sees fit to obtain certification.  

A  second-party  audit  occurs  when  a  company  or  organisation  with  a  relationship   or 
connection with the audited entity (the auditee), performs an audit to ensure that the auditee 
is  meeting  a  set  of  requirements.  These  requirements  may  include  special  control  over 
certain  processes,  requirements  on  traceability,  requirements  to  have  a vailable  specific 
documentation or records, or any of a host of other items of special interest to that customer. 
Whatever  the  outcome  of  this  process  is,  it  will  affect  only  the  relationship between the 
auditing  entity  (e.g.  customer,  trade  association  etc.)  and  the  auditee  (e.g.  supplier, 
association member etc.). 

First and second party audits or evaluations alone do not comprise certification in and of 
themselves (although these may comprise a part of the systems implemented by certified 
organisations). 

Third-party audits occur where the auditor is independent to the auditee and performs the 
audit to verify that it has succeeded in meeting a set of requirements. Independent auditing 
organisations within certification schemes may be referred to as Conforma nce Assessment 
Bodies (CABs) or – within this report - Certification Bodies (CBs). They provide independent 
assurance  that  the  auditee  meets  all  the  requirements  of  a  chosen  set  of  normative 
requirements (Standard) and continue to meet these requirements o n an ongoing basis.  

To  guarantee  objectivity,  several  independent  parties  may  be  involved  in  a  scheme’s 
certification  system  to  maintain  the  division of roles (e.g. standard setting, accreditation, 
certification)  This  is  usually  referred  to  as  Accreditation  (see  next  section). Additionally, 
various  measures  can  be  implemented  by  the  scheme,  such  as mechanisms to prevent 
conflicts of interest, address complaints and foment certification scheme transparency (see 
section 10). 

4.1 Financing  of certification schemes 

A key principle that is common to most private certification schemes which involve third -party 
auditing is the financing of these schemes. Forest owners, operators and traders who want to 
use private certification as part of their business are usually r equired to pay a fee to the 
certification scheme holder.  

How this fee is governed varies by scheme. Payment for the third -party auditing service may 
either be directly to the scheme (who would then pay the certification body) or directly to the 
certification body.  

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Some schemes may require payment of different fees to both scheme and to Certification 
Body. 

Figure 1: Overview of forest-related certification 

194 

 
 
 
 
 
ANNEX 1 : FOREST-RELATED CERTIFICATION SCHEMES – AN OVERVIEW 

5. Actors involved in certification schemes 

“A  fully  functioning  assurance  ecosystem  includes  several  players,  each  with  their  own 
responsibilities.”61Entities  involved  in  certification  schemes  may  be  any  kind  of  non -
governmental  entity  such  as  private  enterprises,  trade  associations,  non -governmental 
and/or non-profit organisations with various governance structures. Governmental bodies 
may  in  some cases be represented in voluntary certification schemes but will usually not 
have decision-making power. The main types of entities involved in certification schemes are 
discussed below. 

1.1 Scheme  owners or managers 

Scheme owners are responsible for the development, administration and maintenance of a 
certification scheme. This usually includes:  

  Developing a set of relevant normative requirements (standards). 
  Ensuring  the  maintenance,  revision  and  appropriate  interpretation  of  standards, 

including through elaborating guidance and tools. 

  Developing rules and procedures for certificate holders and the process by which 
their conformance with the standards will be determined (see sections 7, 8 and 9).  
  Formulation  and  implementation  of  an  assurance  system  to  ensure  a  proper 

functioning of the scheme (see sections 10 & 11). 

  Day to day operational management of the scheme, marketing, promotion, financing, 

etc. 

Scheme owners may be categorised according to their governance set-up. This will influence 
who has effective control over the scheme. A private structure where decision -making firmly 
rests on shareholders and their executive’s representatives may influence the functioning of 
a  certification  scheme differently than a membership-based organisation, where decision 
making rests with a large and open membership base. 

The  interests  of  the  scheme  owners  revolve  on  ensuring  its  credibility and consistency. 
Scheme owners also normally own the intellectual property, copyright, name and trademark 
of their scheme. 

ISO62 and ISEAL63 have developed guidelines relevant to scheme owners in the development 
of certification schemes. 

Sullivan 

61 
An 
https://www.certificationkitbag.com/blog/2018/5/3/an -assurance-ecosystem 

2008.  Who 

J.  May 

what? 

does 

assurance 

ecosystem. 

Available 

at: 

62 ISO/IEC 17067:20143 Conformity assessment – Fundamentals of product certification and guidelines for product certificat io n 
schemes. https://www.iso.org/standard/55087.html  

63 ISEAL Standard-setting Code of Good practice, ISEAL Assurance Code of Good Practice, ISEAL  I m pa ct s Co d e  o f  G o o d  
Practice. https://www.isealalliance.org/credible-sustainability-standards/iseal-codes-good-practice  

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Scheme  owners  can  also  act  as  accreditors  of  certifiers,  or  even  act  as  the  certifier 
themselves. 

2.1 Accreditation bodies 

Accreditation bodies are organisations that accredit other organisations (certification bodies) 
as qualified to deliver certification services based on a set of requirements. They will carry 
out regular evaluations of the certification bodies to ensure their ongoing competence to 
conduct conformity assessment work by evaluating their performance and conformity with 
scheme requirements, as well as the proper functioning of the system put in place by the 
certification body.64   

“To  assess  the  competency  of  a  conformity  assessment  body  (CAB) 65  the [accreditation 
body]  looks  at  the  systems,  process  and  procedures  used  as  well  as  how  they  are 
executed.”66 Evaluations of certification bodies by accreditation bodies can cover, inter alia, 
the following elements:  

  Evaluating the relationship between certification bodies and their clients (certificate 

holders). 

  Ensuring that the staff involved are qualified and competent. 
  Ensuring the proper planning and execution of audits. 
  Ensuring conformity to scheme requirements in relation to certification decisions and 
the identifying and evaluating of non-conformities by the certificate holders, as well as 
concluding non-conformities. 

If  an  accreditation  body  is  included  in  the  scheme’s  institutional set-up; it will usually be 
chosen by the scheme owner. According to each scheme, one or more accreditation body 
may  exist.  For  example,  PEFC  accepts  accreditations from members of the International 
Accreditation Forum (IAF) or other regional accreditation groups such as the European co -
operation  for  Accreditation  (EA).  On  the  contrary,  the  FSC  works  only  with  Assurance 
Services International (ASI). 67 Some accreditation bodies work at a national or regional level, 
whilst others may have an international reach (ASI for instance). 

Not all certification schemes function with a separate accreditation body. The scheme owner 
can also conduct accreditation activities itself to endorse other organisations as certification 
bodies, dispensing with the need for a separate accreditation body. This is more common in 

64  ISO  describes  accreditation  bodies’  role  as  providing  "third -party  attestation  related  to  a  conformity  assessment  body 
conveying formal demonstration of its competence to carry out specific conformity assessment tasks”.  ISO 17011:2004 3.1. 

65  Within  forest  certification  schemes,  the  term  Certification  body  (CB)  describes  the  Conformity  assessment  body  (CAB) 
responsible 
: 
of 
https://www.iso.org/sites/cascoregulators/01_3_conformity-assessment-bodies.html  

holders.  See  

organisations 

conformance 

evaluating 

certificate 

and 

the 

for 

Sullivan 

66 
is 
https://www.certificationkitbag.com/blog/2014/12/3/accrediation -why-bother  

Accreditation 

J.,  May 

–  What 

2008. 

it 

&  why 

bother? 

Availabl e 

at: 

67 Assurance Services International: https://www.asi-assurance.org/s/      

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the  case  of  many  legality  verification  schemes,  where  the  scheme  owner  is  also  an 
accredited Certification Body. 

Alternatively, a scheme owner may act directly as the certification body of certificate holders. 
Within the scheme owner’s organisational structure, distinct functions or responsibilities may 
be placed on part of the organisation to oversee and ensure the quality of a separate part of 
the organisation which conducts the auditing activities. 

3.1 Certification bodies 

Certification  bodies  (CBs)  are  the  entities  that  will  deliver  certification  services,  mainly 
through auditing practices. Individual auditors normally work for a certification body. Their 
role  is  to  ensure  that  certificate  holders are conforming to the applicable relevant set of 
requirements,  while  themselves  following  the  relevant  procedures  set up by the scheme 
owner for CBs. 

CBs work in a third-party capacity, they need to be impartial to ensure objective auditing and 
certification decision-making and thus uphold the credibility of the scheme. 

CBs can vary in reach, size and organisational set-up. “They can come in any organisational 
form and ownership, and can be commercial in focus or not-for-profit entities". T hey can be 
government  agencies,  national  standards  bodies, 
trade  associations,  consumer 
organisations,  or  private  or publicly owned companies.”68  However, in the case of forest-
related certification schemes, they are very rarely government agencies.  

Usually, there is a competitive market among CBs who will charge a service fee to certificate 
holders. 

It can also be the case the scheme owner is delivering certification activities itself. This is 
commonly the case of many private-sector legality verification schemes.  

The Guidance Document for the EU Timber Regulation 69 refers to “certification” as those that 
usually  include  an  accreditation  process  and  where  the  scheme  owner  and  certification 
bodies are separated. The guide refers to “proprietary timber legality verification schemes” to 
describe schemes where the scheme owner is also the certifier. 70  In theory, separating the 
scheme  owner  and  the  certifier  allows  for  greater  credibility,  as  it  allows  for  the  skills, 
procedures, and impartiality of the certifiers to be regularly assessed (FERN, 2001). 

4.1 Certificate holders 

68 ISO. Conformity Assessment bodies. https://www.iso.org/sites/cascoregulators/01_3_conformity-assessment-bodies.html  

69 https://ec.europa.eu/environment/forests/pdf/eutr_guidance.zip  

70 It is important here to make the distinction between independent verification system and government-led verification syste m s,  
such as the Timber Legality Assurance Systems developed by States in the context of a Voluntary P a rt n e rsh i p A g re e me nt  
(VPA) negotiated with the EU (Brown et al., 2008). Also see COMMISSION NOTICE C(2016)-755 of 12.2.2016, Part 6.  

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Certificate  holders  (or  applicant  certificate  holders)  are  the  organisations  (forest 
owners/processors) willing to voluntarily commit to conformity assessments against one or 
several standard(s). As they are regularly assessed by auditors, they are generally referred 
to  as  the “auditee”. A distinction is sometimes made by a Certification Body between the 
‘certification client’ (which finances and is responsible for the certification) and the auditee, 
which is the organisation being audited. Certificate holders may in many cases also exert 
influence over a scheme, as members of the scheme, enabling them to put forward motions 
and  vote at the scheme’s general assembly, participate in standard setting processes or 
other technical working groups and be represented in the board of directors of the scheme. 
Certification  schemes  may  in  return  depend  on  established,  well-known  brands,  to  gain 
market recognition and reach consumers. 

5.1 Other stakeholders 

While developing a standard can rest solely in the hands of the scheme owner, it can also be 
a collective exercise involving stakeholders.  

It  is  recognised  that  stakeholder  engagement  is  crucial  for  any  credible  scheme 71  and 
involving  many  stakeholders  can  be  quite  a  challenge,  in  particular   if  poorly organised. 
“Crucial differences in standard setting between schemes appear to be related to: (i) the 
meaningfulness or effectiveness of participation by interested parties; (ii) interpretation of 
situations in which a stakeholder group does not participate even though it is invited to do so; 
and (iii) the possible dominance of certain parties” (Purbawiyatna & Simula, 2008). 

71 “As the standard-setting process is arguably the most politically contentious part of forest certification, any cre d i ble  sch e me  
must  engage  all stakeholders in participation, and no stakeholder group should be allowed to dominate. Certain forestry 
Scheme do impose conditions on participation of relevant stakeholders for the development and maintenance o f  S t a nd ard s. ” 
Participation as a very important element has also been acknowledged by the International Forest industry rou n d  t a b le  (IFIR) 
and by the Intergovernmental Panel on Forests (IPF). The ISEAL Code of Good Practice for Setting Social and Enviro n me n t a l 
Standards also establishes the guidance that “the standard -setter informs stakeholders about why the standard is important and 
communicates  to  them  how  they  can  participate  in  the  standards  development  or  revision  process.  The  standard -setter 
proactively engages with stakeholder groups that are likely to have an interest in the standard or that are likely to be affe cted by 
its implementation and provides them w ith mechanisms for participation that are appropriate and accessible. Stakeholders f e e l 
that their views are represented in the consultation process and in decision -making”. 

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Figure 2: Overview of Overview  and roles of actors in certification schemes 

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6. Requirements for certificate holders 

A key component of a certification scheme is the set of requirements to which a certificate 
holder shall conform. These are the performance requirements upon which the scheme is 
based,  often  formulated  hierarchically  into  different tiers, such as principles, cr iteria and 
indicators  –  the  indicators  are  the performance threshold a certificate holder (current or 
prospect) should comply with. 

1.1 Standards 

A  standard  is  a  set  of  requirements  applied  to  similar  entities  operating  under  similar 
conditions. A certification scheme can comprise several standards. For instance, both the 
PEFC and FSC schemes comprise global standards (applicable to different types of entities 
internationally, independent of location) and national or regional standards (comprising a set 
of requirements specific to a country or region). 

In forest certification, forest owners or management enterprises usually must conform to one 
(forest  management)  standard,  while  processing and trading entities may be required to 
conform to a different (chain of custody and/or due diligence) standard: as their activities are 
fundamentally different, two sets of broad rules are needed (see section 7).  

It is also common to find distinct standards for specific situations such as ‘group’ or ‘multi -
site’ certification for the certification of multiple independent forest or supply-chain entities 
(group-certification standards). ‘Multi-site’ standards include special requirements for larger 
supply-chain organisations with multiple operational sites or facilities. Specialised standards 
for  small-scale  forests  (small-holders,  family-owned  forests  or  owners  of  small  areas  of 
forest, low-intensity managed forests, or for small-scale processors and traders within the 
supply  chain),  standards  for  the  making  of  certification-related  claims  and  the  use  of 
trademarks, and standards for project certification (for the certification whole buildings or 
other projects), etc.  

A certificate holder may be required to abide by one or several standards simultaneously. For 
example, many supply-chain organisations are certified for PEFC and/or FSC, for their chain 
of custody and to the standards which govern the use of trademarks. 

Standards can also be elaborated to frame the actual functioning of the certification scheme, 
for example to set up requirements for the accreditation (approval) of certification bodies or 
to describe the development process for standards themselves (see section 9).  

So, in terms of understanding the meaning of a certificate, it is important to understand which 
standards the certificate holder is certified against. 

Finally, the use in standards of the terms ‘shall’ and ‘should’ often has significance. In line 
with ISO norms, requirements presented with ‘shall’ are mandatory for certificate holders, 
while the elements presented with ‘should’ are highly recommended, although it is possible 
that in exceptional or justified cases they can be disregarded. 

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6.1. Principles, criteria, indicators 

The normative requirements listed within standards are usually structured within a hierarchy 
according to the size and importance of the requirement. A common approach – particularly 
for forest-management standards – is the use of principles, criteria and indicators.  

Principles describe general guiding values. These may be comprised by one or more criteria, 
which  will  detail  key  requirements  needed  to  achieve  each  principle.  Criteria  may  be 
comprised by one or more indicators. Indicators will contain more  tangible conditions that 
must be met, and which will help measure performance and assess whether a criterion is 
met.  When  employed  by  the  certification  scheme,  ‘verifiers’  specify  which  measure  or 
elements shall be used to assess conformance by the certificate holder with a criterion or 
indicator. 

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Figure 3: Illustration of the structure of standards. Excerpt from The FSC National Forest 
Stewardship Standard of the Federal Republic of Germany (approved 26 October 2017) 

It is common for supply-chain related (e.g. chain of custody) standards to contain a simplified 
hierarchy of principles and criteria only. 

Certification schemes often use a generic set of principles, criteria and indicators that are 
then  adapted  or  adjusted  to  regional,  national  or  other  co ntexts,  normally  through  the 
development of applicable national certification standards. This approach, or a variation of it, 
is  commonly  applied  to  forest-management  standards.  Other  standards  - such as those 
relevant to chain of custody, group or multisite certification or those for certification -related 
claims  –  are  often  not  adapted  to  national  or  regional  contexts  and  thus  remain  as 
internationally applied standards. 

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2.1 Procedures, policies  and other normative  documents 

In addition to standards, most certification schemes employ the use of additional guidance, 
policies,  procedures,  rules,  and 
to  support  consistent 
implementation of requirements and functioning of the scheme. 

interpretative  documents 

Apart  from  the  standards,  where  the  direct  normative  per formance  requirements  are 
described, these additional documents may also be normative for the certificate holder by 
adding to, clarifying or expanding upon the principles, criteria and indicators.  

In particular, interpretations by the scheme owner provide clarifications and/or guidance on 
the  implementation  of  standards  requirements  –  for  the  benefit  of the certificate holder, 
Certification Body or other scheme stakeholder. 

By its nature, certification guidance, whether it is in the form of stand -alone documents, or 
guidance text within a standard, is not normative but provides additional information which 
may serve to explain or interpret the normative requirement. 

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7. Defining the scope of a certificate 

Understanding the scope of a certificate is critical to understanding what the certification of 
an organisation represents and covers. Organisations to be evaluated, i.e.  Organisations to 
be evaluated (e.g. a forest operation, sawmill, manufacturer), i.e. a prospective certificate 
holders, usually need to define the scope of forest or forest-products and activities which will 
be evaluated by the Certification Body. It is not a requirement – nor a common occurrence – 
within most schemes that all forest operations or products managed by an organisation need 
to  be  included  within  the  scope  of  the  certificate  and  evaluated  as  conforming  with  the 
applicable standards. An organisation may wish to certify only a part of its forest operations 
or products. Therefore, a partial-certification scope can be determined and is usually defined 
and restricted within requirements set by the scheme.  

In  other  words,  partial  certification  of  an organisation’s (forest operation or supply -chain 
entity) product range - is usually feasible and permitted by the certification scheme. However, 
clarity in defining the scope of a certificate is essential to reducing the potential for confusion 
amongst certificate holders and certification bodies, as well as stakeholders and potential 
buyers of certified products.  

The following considerations are also important: 

  According to each scheme, a forest owner or management organisation may decide 
to  include  only  some  of  the  forests  under  its  management  –  e.g.,  specific  forest 
management units (FMUs) – within the scope of its certification (see section 7.2).  

  As regards all other processing and trading entities, certificate -holders can usually 
choose  among  specific  products  or  materials  (product,  species,  etc.)  or  lines  of 
production  for  which  (chain  of  custody)  is to be certified, whilst other produ cts or 
materials handled by the organisation will remain non-certified and will be excluded 
from  the  scrutiny  of  the  certification body. In the case of a certified due diligence 
system  (DDS),  at  their  discretion,  certificate-holders  may  determine  the  specific 
products or supply chains included within the scope of the certificate (see section 
7.3). 

The  following  sections  describe  the  different types of elements that can form part of the 
scope of a forest sector certification scheme. 

1.1 Certificate requirements   

7.1. Sustainable forest management (FM) 

Sustainable  Forest  Management  standards  usually  include  requirements  linked  to 
management  planning,  monitoring  impacts  of  management  activities,  inventories,  the 
implementation of silvicultural practices, the construction of forest infrastructures and other 
on-the-ground  operations,  as  well  as  ecological  and  social  objectives  (conservation  of 
biodiversity, improvements of livelihoods, acknowledgment of traditional land-use rights, the 
inclusion of stakeholders and local communities in decision making, etc.).  

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In addition to best-practice methods for sustainable forest management, Sustainable F orest 
Management standards often include the following: 

  a  commitment  for  sustainable  forest  management  and  may  include  continuous 

improvement approaches from forest owners or managers; 

 

requirements to comply with the legislation applicable in the jurisdiction within which 
the  forest  operations  are  located.  These  requirements  comprise  a  baseline  for 
sustainable forest management certification schemes, to which sustainability criteria 
are added; 

  specialised sets of requirements for specific situations, such as for the certification of 
small-holders or owners of small areas of forest, of non-timber forest products, or of 
group  certification  (allowing  a  smaller  size  enterprise  to  be  covered  by  a  single 
certificate). 

The two most important global forest-related certification schemes are PEFC and FSC:  

  National forestry certification schemes and their forest management standards are 
endorsed by PEFC. PEFC will approve the standards, if they meet specific content 
and quality thresholds.72 In this regard, the PEFC approach takes a bench-marking 
approach  to  existing  schemes  and  standards,  with  PEFC  existing as an umbrella 
organisation under which  national forest management schemes and standards are 
endorsed. 

  FSC,  with its global forest management standard, has developed a generic set of 
criteria  and  indicators  to  meet  its  principles,  which  are  translated  into  nationally 
adjusted standards that have been developed according to specific procedures set up 
by FSC. 

7.1. Legal forest management or harvesting 

Forest-related certification standards have historically focused on the need to define and 
encourage  environmentally  responsible,  socially  beneficial,  and   economically  viable 
managed forests. Normally these standards also include requirements around compliance 
with existing legal frameworks, as the basis for constructing a more sustainable approach.  

However,  for  some  certification  schemes  -  namely  those  focusing  on  timber-legality 
verification  only  -  the  forest-related  standard  may  be  limited  to  ensuring  the  legal 
management and harvest (or even only legal-harvest) of wood-products. Such standards are 
considerably  less  ambitious  in  their  requirements  than  sustainable  forest  management 
standards, as they do not incorporate the social, environmental, and economic best practices 
associated  with  sustainable  or  responsible  management  of  the  forest.  Rather,  they  are 
restricted  to  ensuring  that  the  activities  carried  out  within  a forest management unit are 
conducted in line with applicable legal provisions only. 

72 PEFC endorses existing certification schemes “through a rigorous assessment to confirm [they are] deve lo p ed  i n l in e  wi t h 
[PEFC]  requirements  and  meet  [their]  demanding  international  benchmark  standards”.  https://www.pefc.org/standards-
implementation/meeting-global-expectations.  

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While ensuring legality might seem simpler and more straightforward at first sight, several 
challenges exist. Examples may include: 

The definition of legislation related to forest management and timber harvesting.  

  While the EUTR has its own definition of applicable legislation in the context of five 
specific  areas,  schemes  may  develop  their  own  and/or  may  adapt  the  definition 
differently to include or exclude different elements of applicable legislation. 

  Ambiguities  in  relation  to  legal  requirements,  or  contradictions  between  legal 

requirements at different administrative levels within a jurisdiction. 

Some  schemes  incorporate  requirements  on  legal  conformance   of  trade  and  transport 
operations  within  the  supply  chain,  while  other  schemes  do  this  only partially, or do not 
incorporate such considerations. 

In  the  case  of  the  major  schemes  containing  sustainable  forest  management standards 
(FSC, PEFC), these have traditionally looked at ensuring the sustainable management of 
forests. Historically the schemes have paid less attention to legal compliance in relation to 
trade,  transport,  and  customs within and between supply-chain entities. Requirements in 
relation to the legality of trade and transport of wood-products along the supply chain have 
been added later. 

7.1. Due diligence schemes  

Within  some  certification  schemes, due diligence system (DDS) standards determine the 
requirements applicable to the policies and procedures that a certificate holder puts in place 
to ensure that it is not sourcing wood products or raw materials which are illegal, of unknown 
origin, or otherwise ‘controversial’ or ‘unacceptable’ according to scheme requirements 73 - for 
their use in manufacturing processes. Each scheme will provide a definition of ‘unacceptable’ 
raw materials, which in most cases includes illegally harvested or traded wood -products or 
material.  However,  the  exact  scope  of  legal  requirements  covered  by  the  definition  of 
unacceptable material varies between schemes. 

DDS  requirements  developed  by  the  schemes  focus  on  the  existence  of  appropriate 
procedures on collecting information on supplies, conducting risk-based assessments based 
on supply-chain information gathered, records of risks and implementing mitigation actions 
where  a  risk is identifid. Additionally, the scheme may include requirements for the DDS, 
such  as  the  need  for  documented  procedures  and  training  records.  Other  quality 
management requirements, such as the ongoing periodic (first-party) evaluation of the DDS 
and maintenance of the due diligence system itself may be included. 

DDS standards may or may not have been developed specifically to support organisations 
under  an  obligation  to  implement  a  due  diligence system for wood-products imported or 

73  Due  diligence standards vary in their description or list of controversial or unacceptable sources of wood products or raw 
material, according to the scheme requirements. Beyond illegally harvested or traded wood product s, type s o f  u n a cce p t ab le 
wood material, found across a number of schemes, include wood supply associated with from conversion  o f  n a tu ra l f o re st s,  
areas of social or other conflict, harvested in violation of HCVs or ecologically sensitive areas.  

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placed  into  a  regulated  market  (for  instance,  operators under the EUTR). However, any 
organisation along the supply chain can in theory implement its own due diligence system. 
Examples of stand-alone due diligence standards include, among others:  

  Bureau Veritas: DDS 
  Control Union: Timber Legality Verification (TLV) 
  SCS: Legal Harvest 
  Preferred by Nature: LegalSource 

Sustainability  schemes  have  also  incorporated  due diligence concepts within their set of 
standards requirements – namely Controlled Sources (PEFC) and Controlled Wood (F SC). 
These  are  applied  to  the  portion  of  non-certified  raw  materials  that  can  be  mixed  with 
material  coming  from  certified  forests.  Within  these  schemes,  the  supply  chain  entity 
responsible for the first mixing will be obliged to conform to both the chain of custody (COC) 
and Due Diligence System (DDS) requirements. However, via claims in business-to-business 
transactions, both FSC and PEFC also allow the trade of products or materials su bjected to 
their due diligence systems to be traded independently, without being mixed with material 
coming from certified forests. 

7.1. Traceability or Chain of Custody (CoC) of timber products 

‘Chain of custody’ (CoC) refers to the physical path taken by a given product or material at 
various  stages  of  an  industrial  process  or  along  a  supply-chain,  with  the  certification 
evaluation usually taking place at each node (entity) in the supply-chain. T he objectives of 
chain of custody standards are usually to link products to their source of origin and ensure 
that a product with a certification status maintains its status along the supply chain without 
being  mixed  with  products  or  materials  with  a  different  certified -status  or  non-certified 
material. 

While most CoC systems developed by certification schemes are not providing traceability 
back to the forest of origin, CoC standards do contain requirements designed to ensure that 
mixing or substitution of products or materials with a different certified status – or uncertified 
material – is not occurring along supply chain from the forest of origin to the final consumer. 
Each link in the supply chain must implement those requirements for the whole system to 
function. The CoC is not stronger than the weakest link in the chain. 

Specific  requirements can apply to operations with multiple factories or storage locations 
(multi-site requirements) or groups of entities under a single certificate. 

CoC requirements will typically include options for segregation of materials via ph ysical and 
temporal means, or via labelling approaches, to ensure that certified material is not mixed 
with uncertified material.  

Calculation methods such as ‘percentage’ or ‘mass balance’ (credit system) approaches may 
also exist to allow virtual accounting scenarios, where the amount of certified inputs matches 
the  amount  of certified output for a given entity along the supply chain, over a period or 
production batch. Particularly, ‘mass balance’ methodologies allow for the selling of wood -
products as certified, by drawing down from a mass balance (or credit) account of certified 
raw material that has been purchased by an organisation. The credits are then consumed 

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whilst certified product is manufactured. Actually, certified raw material may or may not h ave 
been incorporated into product being sold as certified.  

Mass balance systems can be quite technically complex as they involve the management of 
significant  amounts  of  data  and  volume  information,  as  well  as  the  use  of  conversion 
factors.74 They also have an impact on certification claims consequently carried on output 
products.  Different  mass  balance  calculation  systems,  combined  with  Due  Diligence 
Systems,  permit  the  mixing  of  certified  material  with  un-certified  material  and will enable 
different product claims. 

As mentioned above, CoC standards are not used – nor able – to link timber products to a 
specific  forest.  However,  they  can link timber products to certified forests in general and 
provide consumers with assurance that the timber product sold a s certified is connected to 
forests whose management has been verified as conforming with certain requirements. T his 
is not the case for mass balance systems described above. 

With the rise of due diligence requirements within certification schemes and the inclusion of 
due diligence ‘controlled’ material or sources in the production of certified products, CoC 
standards  can  also  be  used  to  link  a  product to supply chains where an organisation is 
implementing a risk-based approach to sourcing to exclude material of unknown or illegal 
sources from entering the supply chain.  

FSC, PEFC and other organisations such as ISO   75have a global or ‘generic’ CoC standard 
that is applicable to all supply-chain entities, regardless of type or location. 

74 All wood processing – from converting whole logs into sawn boards, the drying of wet timber products, to the manufact u re  o f  
any (pulp, paper, solid or composite) product, inevitably means that a larger volume of wood material will be co n vert e d i n t o  a  
smaller volume, due to the production process. A conversion factor is primarily a ratio of raw-material input to ou t p ut ,  su ch  a s 
from  round logs to finished or semi -finished wood products. The measurement of conversion factors is commonly made to 
understand or verify the efficiency and technical progress of forest industries. The forest sector – and auditors – use conversi o n  
factors  as  a  tool  for  analysing/verifying  forest  production,  wood product manufacturing and the performance of industrial 
processes. 

75 ISO 38200/2018 

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Figure 4: Overview of the traceability system / transfer of claims through the supply chain 

2.1 Organisational  or area based scope 

A  forest  management  certification  may  include  the  entirety  of  the area or areas (Forest 
Management Units) owned or managed by the forest managemen t enterprise (FME) or be 
limited to selected FMUs. 

According to each scheme, rules may differ as to the extent to which this is permitted by the 
certificate holder, as well as what additional normative requirements, policies or procedures 
may apply to the FMUs not included within the certification. These areas may be of particular 
concern to the scheme if management objectives transgress greatly from the requirements 
for certification for the out-of-scope forest areas in comparison with certified forest areas, 
potentially violating the stated objectives of the scheme for sustainable forest management 
or even legal harvesting and trade. 

Different  schemes  may  also  provide  different  rules  or  normative  requirements,  where 
certificate holders may wish to exclude  specific areas within certified Forest Management 
Units from a certification. Similar concerns by the scheme may exist as described above, and 
such situations may not be commonly occurring within the scheme. 

As a result of the above, it is critically important for the certificate holder, certification body 
and scheme to have clear requirements in relation to how partial certification scopes are 
communicated.  This  is  essential  to  avoid  mis-claims  and  confusion  amongst  buyers 
(including Operators, Monitoring organisations or competent authorities as far as the EUT R 
is concerned) in relation to which forest areas are covered by certification.  

3.1 Products or supply-chain  scope 

For processing or trade organisations, the scope of their certificate may be limited to  certain 
products consisting of – or incorporating in its production – certified raw material. 

It  is  standard  across  all  schemes  that  certificate-holders are generally free to select the 
specific products or materials (product, species, etc.) or lines of pr oduction for which chain of 
custody  certification  will  be  sought,  whilst  other  products  or  materials  managed  by  the 
organisation  will  remain  non-certified and out of the scope of the certification. Effectively 
excluding it from the scrutiny of the certification body.  

As a result, while some organisations may manufacture or trade only certified products, it is 
common that certificate holders have certified only a proportion of the scope of products they 
make available within a market. Few, if any, schemes place restrictions or a lower threshold 
limit  on  such  entities  with  regards  to  the  proportion  of  products  they  are  required  to 
manufacture or trade as certified. 

In the case of schemes which incorporate a certified due diligence system (DDS), certificate -
holders again may usually select at their discretion the specific products, materials or supply 
chains included within the scope of the certified DDS. In some instances, such as PEFC and 

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FSC, they may however be required to ensure certain materials used in l ater stages of a 
production units are subject to scrutiny within the DDS. 

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8. The certification process 

Most  certification  schemes  apply  a  comparable  structured  approach  to  evaluating  the 
conformance of certificate holders. The following describes some key aspects of this process 
and clarifies the meaning of some of the terms often used. 

1.1 Auditing  conformance 

The  evaluation  of  the  certificate  holder’s  conformance  with  the  relevant  requirements 
(standards)  is  usually  conducted  through  audits.  Audits  usually  involves  on-site visits in 
which representatives of the Certification Body conduct an evaluation of the performance of 
the  certificate  holder  (or  prospective  certificate  holder,  in  the  case  of  certification  main 
assessments),  through  different  methods  (document  review,  direct  observation  and 
measurement, interviews with staff and consultation of stakeholders). 

Audits may be located at different stages of the certification process and therefore serve 
different purposes. 

The types and frequency of audits are normally detailed within scheme rules and procedures. 
The usual types of audits are:  

  Certification main assessment: these are usually the principal audit conducted of 
an organisation entering a certification scheme. Often, all the applicable requirements 
will be assessed during such audits by the auditor pertaining to the certification body.  

  Annual or surveillance audits. These types of audits may be less intensive than 
certification and re-certification audits but are designed to ensure a programme exists 
of direct ongoing monitoring of the certified operation’s activities. Requirements may 
be partially assessed and/or lower sample rates employed by the certification body.  

  Re-certification or re-assessment audits happen at the end of a certification cycle 
(often  5  years).  They  are  normally  very  similar  in  practice  to  certification  main 
assessments. 

Verification audits may also be conducted to evaluate the closure of non-conformances 
(see section 8.1.3) outside the normal audit schedule. Similarly, scope-change aud its  may 
be  employed  where  the  certificate  holder  wishes  to  significantly  alter  aspects  of  its 
certification scope between regular audits. 

In addition, many schemes allow for certification bodies to conduct un-announced or ‘short-
notice’  audits  in  case  major  non-conformances  are  identified  outside  the normal audit 
schedule, or in a case where a substantiated complaint regarding a certified organisation is 
raised by a stakeholder.  

Another distinction that can be drawn is the method of audit: some schemes require on -site 
audits allowing direct observations, monitoring and in-person interviews to be conducted. In 
other circumstances a certified organisation may be assessed via a remote (desk -based) 
audit, mostly limited to the review of information provided electronically by the audited entity 
(although remote interviews are also possible).  

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Often,  a  combination  of  on-site  and  remote  audits may be employed within the scheme, 
under different circumstances. 

8.1. Conducting audits 

Certification  schemes  usually  set  rules  on how audits should be conducted. Certification 
Bodies  are  usually  required  to  apply  a  documented  methodology  for the assessment of 
organisations. These rules usually address:  

  audit coverage (physical locations and activities covered). 
 

frequency of audits – standard among most schemes is that significant (annual or 
surveillance) audits are conducted within 12 months of each other. 

  steps that the audits must include. For instance: opening and closing meetings, which 
activities must be evaluated; individuals to be interviewed or stakeholders consulted.  
the necessary skills, qualifications, and experience of auditors. 
the duration that should be spent by auditors for various types of audits (this can be 
set  up  in  terms  of  person-days).  Other  audit  timeliness  factors,  such  report 
submission to the certificate holder after the audit has been completed.  

 
 

  How audits must be recorded and how audits records are managed. 

  Codes of conduct applying to certification bodies and auditors (availability, timeliness,  
accuracy, etc.). For more information on the topic of conflict of interest between the 
auditor and the auditee, see section 9.2. 

Schemes may differ in the extent to which the requirements for forest management and for 
supply chain entities shall be applicable to the organisation’s contractors and outsourcing 
facilities, as well as to their own staff. 

In  forest  certification,  an  important  distinguishing  element  between  schemes  is  whether 
stakeholder  consultation  shall  comprise  a  part  of  the  audit  process,  a s  part  of  forest 
management or harvesting evaluations. The value of stakeholder consultation, when done 
properly, lies in its ability to improve the rigor of the audit process  – and therefore of the 
scheme itself – by providing greater assurance that the certificate holder is conforming to the 
Scheme requirements. It does this by, among other things: i) assisting in audit planning by 
directing the auditor towards issues raised by stakeholders and ii) capturing issues which 
may otherwise have escaped the attention of the auditor/or which the auditor would unlikely 
capture  due  to  limitations  of  time  or  resources.  Schemes  differ  in  the  extent  to  which 
mechanisms exist to ensure that Certification Bodies conduct stakeholder consultation.  

Often amongst the accreditation requirements, schemes usually seek to ensure that auditors, 
and  other  relevant  personnel  of  the  Certification  Body,  are  qualified  and  competent  to 
evaluate organisations’ compliance with specific Scheme requirements. 

8.1. Audit reports 

Most schemes require that a description of audit findings and conclusions reached by the 
auditor, be recorded in the form of a confidential audit report. Rules in place can determine:  

 
 

the structure and elements to be included in audit reports. 
the requirement for internal report review processes. 

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 

the level of confidentiality of the report or its constituent parts 

On this last point, a scheme might request that the whole - or part - of an audit report are 
made publicly available as a pledge of transparency. In the case of PEFC, public summaries 
of audit reports are not made available by the scheme centrally. In the case of F SC F M and 
Controlled  Wood  audits,  public  summary  reports  are  publicly  available  via  the  scheme 
certificate database (https://info.fsc.org/). 

8.1. Non-conformities  

During  audits,  auditors  will  assess  whether  the  organisation  is  in  conformance 76  with 
applicable requirements. Non-conformances can be considered as the failure to implement 
and maintain, systems or procedures  – or the meeting of performance thresholds – which 
affect the organisation’s ability to meet one or more requirements of the standard, that may 
result in a risk to the functioning and effectiveness of the certification as int ended by the 
scheme. 

Non-conformances  may be split between “major” and “minor” size classes, depending on 
their gravity and scale. Different categories of a non-conformance: 

  can  lead  to  a  different  deadline  for  corrective  measures  to  be  implemented  (for 
instance, prior to certification, or up to 3 months for a major non -conformance versus 
up to 12 months for minor non-conformance). 
impact differently on the certification decision (e.g., prior to certification) 

 

For  some  schemes ‘Observations’ may be raised  by the auditor, which bring to attention 
issues of potential risk of non-conformance. According to the schemes, an evaluation finding 
may not warrant a non-conformity but is identified by the audit team as an opportunity for 
improvement. 

It should be noted that schemes may or may not require a different response, where the non -
conformance relates to a legal non-compliance. In some schemes, legal non-compliances 
are likely to influence the gravity and scale of the non-conformance which is concluded by 
the  auditor.  However,  Auditors  are  generally  under  no  obligation  to  inform  a  relevant 
competent authority in the case they observe activities in breach of legislation to which the 
certificate  holder  is  bound.  If  observed  breaches  take  place  outside  the  scope  of  the 
certification,  the  auditor  may  not  be  in  a  position  to  mark  this  as  a  non -conformance, 
although some schemes do provide avenues and alternative options to raise such issues. 

8.1. Certification decision 

Based on the conclusion of the audit, a certain recommendation will be reached whether to 
grant or approve certification for an organisation – or to maintain the validity of a certificate 
for an organisation which is already certified. Schemes may include requirements that ensure 

76 Certification language uses the word “conformance” rather than “compliance”, which is associated with th e  e n f orce me nt  o f  
regulations. See Sullivan, J. 2014. Conformity vs. compliance.  
Available at: https://www.certificationkitbag.com/blog/2014/3/5/conformity-vs-compliance  

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that the certification decision process is well defined and that the decision on certification is 
conducted by positions/bodies that are separate to the auditor, and impartial to the auditee. 

As a result, different rules may be set up to determine on which grounds decisions are made, 
upon the process (who has the authority to make certification decisions), and how this is 
communicated to the (applicant) certificate holder.  

According to the scheme, minor non-conformances may or may not impede the delivering or 
continued validity of a certificate and have a longer deadline to be corrected, whilst major 
non-conformances will normally prevent the issuing of a certificate or can lead to a certificate 
suspension if they are not corrected by a certificate holder within their shorter timeline.  

8.1. Certificate validity 

Forest  management,  COC  certificates  –  and,  for  some  schemes,  due  diligence  system 
certificates – may be awarded by the Scheme. These usually have a fixed period of validity, 
after which the certificate needs to be renewed. A 5-year period of validity is very common 
for forest-related certification schemes.  

This  does  not  mean  that  checks  are  not  conducted  during  the  period  of  validity:  most 
schemes require annual, or at least regular, surveillance audits. These are normally less 
intensive than certification main assessments or re-certification audits (conducted at the end 
of the validity period). However, it is important to keep in mind that surveillance audits can 
still  lead  to  the  suspension  of  a  certificate,  which  is  why  public-facing official databases 
detailing certificate validity and scope are a very important element of scheme transparency 
and robustness. It is important that these databases are maintained up to date on an ongoing 
basis.  Some  schemes  do  not  have  an  online  database  but  may  be  reached to check a 
certificate validity. 

If the certificate is not renewed after the validity period, the entity involved will no longer be 
permitted to sell products as certified – or to make other certification-related claims - to other 
businesses or consumers. Equally, an entity engaged in a certification process is usually not 
permitted to sell products as certified, or to make any certification -related claims before the 
actual date of issuance of the certificate. 

2.1 Claims  and communication  of certified status 

Sustainable  forest  management  certification  schemes  usually  allow  consumer  or  buyer -
oriented claims to be made in relation to products covered by a certificate scope. However, 
for some schemes or types of products, claims may be restricted to business-to-business 
trade  only  (e.g.  “FSC  Controlled  wood”  claim  within  the  FSC  system,  or  “LegalSource 
certified” claim within the NEPCon LegalSource certification) rather than extending to end -
consumers.  Claims  may  be  permitted  ‘on-product’  in  the  form  of  labels,  in  the  case  of 
sustainable  forest  management  certification  schemes,  however  these  are  not  usually 
permitted for certification schemes limited to timber-legality only. 

With the increase in complexity of forest-related certification schemes, there is a substantial 
number of different claims which can be made. These normally provide information on the 

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inputs  present  in  the  wood-product  and/or  the  method  of  segregation  or  mass-balance 
system  used  within  the  supply  chain.  While  it  is  not  within  the  purview  of  this  report  to 
elaborate  on  each  single  claim of all forest-related schemes, some main claim types are 
mentioned below:  

  A  “100%”  claim  usually  means  either that (1) all the timber in the product can be 
linked to a certified forest (FSC and PEFC) or that (2) a mass-balance calculation has 
been  used  and  an  equivalent  volume  of  timber  has  been  sourced  from  certified 
forests (PEFC). 

  A “Mix” or “XX%”  claim usually means that: 

o 

o  a part of the product is deriving from certified forests, whilst; 
o 

the  remainder  of  the  product  comprises  virgin  material  deriving from non -
certified forests or reclaimed material. The non-certified virgin material may 
have been subject to a due diligence system implemented by a certified entity 
within the supply chain  – or other controls – to avoid controversial sources 
such as illegally harvested timber entering production. 
“XX%”  and  “Credit”  (FSC)  claims  can  be  used  to  distinguish  between  the 
technical methods of calculating and attributing claims to products. 
  a “recycled” claim usually means that all, or a majority part, of the timber derives from 
reclaimed  sources.  Schemes  differ  on  both  the  definitions  of  reclaimed  material, 
including  post  and  pre-consumer  reclaimed  definitions  (this  is  relevant  to  the 
definition  of  reclaimed  material  as  described  in the EUTR). Additionally, schemes 
differ  regarding  the  level  of  information  made  available  to  interested  parties,  in 
relation to nature of the reclaimed material. 

8.2. Trademark use 

Schemes usually develop specific graphic requirements and other rules for the use of their 
trademarks,  logos,  and  other  distinctive  features.  This  applies  both  to  claims  made  on 
certified timber products (“off-product” claims such as those appearing on sales documents 
or other product-related information, as well as on-product/labelling requirements) in addition 
to claims regarding the organisation’s certified status. 

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9. Management of Certification Bodies 

An important element of a certification scheme is the safeguards systems and procedures 
set up to uphold the credibility of the oversight of Certificate Holders. 

1.1 Accreditation and Oversight 

The requirements placed on certification bodies through what is called accreditation, is the 
process of evaluating and approving certification bodies to function u nder the Scheme rules. 
Indeed, the goals of providing robust and objective assessments implies consistency over 
time, locations and between certification bodies (two similar situations shall be assessed the 
same  way  –  with similar audit conclusions reached – independently of the time, location, 
auditor, or certification body in question).  

Many  approaches  for  calibration,  guidance,  or  interpretation,  have  been  employed  by 
certification schemes to prevent or correct threats to credibility and objectivity – often in line 
with  ISO  or  ISEAL  guidelines.  The  ISEAL  Code  of  good  practice 77  provides  a  detailed 
normative framework to support “standards systems to measure and improve the results of 
their work and to ensure that standards are delivering the desired impac t”. 

Even where a certification scheme does not accredit independent certification bodies (such 
as where the scheme owner is also the auditing organisation, as in the case of many timber -
legality certification schemes) an oversight system will be applied to  ensure the continued 
competence and performance of certification auditors to conduct conformity assessments to 
a particular standard (in short, measures to monitor the integrity of the audit process).  

Mechanisms in place may concern both internal and external controls applied to auditors. 
These may include (to greater or lesser extents) the regular review of the performance of 
auditors and certification bodies through, for instance, regularly evaluating the performance 
of auditors conducting audits of certificate holders. Such audits may be conducted both by a 
designated person within the certification body as part of an internal quality control measure 
and/or by an external party such as the accreditation body. 

2.1 Impartiality and conflicts of interests (COI) 

Schemes  usually  include some requirements to ensure that certification bodies and their 
auditors - including other personnel relevant to the conformance evaluation of organisations - 
are impartial to the entities under evaluation. 

Conflicts  of  interests  may arise for example when an auditor, report reviewer or decision 
maker within a certification body has private or personal interests which risk influencing the 

77 ISEAL Assuring Compliance with Social and Environmental Standards 

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objectivity  of  the  audit  process.  This  can  happen  if the auditor has a specific link to the 
(applicant) certificate holder: family of friendship links, business connections, etc.  

On the other hand, risk of impartiality can occur if the auditor has previously conducted work 
on the behalf of the organisation, such as in setting up the procedures an d system he/she is 
tasked with assessing or has provided consultancy on topics connected to the certificate -
holders systems and procedures. Previous consultancy services to an (applicant) certificate 
holder should always be disclosed.  

Risks to impartiality and conflicts of interest can be prevented and monitored in various ways:  

  schemes can require certification bodies to set up systems, procedures and records 
dedicated to the detection and prevention of risk to impartiality and COI – this can be 
achieved with systematic disclosure of (real or perceived) COI by certification body 
staff members prior to composing audit teams, a good management of data on COI, 
etc.  

  mechanisms such as composing teams with several auditors, auditor rotation or even 

certification body rotation may be implemented. 

  clear  mechanisms  can  be  implemented  restricting  and  monitoring  information 
delivered to (applicant) certificate holders by certification bodies (such as training) to 
avoid  actively  engaging in their efforts toward achieving conformity with a specific 
standard. 

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10.  Scheme management 

1.1 Transparency 

Schemes differ in their level of transparency, some aspects of which are extremely important 
to  allowing  operators,  competent  authorities  and  other  organisations  to  evaluate  the 
applicability of the scheme certifications to their due diligence concerns. Examples of where 
transparency is important, include: 

 

 

the  provision  of  information  on  certificate  scope  (forests, manufacturing facilities, 
etc..) and validity via public-facing official databases is very important and useful tool, 
adding to scheme transparency and robustness. It is important that these datab ases 
are maintained up to date on an ongoing basis. Some schemes do not have an online 
database but may be reached to check a certificate validity. However, information in 
relation to gaps in the certified status of certificate holders, may not be availabl e.  
information of relevance to buyers for certified products. This may be important to 
organisations which are also Operators under the EUTR, and includes information on 
species and origin, reclaimed content, etc. in relation to the certified product.  

  ensuring that relevant information about the different aspects of scheme functioning is 
freely available, including scheme normative requirements for certificate holders and 
certification bodies; how the system is governed; which entities are evaluated and 
under  what  process,  as  well  as  impact  information.  This  is  important  to  permit 
evaluation of the value of the scheme in relation to the EUTR. 
  allowing for stakeholder engagement in relation to the scheme. 

Finally, Schemes also differ with regards to the extent to which publicly available summaries 
of  audits  are  made,  with  relevant  conclusions  and  associated  scope  information.  Such 
reports may or may not include related information which is important to organisations which 
are also Operators under the EUTR, such as: non-conformances raised by auditors, risks 
and risk mitigation actions taken within certified due diligence systems, etc.    

2.1 Appeals and complaints 

A  robust  assurance  system  must  also  have  detailed  and  consistently  implemented 
procedures to handle appeals and complaints.  

Appeals  refer  to  the  possibility  for  the  (applicant)  certificate  holder  to  obtain  the 
reconsideration  of  a  certification decision taken by the certification body. This can cover 
mechanisms internal to the certification body, or externally, such as where a procedure exists 
to raise an appeal to the accreditation body or the scheme owner. Those mechanisms can 
define  deadlines  for  addressing  the  appeal, responsible authorities, transparency of the 
process, etc. 

Complaint’s  procedures  refer  to  permitting  the  expression  of  dissatisfaction  over  the 
functioning of a scheme, scheme-related entity (certification body, accreditation body…) or 
scheme  participant  (certificate  holder).  The option of raising complaints should be made 

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available to any stakeholder (person or organisation) in regard to the activities of any of the 
entities involved within a certification scheme. Specific procedures can be defined to handle 
complaints; “To be credible, a certification scheme must have a complaints mecha nism to 
allow it to address complaints and rectify mistakes made during certification or accreditation 
procedures.  Ideally,  an  independent  dispute  panel  or  similar  body  should  deal  with 
complaints” (FERN, 2001). 

3.1 Standard setting 

Schemes differ in their approaches to standard setting, as well as in the level of transparency 
which comprises the standard-setting process. Furthermore, schemes vary widely in the level 
to which stakeholders can influence, participate in, or support the standing setting process.  

Likewise,  where  applicable  and  according  to  individual  Schemes,  they  may  differ  in  the 
extent to which international standards are used as a starting point to be adapted to national 
or  subnational  contexts  in  which  they  are  being  implemented  (e.g.,  FSC  sch eme),  or 
conversely, used as a benchmark to review and approve existing national standards (e.g., 
PEFC scheme). 

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11.  Certification schemes and the EUTR 

Despite  their  similarities,  each  certification  scheme  encompasses  a  different  system  of 
requirements  and  –  to  differing  degrees  –  covers  a  different  scope  of  legal,  social and 
environmental criteria. Additionally, each scheme comprises different levels of transparency, 
different rules and procedures as well as different quality assurance requirements. These 
can lead to substantially different approaches to ensuring conformance among organisations 
which participate (certify) in the scheme. 

In  the  following  sections,  it  is  discussed  how  certification  schemes  may  be  used  as  a 
component  of  the  due  diligence  system  applied  by  Operators  to  meet  the  EUTR 
requirements. 

1.1 EUTR  requirements 

The EUTR includes provisions to recognise third party verification to mitigate risks in supply 
chains.  The  Implementing  Regulation  607/2012  details  four  conditions  necessary  for 
certification  schemes  to  be  considered  when  implementing  risk  assessment  and  risk 
mitigation,78 namely that the scheme in question has: 

  A  publicly  available  system  of  requirements  (standards)  including  at  least  all 

requirements of the applicable legislation. 

  A third-party regularly conducting appropriate checks including field-visits (12 months 

interval maximum). 

  Means  to  trace  timber  harvested and derived products at any point of the supply 

chain before it is placed on the EU market. 

  Controls to ensure that products/materials along the supply chain are not mixed with 
products  of  unknown  origin  or  timber  harvested  in  contravention  of  applicable 
legislation.  

The EUTR Guidance document further details “the role of third-party-verification schemes in 
risk assessment and risk mitigation”.79 It requires that in order to “make use of a certification 
scheme or legality verification as assurance that the timber in a product had been legally 
harvested”, operators must:  

  have  knowledge  of  the  scheme  being  used,  including  its  coverage  of  applicable 

legislation. 

  have  knowledge  of  the  practical  implementation  of  the  scheme  in  the  country  of 
harvest  of  the  timber.  In  other  words,  be  aware  of  substantiated  reports  about 
possible  shortcomings  or  problems  of  the  third-party  schemes  in  the  specific 
countries from which the timber or timber products are imported.  

78 Art. 4, Implementing Regulation (EU) No 607/2012. 

79 For the exact EUTR language on certification, see Appendix 1. 

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  have confidence that appropriate checks are conducted on the portion of material 

potentially coming from non-certified forests and allowed into the timber mix. 

  be satisfied that the third-party organisation that issued a certificate was sufficiently 
qualified  and  is  in  good  standing  with  the  certification  scheme  and  the  relevant 
accreditation body. 

  have knowledge on the robustness of chain of custody requirements and checks s o 

that only permitted material enters the supply chain. 

  have strong confidence in the credibility of the scheme, ensuring the frequency of 
audits, identifying whether an independent organisation is performing checks on the 
certification  body,  or  even  checking  compliance  with  international  or  European 
standards  on  certification  schemes  and  auditing  (ISO  and  ISEAL guidance being 
cited as examples). 

These points form the basis for evaluating schemes in relation to the EUTR and with the 
discussion in the next section regarding factors that can affect scheme performance and 
credibility. 

2.1 Assessing  certification schemes 

Whilst each scheme includes different requirements, procedures, and assurance systems, 
each will need to be evaluated by the Operator within the EUTR’s mandated due diligence 
requirements, to determine its value as an indicator of low risk. It is important for the operator 
to ensure that the scheme is able to provide a sufficient level of risk mitigation as desired, in 
cases where risks of legal non-compliance may exist. 

11.2. Comparing forest-related schemes against the EUTR 

Whether related to certification schemes’ standards and requirements, or to the schemes’ 
institutional and procedural arrangements, the following elements should be considered for 
evaluation to understand the strengths and potential limitation of those schemes, in view of 
their use by Operators to comply with EUTR requirements:  

1.  Scheme normative requirements and the definition of legality 

Normative requirements in general – and for specific standards – should be well formulated 
and organised, sufficiently clear to allow for consistent interpretation, and implemented in 
sufficiently rigorous way to provide strong assurance on systems and performances.  

Forest-related  schemes  usually  include  requirements  on  the  legal  compliance  of  forest 
management units with applicable legislation, thereby defining boundaries of what legal rules 
are considered by the Scheme. This may vary amongst schemes.  

The EUTR has its own definition of forest-related applicable, including national legislation 
and international conventions. It is therefore important to determine if/where schemes differ 
from this definition: some schemes might go beyond the EUTR definitio n, which does not 
create any issue, whilst other schemes may fall short of aligning with this definition, in which 

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case it is important to determine where exactly the gaps exist (i.e. where a scheme does not 
include, as relevant, an area of legislation that the EUTR does include as applicable, and 
therefore relevant).  

Requirements  to ensure supply-chain legality have, to some extent, been included within 
certification  schemes  as later additions to standard requirements, which have historically 
focussed on demonstrating forest-level performance. It is important to determine if they are 
as robustly addressed and monitored compared to forest-level legality risks. 

It may be necessary to assess the extent to which schemes are vulnerable to different types 
of corruption which may impact the forest sector, particularly bribery. Corruption is probably 
extremely difficult for private certification schemes to avoid or address in any meaningful way 
and perhaps only indirectly. However, risks of corruption are specifica lly mentioned by the 
EUTR as a crucial risk factor to illegality.  

2.  Alignment with other EUTR definitions 

Besides  requirements  on  the  legal  compliance  of  forest  management  units,  a  few other 
concepts may be tackled differently between a certification scheme and the EUTR and have 
an impact as to how the scheme can be used to comply with the EUTR. These concerns, 
among other things:  

  due  diligence  systems:  where  due  diligence  requirements  are  used  within  a 
certification scheme, it is one thing to ensure that the “applicable legislation” is similar 
between the scheme and the EUTR, but it is also crucial to ensure that the required 
elements of due diligence are robust enough to bring confidence that there is indeed 
a  low  risk  of  legislation  not  being  complied  with.  This  is  applicable  both:  i)  for 
standalone  due  diligence  standards  and,  ii)  where  mixing  of  certified  material  is 
permitted  with  non-certified  (“controlled”)  material.  In  such  systems,  there  is  a 
potential for weaknesses to exist in relation to the non-certified (controlled) material to 
some extent, with a weaker level of control applied by the certification schemes to 
ensuring  legal  compliance by operators, or less robust monitoring by the certified 
organisations and/or certification bodies. 
reclaimed  material:  the  EUTR  exempts post-consumer recycled timber and timber 
products, mainly based on whether the recycled material has completed its lifecycle 
or  not.80  Forest-related  certification schemes might include a different definition of 
reclaimed material (leading to recycled claims on certified products). Indeed, many 
schemes are aware of the tension that exists between encouraging the re -utilisation 

 

80  Recital  (11)  of  Regulation  (EU)  No  995/2010  states  that  “[b]bearing  in  mind  that the use of recycled timber and timber 
products should be encouraged, and that including such products in the scope of this Regulation would place a disproportionat e 
burden on operators, used timber and timber products that have completed their lifecycle, and  would otherwise be dispo sed  o f  
as waste, should be excluded from the scope of this Regulation”. More details are provided by the Commission Notice C(2 0 1 6) 
755 – Guidance document for the EUTR – Part 5B and the Guidance document on Recycled timber and timb er products by t h e  
Expert Group on the EU Timber Regulation and the Forest Law Enforcement, Governance and Trade (FLEGT) Regulation. 

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of material that would otherwise have been discarded and the concern that this option 
can be misused to  lower conditions applying to some material, for by-products and 
scraps of the timber industry. This and the highly complex and technical nature of 
some  industries  using  reclaimed  materials  has  led  many  certification  schemes to 
develop  clear  requirements  on  the  subject,  starting  with  as  clear  a  definition  as 
possible of pre-consumer and post-consumer reclaimed material.  

3.  Chain of custody systems 

Certification schemes need to contain robust chain of custody (COC) requirements. T his is 
essential  for  the  schemes  in  linking  a  specific  timber  product  to  a  certified  entity.  COC 
systems provide the confidence that a product is within the certification scope of the entity 
harvesting the timber (or subjecting wood material to due diligence procedures) and that no 
contamination of such material is occurring with other timber products throughout the supply 
chain.  

In  theory,  all  schemes  may  suffer  from  a  risk  of  accidental  errors,  miscalculations,  or 
mistakes in relation to certified claims, as well as potentially delib erate mis-implementation of 
standard requirements. In recognition of this issue, many schemes are engaged in ongoing 
efforts to ensure robust transaction verification systems are in place, with interest increasing 
in the use of transaction verification, cloud databases, IT platforms and other technologies.  

4.  Claims on timber products 

It  is  important  to  understand  the  meaning  of  different  claims which are possible within a 
scheme, as each may hold different weight and have different levels of meaning in re lation to 
the EUTR. 

In the same vein, as the point above, all schemes are subject to accidental or intended false 
claims  –  whether  through  mislabelling  or  via  sales  claims  on  invoice  and  transport 
documents. Schemes may have more of less efficient ways of controlling such deliberate or 
accidental false claims.  

Conversely,  mistakes  can  be  made  by  the  entity  purchasing  the  certified  products,  for 
example by relying on the active certificate of their supplier without actively ensuring that 
timber products traded are also linked to the certification system in place. 81 

5.  Scheme assurance systems 

Schemes  must  have  sufficiently  robust  quality  assurance systems to ensure certification 
bodies and/or certificate-holders’ conformance with standards requirements in all contexts.  

81 See Appendix 4 for an overview of the process of validating certification claims (FSC and PEFC).  

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Assurance systems should include an oversight mechanism, which is robustly implemented 
(sufficient  processes  are  in  place  to  review  the  performance of CBs and their auditors). 
Where schemes may not have sufficient systems in place to address risks to impartiality and 
conflict of interest, this may not allow for rigorous independent certification decision-making, 
and therefore be detrimental to the credibility of the Scheme.  

The challenges of corruption and bribery within the countries within which a scheme operates 
may place added pressure, and increase risks, in relation to a  scheme’s ability to meet its 
own objectives and ensure there is trust in scheme certification claims. An important element 
is  therefore  ensuring  the  scheme  seeks  to  address  in  robust  ways  the  risk  that  official 
documents related to the awarding of permissions and licenses such as concession rights, 
harvesting permits and transportation of wood products, etc. are not issued based on bribery 
or  corrupt  practices.  They  should  also  be  free of potential disputes and complaints, nor 
conflict of interest between auditors and certificate holders which may bring into question 
their validity. 

6.  Scheme transparency  

Transparency is an important element as regards scheme credibility. Of course, a scheme’s 
applicable  standard(s)  and  requirements  must be publicly available , otherwise this could 
impede  the  use  of  the  scheme  by  the  Operator,  by  preventing  comparison  with  other 
schemes and with regulatory requirements (such as the EUTR).  

Transparency issues include whether public certificate databases are updated in real time  
but  extend  far  beyond this to the many other aspects of certification schemes which can 
affect a schemes’ utility and the trust it generates among users and stakeholders.  

Institutional and procedural arrangements of forest-related certification schemes s hould be 
clear  and  transparent,  for  instance  as  regards  the  scheme  owner,  the  decision -making 
structures,  the  use  an  independent  accreditation  body  and  the existence of certification 
bodies.  

Additionally,  clarity  on  the  following  elements  may be important: elements of a scheme’s 
procedural set-up for auditing, such as the assessment process and certification decision 
making methodology; the management of non-conformances; oversight mechanisms and the 
management of disputes and complaints, and their resolution.  

Finally,  transparency  in  relation  to  audit  findings  is  important  (and  a  key  differentiator 
between certification schemes). The provision of summary reports of certification audits can 
be valuable to providing key EUTR-relevant information regarding the performance of the 
certified organisation and the scope of activity under evaluation.    

7.  Stakeholders 

As a sub-component of transparency, it is generally agreed that stakeholder engagement 
has the potential to increase the robustness and credibility of a certification scheme. Some 
schemes  allow  stakeholders  to  participate  in  the  development  and  interpretation  of 
standards.  Others  require  that  stakeholders  be  consulted  during  audits  where  they  are 
affected or may be an interested party. 

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3.1 Understanding  certificates 

Often the first information available to an operator about a certified product, is a copy of the 
certificate itself – or a link to the publicly-available online certificate database. In order for the 
certification to be understood in relation to the underlying attributes of the scheme to which it 
belongs,  a  number  of  questions  could  be  asked.  These  questions  can  help  to  further 
investigate and understand relevant aspects of the certified product or material in question.  

Different  certification  schemes  will  have  different  formats  in  relation  to  their  formal 
“certificates” – meaning the statement to express the conformance level of the certificate 
holder. There is variation in what information can be extracted from certificates. Following are 
some key aspects of a certificate that should be available for consideration: 

  Certificate holder legal name 
  Main address – including addresses of additional locations or installations included 

within the scope of the certificate. 

  Certificate number or code: unique code that identifies an organisation as certified 

under the Scheme. 

  Scheme standards (or type of certification) to which the Certificate Holder is certified.  
  Forest areas covered by certification. 
  Product scope, including for each product:  

o 
o 
o 

i) product type, description or classification;  
ii) species from which it is comprised;  
iii) output category or scheme claim (if applicable) 

See Annex 4 for guidance on how to validate certification claims. 

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EUTR  regulations  and  guidance  on  using  certification 
schemes 

REGULATION  (EU)  No  995/2010  OF  THE  EUROPEAN  PARLIAMENT  AND  OF  THE 
COUNCIL  

of 20 October 2010  

laying down the obligations of operators who place timber and timber products on the market  

[…] 

(19) In order to recognise good practice in the forestry sector, certification or other third party 
verified schemes that include verification of compliance with applicable legislation may be 
used in the risk assessment procedure. 

[…] 

Article 6  

Due diligence systems  

1. The due diligence system referred to in Article 4(2) shall contain the following elements: 

[…] 

(b) risk assessment procedures enabling the operator to analyse and evaluate the risk of 
illegally harvested timber or timber products derived from such timber being placed on the 
market.  

Such procedures shall consider […] relevant risk assessment criteria, including:  

—  assurance  of  compliance with applicable legislation, which may include certification or 
other third-party- verified schemes which cover compliance with applicable legislation, 

[…] 

COMMISSION IMPLEMENTING REGULATION (EU) No 607/2012  

of 6 July 2012  

on the detailed rules concerning the due diligence system and the frequency and nature of 
the checks on monitoring organisations as provided for in Regulation (EU) No 995/2010 of 
the European Parliament and of the Council laying down the obligations of operators who 
place timber and timber products on the market 

[…] 

Article 4  

Risk assessment and mitigation  

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Certification or other third-party verified schemes referred to in the first indent of the second 
paragraph of Article 6(1)(b) and in Article 6(1)(c) of Regulation (EU) No 995/2010 may be 
taken into account in the risk assessment and risk mitigation proced ures where they meet 
the following criteria:  

(a) they have established and made available for third-party use a publicly available system 
of  requirements,  which  system  shall  at  the  least  include all relevant requirements of the 
applicable legislation;  

(b) they specify that appropriate checks, including field-visits, are made by a third party at 
regular intervals no longer than 12 months to verify that the applicable legislation is complied 
with;  

(c) they include means, verified by a third party, to trace timber harvested in accordance with 
applicable  legislation,  and  timber  products  derived  from  such  timber, at any point in the 
supply chain before such timber or timber products are placed on the market;  

(d) they include controls, verified by a third party, to ensure that timber or timber products of 
unknown origin, or timber or timber products which have not been harvested in accordance 
with applicable legislation, do not enter the supply chain. 

[…]  

COMMISSION NOTICE C(2016)-755 

of 12.2.2016  

GUIDANCE DOCUMENT FOR THE EU TIMBER REGULATION 

6.  THE  ROLE  OF  THIRD-PARTY-VERIFICATION  SCHEMES IN RISK ASSESSMENT AND 
RISK MITIGATION 

[…] 

A. Background information  

Voluntary forest certification and timber legality verification schemes are often used to meet 
specific customer requirements for timber products. Typically, these include a standard that 
describes management practices that must be implemented within a forest management unit, 
comprising: broad principles, criteria and indicators; requirements for checkin g compliance 
with the standard and awarding certificates; and separate chain -of-custody certification to 
provide assurance along the supply chain that a product only contains timber, or a specified 
percentage of timber, from certified forests.  

When  an  organisation  that  is  not  the  forest  manager,  manufacturer  or  trader,  nor  the 
customer requiring certification, carries out an assessment and awards a certificate, this is 
known as third-party certification. 

Certification schemes generally require third-party organisations to be able to demonstrate 
their  qualifications  to  perform  assessments  through  a  process  of  accreditation that sets 
standards for the skills of auditors and the systems that the certification organisations must 
adhere to. The International Organisation for Standardisation (ISO) has published standards 

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covering both requirements for certification bodies and assessment practices. Proprietary 
timber  legality  verification  schemes,  though  often  provided  by  organisations  that  offer 
accredited certification services, generally do not require accreditation themselves.  

A  requirement  for  compliance  with  legislation  governing  the  management  of  the  forest 
management unit is generally part of forest management certification standards. Systems 
management  standards,  such  as  those  for  environmental  management  or  quality 
management,  generally  do  not  include  such  a  requirement,  or  the  latter  might  not  be 
rigorously checked in assessment.  

B. Guidance  

In  considering  whether  to  make  use  of  a  certification  scheme  o r  legality  verification  as 
assurance  that  the  timber  in  a  product  had  been  legally  harvested,  an  operator  must 
determine  whether  the  scheme  incorporates  a  standard  that  includes  all  the  applicable 
legislation. This requires some knowledge of the scheme the operator is using and how it is 
applied in the country where the timber was harvested.  

Certified products generally carry a label with the name of the certification organisation that 
has set the criteria for the certificate and has set the requirements f or the auditing process. 
Such  organisations  will  normally  be  able  to  provide  information  on  coverage  of  the 
certification and how it was applied in the country where the timber was harvested, including 
such details as the nature and frequency of field audits.  

The operator should be satisfied that the third-party organisation that issued a certificate was 
sufficiently qualified and is in good standing with the certification scheme and the relevant 
accreditation body.  

Information about how schemes are regulated can usually be obtained from the certification 
scheme. Some schemes allow certification when a specified percentage of the timber in a 
product has met the full certification standard. This percentage is usually stated on the label. 
In such cases, it is important that the operator obtains information about whether checks on 
the non-certified portion have been performed and whether those checks provide adequate 
evidence of compliance with the applicable legislation.  

Chain-of-custody certification may be used as evidence that no unknown or non-permitted 
timber enters a supply chain. These are generally based on ensuring that only permitted 
timber is allowed to enter the supply chain at ‘critical control points’, and a product can be 
traced to its previous custodian (who must also hold chain-of-custody certification) rather 
than back to the forest where it was harvested. A product with chain -of-custody certification 
may contain a mix of certified and other permitted material from a variety of sources. When 
using chain-of-custody certification as evidence of legality, an operator should ensure that 
permitted  material  complies  with  applicable  legislation  and  that  controls  are  sufficient to 
exclude other material.  

It is important to note that an organisation may hold chain-of-custody certification as long as 
it  has  systems  in  place  to  segregate  certified,  and the allowed percentage of, permitted 
material and non-permitted material, even if it is not producing any certified product at that 
time. When operators rely on certification as assurance and purchase from suppliers with 
chain-of-custody certification, they must check that the chain of custody certification covers 
the specific product they are purchasing.  

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In the process of assessing the credibility of a third-party-verification scheme, operators may 
use the following questions (note that the list is not exhaustive):  

  Are all requirements under Article 4 of the Commission implementing Regulation (EU) 

No 607/2012 fulfilled?  

  Is the certification or other third-party-verification scheme compliant with international 

or European standards (e.g. the relevant ISO-guides or ISEAL codes)?  

  Are there substantiated reports about possible shortcomings or problems of the third -
party-verification schemes in the specific countries from which the timber or timber 
products are imported?  

  Are the third parties that perform the checks and verifications referred to under Article 
4  (b)(c)  and  (d)  of  the  Commission  implementing  Regulation  (EU)  No  607/2012 
independent accredited organisations? 

[…] 

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Summary 
schemes 

table  –  categorisation  of 

forest-related 

See accompanying Excel: Relevant certification and verification schemes 

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Glossary of terms 

  Accreditation 
  Oversight 

Assessment of a certification body’s provider’s demonstration of 
competence to carry out specific assurance tasks. 

  Assessment 
  Main evaluation 
  Initial  audit 
  Full  system audit 
  Certification Audit   

  Annual  audit  
  Surveillance audit 
  Audit 

  Active 
 
Issued  
  Valid 

  Pre-assessment 
  Pre-evaluation 
  Scoping 
  Pre-audit 
  Gap analysis 

  Certification 
  Verification 
  Registration 

These terms often refer to the first full scale evaluation performed 
for a company who desires to be certified/ verified. In ISO 
documents the term audit is used for both first and subsequent 
audits with the most common terms being initial  audit or 
certification audit. Full  system audit is used primarily for 
management systems auditing and consists of Stage 1 audit 
(document review and initial  review), which can be replaced by pre-
assessment (see below); and Stage 2 audit which is an on-site audit 
of full management system implementation. 

These terms often refer to repeatedly conducted evaluations to 
monitor continuous conformance of the auditee to the requirements. 
NEPCon uses the term ‘annual audit’ for annual surveillance audits.  

These terms define the status of a certification. 

Sometimes (in case of larger or more complex auditees), assessors 
perform an initial  short and general evaluation to identify the main 
shortcomings that can potentially result in a negative 
recommendation after the main evaluation. 

The term is used a bit differently in different situations; however it 
generally  refers to the whole process of granting a certificate/ 
verification statement by an independent third-party assessor. The 
process starts formally with an application and ends after the 
certification/ verification decision has been made and certificate/ 
verification statement has been issued. In the broader context, 

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annual surveillance activities are part of the certification/ 
verification process. 

A certification body is an independent, impartial  and competent 
legal  entity that carries out certification auditing. Although it is not 
always a requirement that the assessor be accredited, professional 
certification bodies are usually  considered to be those who have 
gained accreditation for the auditing services they offer. 

Although these terms are sometimes used interchangeably, they are 
not necessarily synonyms. Applicant refers to a company that has 
applied  for certification but has not yet received it. An audit client 
may request an audit; the auditee is the organisation being audited. 
In some cases, these can be different (e.g., a company ordering an 
audit for its supplier). With auditing services, the general term 
client seems to be the most widely used term. 

In the COC certification, the certificate is often issued to the 
organisation that has direct management responsibility for the 
Chain of Custody system under its control. 

In FM certification, the certificate is often issued to the organisation 
that has ownership or management control over the applicable 
forest management units.  

These terms refer to documented requirements that must be fulfilled 
by the auditee  in order to receive a certificate. Audit criteria is the 
definitive,  formal common ISO term for any set of requirements 
against which the auditee is audited. Standard is a term used more 
commonly in everyday language. 

  Certification body (CB) 
  Conformity assessment 

body (CAB) 

  Certifier 
  Assessor 
  Assurance provider 
  Third-party auditor 

  Client 
  Certified client 
  Applicant 
  Audit  Client 
  Certificate holder 
  Auditee 
  Supplier (in product 
certification) 
  Organisation 
  Company 

  Standard 
  Audit  criteria 
  Requirements 
  Certification requirements 
  Normative document 
  Norm 
  Checklist 

  Non-conformance 
  Non-conformity 
  Non-compliance 

These terms refer to non-fulfilment of a requirement. In simpler 
terms this means that some part of the standard has not been 
correctly fulfilled. Nonconformity is the definitive  term in ISO 
documents. Similar options are used for positive fulfilment of 

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ANNEX 1 : FOREST-RELATED CERTIFICATION SCHEMES – AN OVERVIEW 

requirements (conformance, conformity, compliance). Compliance 
is most often used as reference to legal requirement, whereas 
conformance is referring to voluntary requirements. 

  NCR (non-conformity 

report) 

  CAR  (corrective action 

request) 

These two terms are commonly used by various auditing systems to 
describe the documentation of non-conformances.  

  Suspension 

  Termination 

  Certification 

  Certification Scheme 

  Competent authority 

Suspension refers to the temporary ceasing of a certification 
validity.  A suspension may occur under specific situations, such as 
where a certificate holder fails to meet certification requirements as 
part of an annual audit or to meet certification requirements detailed 
in a certification agreement. 

Termination refers to the definitive end of a certification. A 
termination may occur prior to the end of the certification period 
(i.e., prior to the expiration date). 

This is the process whereby an independent third-party (called a 
certifier or certification body) assesses the quality of forest 
management in relation to a set of predetermined requirements (the 
standard). The certifier gives written assurance that a product or 
process conforms to the requirements specified in the standard 

3rd party scheme providing assurance of conformance to a 
normative standard. 

The organisation determines the objectives and scope of the 
certification system and applicable standards, as well as the rules 
for how the System will operate and the standards against which 
conformance will be assessed. In most cases this is the standard-
setting organisation, but it may also act as a Certification body.  

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  Complaint 

  Forest Management 

Enterprise (FME) 

Organisation, company, or operation responsible for forest 
management 

  Forest Management Unit 

A spatial area or areas submitted for certification with clearly 
defined boundaries managed to a set of explicit long term 
management objectives which are expressed  in a management plan 

  Species 

  Supply chain 

A group of living organisms consisting of similar individuals 
capable of exchanging genes or interbreeding. The species is the 
principal natural taxonomic unit, ranking below a genus. 

The route of forest products and entities that take legal ownership 
of the forest products from the forest – where the material is 
harvested – to the Organisation that takes final ownership of the 
material 

  Due Diligence  System 

(DDS) 

A set of steps or actions taken to ensure that due diligence is 
exercised. The due diligence system may consist of written 
guidelines and procedures that describe the due diligence process 
in detail. 

  Publicly available 

Obtainable by any person, without unreasonable barriers  of access 

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How to validate certification claims (FSC and PEFC) 

This  procedure  outlines  how  the  validity  and  scope  of  the  supplier’s  certifica te  and 
certification claims can be verified, via FSC and PEFC databases.  

1. FSC Certificate Checks 

For FSC certified supply chains, verify the validity and scope of the supplier’s certificate and 
ensure that certification claims are provided for purchased goods.  

1.1. Verify supplier’s certificate validity & scope   

  Go to the FSC online database: info.fsc.org     
  Click “Certificate search” 

Figure 1: FSC Public Search 

  Search for your supplier by:   
  Supplier’s name (i.e. name of the legal entity declared by the supplier); or  
  Supplier’s FSC certificate code (which can be found on the supplier’s FSC certificate, 

FSC invoice or transport documentation  

NOTE:  Each  FSC-certified  company  has  a  unique  code  that  identifies  them  as  an  FSC 
certificate holder, e.g. TP Toys has the code NC-COC-014367 

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Figure 2: Searching by Name or Code 

  Click ”search”. 
  Click on the link to your supplier (which appears after you have  clicked ”search”). 

Figure 3: Certificate Results 

  Verify that the ‘Certificate code’ on the FSC online database (see Figure 4) matches 
the  suppliers  FSC  certificate,  invoice  or  transport 

the  code  provided  on 
documentation. 

 

Figure 4: Checking the certificate code  

Figure 5: Checking certificate validity 

  Check the certificate is ‘Valid’ and check the ‘Expiry date’.  
  Verify that the product scope shown on the FSC database matches the information 
on the supplier’s invoice, delivery note, including: i) Product type; ii) Species; iii) Main 
output category (i.e. FSC claim); iv) Address of certified site. 

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ANNEX 1 : FOREST-RELATED CERTIFICATION SCHEMES – AN OVERVIEW 

Figure 6: Checking product scope 

1.2. Validate sales and delivery documentation  

Verify that the supplier’s invoice and delivery note, includes all relevant information – see 
below. Verify that items with an asterisk mirror the information as it appears on the online 
FSC database: 

  Name and address of the supplier* 
  FSC COC certificate code* 
  Main output category (FSC certification claim)*  
  Product code & Description of the product 
  Claim period or invoice numbers to which the FSC declaration applies.  

1.3. Check certified forests exist in country/region of harvest  

For all FSC certified supply chains, if the forest management unit is identified by th e supplier, 
the certificate validity can also be checked, and it is possible to check whether the species 
included  within  the  product  is  included  within  the  scope  of  the  forest  management  unit 
certification.   

2. PEFC Certificate Checks 

For PEFC certified supply chains verify the validity and scope of the supplier’s certificate and 
ensure that certification claims are provided for purchased goods. 

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ANNEX 1 : FOREST-RELATED CERTIFICATION SCHEMES – AN OVERVIEW 

2.1. Verify supplier’s certificate validity & scope   

Frequency: The following checks shall be conducted annually, at a minimum. 

  Go to the PEFC online database: www.pefc.org/find-certified/certified-certificates    
  Click “Advanced search” (Figure 7) 
  Find the supplier by searching for: 

• 
• 

Supplier’s name (i.e. name of the legal entity declared by the supplier)  
the  supplier’s  PEFC  certificate  number  (which  can  be  found  on  the 
supplier’s PEFC certificate, invoice or transport documentation) 

  Click “search” 
  Click on “more info” against the correct supplier certificate (Figure 8). 

Figure 7: PEFC certificate search 

The information checks provided for PEFC and FSC certificates on the online databases are 
similar and validity and scope checks can be conducted in a similar way. However, the PEFC 
online database does not provide scope information on species of certification claim types. 
Only product type and product trade name is shown. 

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ANNEX 1 : FOREST-RELATED CERTIFICATION SCHEMES – AN OVERVIEW 

Figure 8: Accessing the certificate details 

2.2. Validate sales and delivery documentation  

  The  information  in point 2 is required on the supplier’s PEFC invoice  OR delivery 

note.82 

  The items with an asterisk should mirror the information as it appears in the PEFC 

database: 

a.  Name and address of the supplier* 
b.  PEFC COC certificate code* 
c.  Main output category (PEFC certification claim)*  
d.  Product code & Description of the product 
e.  Claim period or invoice numbers to which the PEFC declaration applies. 

82 PEFC allows the choice of document to which the PEFC-certified claim is made. 

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ANNEX 1 : FOREST-RELATED CERTIFICATION SCHEMES – AN OVERVIEW 

References 

  FERN’s assessment “Behind the logo - An environmental and social assessment of 
at: 

forest 
https://www.fern.org/fileadmin/uploads/fern/Documents/Behind%20the%20logo.pdf   

certification 

schemes” 

Available 

(2001). 

  Purbawiyatna  A.,  Simula  M.  2008.  Developing  forest  certification  –  Towards 
increasing the comparability and acceptance of forest certification systems. In IT T O  - 
Technical Series No 29. 

  Perera, P. and Vlosky R.P. 2006. A History of Forest Certification. In Louisiana Forest 
at: 

Products  Development  Center  Working  Paper 
http://www.lfpdc.lsu.edu/publications/working_papers/wp71.pdf  

#71.  Available 

  Brown, D., Schreckenberg, K., Bird, N., Cerutti, P., Del Gatto, F., Diaw, C., Fo mété, 
T., Luttrell, C., Navarro, G., Oberndorf, R., Thiel, H., Wells, A., 2008. Legal Timber, 
Verification and Governance in the Forest Sector. Overseas Development Institute. 
Available at: https://www.odi.org/sites/odi.org.uk/files/odi-assets/publications-opinion-
files/3472.pdf   

  Sullivan  J.,  May  2008.  Accreditation  –  What  is  it  &  why  bother?  Available  at: 

https://www.certificationkitbag.com/blog/2014/12/3/accrediation-why-bother  

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Annex 2: Certification Scheme Assessment 
Procedure (SAP) 

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Table of Contents 

Introduction ........................................................................................................... 243 

Application of framework...................................................................................... 244 

1. Goal of certification scheme evaluation................................................... 244 

2. Overview of evaluation approach ............................................................ 244 

3. Certification Scheme Assessment Framework ....................................... 245 

4. Template tools .......................................................................................... 246 

5. Scope of assessment ............................................................................... 247 

6. Selection of schemes ............................................................................... 248 

Assessment steps ................................................................................................ 249 

7. Key steps of the Scheme evaluation process ......................................... 249 

Assessment methodology.................................................................................... 251 

8. Assessment methodology – information gathering................................. 252 

9. Assessment methodology – evaluation of coverage .............................. 255 

10. Assessment methodology – coverage conclusions and risk................ 257 

Glossary of Definitions ......................................................................................... 258 

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Introduction 

This document conforms to Activity 2.2 of the project “Study on Certification and Verification 
Schemes  in  the  Forest Sector and for Wood-based Products” and the development of a 
Scheme  Assessment  Procedure  (SAP)  that will act as the methodology and guide to the 
application of the Certification Scheme Assessment Framework (SAF). 

The overall objective  of the Study is to create a resource of knowledge and reference for all 
interested and concerned parties in the forest- and wood-based products sector concerning 
what certification is, the different types of certification and how certificat ion schemes work as 
well  as  a  categorisation  of  the  relevant  forest-  and  wood-based  products  certification 
schemes based on their type, scope, purpose and intended use, including relevant examples  

It should help Competent Authorities, Operators and Monito ring Organisations covered by 
the  EUTR in their understanding of potential benefits, strengths and shortcomings of the 
various  certification  schemes.  As  such,  one part of the overall objectives is to create an 
overview of existing certificates, third-party verified schemes and certifying bodies issuing 
certificates with regard to forests and wood-based products and to evaluate their respective 
strengths  and  weaknesses  in  respect  to  the  EUTR  obligations.  This  should,  in  turn, 
encourage stronger standards and transparency of certification and third part verification 
schemes.  

As part of the above objective, this documented procedure has been developed to guide the 
evaluation of the differences and uniformities between certificates and certifying bodies.  

This  procedure  therefore  details  the  process  for  applying  the  Scheme  Assessment 
Framework when conducting an evaluation of a Certification/Legality Verification scheme. 
This is important to ensuring a uniform approach, so that all scheme assessments are made 
in a consistent, rigorous and systematic way. 

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Application of framework 

12.  Goal of certification scheme evaluation 

1.1. 

The Scheme Assessment Framework (SAF) shall be used to assess the ability of 
certification schemes to provide assurance that material traded via the scheme 
has a low (negligible) risk of being illegally harvested or traded. The framework 
and this procedure have been developed to align with the legality definition of the 
EU Timber Regulation and the associated Guidance Document and requirements 
for  the  use  of  third  party  certification  schemes as outlined in the  Commission 
implementing Regulation (EU) No 607/2012. 

13.  Overview of evaluation approach 

2.1. 

The  SAF  should  be  applied  to  the  level  of  implementation  of  the  Scheme 
standards. This means that where the scheme is organized through national (or 
sub-national) standard setting and quality management schemes, these should be 
the object of assessment. International rules, procedures or standards should be 
evaluated where they are relevant to the implementation of the Scheme as well.  

2.2. 

The framework includes requirements to assess how different timber certification 
schemes provide assurance of low (negligible) risk of ‘legal non -compliance’ of 
certified material.  

2.3. 

The assessment (see assessment methodology below for more details) of each  
Scheme shall be conducted primarily using four broad sources of information:  

1:  Publicly  available  information  from  the  scheme  itself:  in  relation  to 
documented  normative 
(existing  standards,  policies  and 
procedures) and documents that guide the operational functioning of the Scheme 
(such  as  guidance83  and  other  tools  or  resources  which  describe  how 
requirements should be interpreted) 

requirements 

2: Direct interviews and discussions with relevant Scheme p erson nel:  the 
application  of  the  Framework  will  not  be  limited  to  desk-based  review  of 
documents but will also include on-site interviews with relevant representatives 
from  the  selected  Schemes  (and  where  relevant,  related  bodies  such  as 
assurance  providers, accreditation bodies and certificate holders) to  ensure a 
detailed representation of the functions of the schemes.  

Interviews are expected to provide the assessment team with information about 
the  intended  functioning  of  schemes  and  deepen  the  understanding  of  the 

83 Guidance is often contained within separate guidance documents or embedded in assurance requirements as interp re t a t i on  
guidance that can be referred to. It provides necessary context and consistency for the interpretation of standards. 

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activities of the scheme participants. This will be based on an interview guide and 
questionnaires developed before interviews are conducted. 

3: Stakeholder input via the Stakeholder Consultative Forum: input solicited 
by Preferred by Nature  – or submitted independently by Stakeholders - via the 
Stakeholder Consultative Forum. 

4: Outcomes or impacts information: it is not possible (as this is not within the 
scope  of  activities  of  the  project)  for  on-site  assessments  to  be  employed  to 
evaluate the framework or on-site performance of Certificate Holders, Certification 
Bodies or Scheme managers. Furthermore, many Scheme evaluation exercises 
focus primarily on the content of standards  – the requirements that need to be 
met by Certificate Holders. This is clearly important, but can be insufficient. T w o 
standards  that  look  identical  on  paper  can  support  very  different  outcomes 
depending on how they are implemented in practice. It is therefore necessary to 
look  at  both  the  performance  requirements  and  the  operational  systems  that 
support their uptake.  

As a result, other publicly available information or data (public summaries of audit 
reports,  research  studies,  stakeholder  reports,  competent  authority  data, 
certificate databases) as well as expert or authority consultations, which inform 
the  evaluation  of  the  Scheme  in  relation  to  the  results  or  impacts  that  it  has 
achieved, or that relates to Schemes in general 84. 

14.  Certification Scheme Assessment Framework 

3.1 

 Assessment of each Certification Scheme shall be conducted by application of 
the  criteria,  indicators  and  threshold  guidance  contained  in  the  Scheme 
Assessment  Framework  (SAF)  to  evaluate  the  schemes  ability  to ensure that 
legal requirements are met. 

3.2 

The SAF is divided into separate sections aiming at evaluating different aspects of 
the Scheme. These include: 

A: Requirements for Certificate Holders 

  A.1 Legal Requirements at the forest level 
  A.2 Legal requirements for supply chain entities 

Does  the  scheme  include a complete and comprehensive set of requirements 
enabling  evaluation  of  compliance  with  applicable legislation by the certificate 

84 In the absence of on-site evaluation of Schemes, it is important to recognise that the first “Scheme normative re q u ire me nt s” 
column is - to an extent - a proxy for impacts and that we should aim to include where possible any measurement or evaluat io n 
of actual results as the data becomes more reliable and available. 

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holder? These requirements are applicable to forest level, as well as supply chain 
entities. 

  A.3 Requirements for material control 

Does  the  scheme  include  requirements  to ensure that material from unknown 
sources  is  not  mixed  into  the  product  flow  included  in  the  scope  of  the 
certification?  This  may  be  via  a  CoC  system  using different forms of physical 
separation or using risk-based approaches to supply chain management. It should 
be underlined that it is not a requirement of the SAF that schemes have a specific 
type of CoC system, but there does need to be performance requirements that 
assure the absence of mixing. 

  A.4 General requirements for Certificate Holders 
  A.5 Quality and procedural requirements for Certificate Holders 

The SAF contains criteria that shall be used to assess how the scheme ensures 
that  Certificate  Holders  have  in  place  systems,  capacity  and  qualifications  to 
continually meet the Scheme requirements. 

B: Requirements for Certification Bodies 

  B.1 General Certification Body requirements 
  B.2 Certification Body requirements for auditing and certification 

These criteria are formulated to assess the system of the Scheme that should be 
in  place  to  manage  processes  like  accreditation,  oversight,  competence  a nd 
resources in relation to Certification Bodies. 

C: Requirements for Certification Schemes 

  C.1 Transparency 
  C.2 Standard setting 
  C.3 Accreditation 
  C.4 Certification process 

These criteria are formulated to assess the system of the Scheme that should be 
in place to manage Standard setting and revision, as well as on -going scheme 
maintenance  and  development,  including  scheme  transparency,  managing 
complaints etc. 

15.  Template tools 

4.1 

Assessment  of  certification  schemes  shall  follow  this  procedure,  and  use  the 
following documents: 

  Certification Scheme Assessment Framework (SAF); 
  Certification  Scheme  Assessment  Report  (SAR) 

template  (to  be 

Developed); 

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  Scheme  &  Stakeholder  interview  templates  (modified  for  different 

stakeholder groups) (to be Developed). 

16.  Scope of assessment 

5.1  The  assessment  of  each  certification  scheme  shall  identify at the outset  - and 
include  -  all  the  types  of  certification  standard  relevant  to  timber  legality 
included  in  the  scheme.  Any  differences  between  different standards for differ 
forest  types  must  be  included  (e.g.  where separate standards exist for natural 
forests and plantations). 

By way of example: 

  evaluation  of  the  PEFC  Scheme  must  include  evaluation  of  the  PEFC 
Forest Management (FM) standard, Group Forest Management and the 
PEFC COC standard. 

  evaluation  of  the  FSC  Scheme  must  include  evaluation  of  the  FSC 
certification  according to the Forest Management (FM) standard, SL IMF 
standard,  as  well  as  the  FSC  FM  –  and  FSC  COC  –  Controlled  Wood 
standards, along with FSC CoC standard. 

5.2  The  assessment  of  each  certification  scheme  shall  identify  at  the  outset,  and 
include,  all  models  of  certification  which  may  exist  within  the  Scheme.  It  is 
possible  that  some  variations  may  exclude  the  need  for  evaluation  of  some 
indicators. Examples of certification models include: 

  Forest Management certification 
  Group and multi-site certification 
  Smallholder, family-owned or reduced intensity models 
  Regional or jurisdictional models of certification 
  DDS and risk-based certification models. 

5.3  The  assessment  shall  include  all  documented  normative  requirements 
(existing standards, policies, procedures, interpretations, directives, instructions…) 
as well as the documented guidance that supports the operational functioning of 
the Scheme (such as guidance, advice notes, and other tools or resources).  

5.4  The assessment of each certification scheme shall consider the use of ap pr oved 

temporary or interim standards developed within Schemes.  

5.5  The  assessment  of  each  certification  scheme  shall  not  consider  draft 
standards/guidance which have not been finalised and /or ap p rove d as per 
Scheme document development processes.  

5.6  On  a  case  by  case  basis,  assessments  shall  consider  any  approved  final 
versions of standards/guidance , where the new document has not come into 
force or is still in a transitional phase (where the date for f ull replacement of the 
previous standard has not arrived). 

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17.  Selection of schemes 

6.1  Selection  of  schemes  for  evaluation  –  scheme  selection  shall  be  made  by 
Preferred by Nature, in agreement with the EC, with input via a public stakeholder 
process.  The  following  three  elements  shall  be  included  in  the  process  and 
decision making for Scheme selection:  

  Public stakeholder process, including initial stakeholder survey on scheme 

selection (run 18th June to 2nd July). 

  Our evaluation of the relevance and use by the Scheme to the European 
forest sector and wood-using industries, as a risk mitigation tool in relation 
to the EU Timber Regulation. 

  Relevance  of  the  importance  to  the  global  forest  sector  and  wood -
industries, in relation to the use of certification schemes,  including basic 
metrics such as the number of certifications or forest area certified, etc.  

6.2  Communicate with Scheme owners/manager – it is important to communicate the 
intentions to evaluate specific schemes or standards with the Scheme owner, once 
the selection of Schemes has been made. 

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Assessment steps 

Figure 1: Scheme evaluation process (once SAF and SAP are finalised and approved) 

18.  Key steps of the Scheme evaluation process 

7.1  The assessment process has a number of distinct steps that should be followed. 

These comprise, in the following approximate order and are discussed in turn:  

Internal quality review,  

  Application of the Assessment Framework by internal experts (Assessors),  
 
  External peer review 
  Stakeholder consultation 

7.2  Application of the Assessment Framework – This shall include communication 
with the Scheme owners/managers. See section D. Assessment Methodology. The 
application of the assessment framework shall be applied on two levels: 

  Evaluation of the Scheme at overall (central or international) level 
  Consideration  of  how  the  Scheme  will  be  implemented  at  the  local 
(national) level. The purpose is that national level evaluation is to provide 
data and findings that feed in as evidence into the central-level evaluation.  

In  the  case  of  two  schemes  (FSC/PEFC),  Preferred  by  Nature  shall  evaluate 
national implementation of these two Schemes for four countries. In the case of 
other schemes, attempts should be made to understand  the extent and level of 
local adaptation.  

7.3 

Internal quality review – The Assessor (Preferred by Nature team responsible for 
the application of the Assessment Framework) shall ensure internal quality checks 
of draft scheme assessments before peer review and stakeholder consultations 
take place. 

7.3.1. The objective of the internal review is to ensure i) the assessments have 
complied  with  the  procedure  outlined  in  this  manual;  ii)  the  rigor  of  the 

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evaluation process, as well as; iii) the consistency of evaluation a pproach 
across all Scheme evaluations.  

7.4  External Peer Review – at least three peers, selected based on their experience 

and competence, shall act as independent reviewers. 

7.4.1. Three or more external peers should be established prior to initiation of the 

analysis. 

7.4.2. External peer reviewers shall be free of conflict of interest in relation to the 
schemes  under  evaluation.  Peer  reviewers  shall  complete  and  sign  a 
Disclosure of Conflict of Interest agreement with Preferred by Nature.  

7.4.3. External  peer  reviewers  shall  possess  experience and competence with 
relevant  schemes.  They  may  have such experience from direct work as 
auditors for a scheme, or through work in relevant industry where they may 
have  applied  the  scheme  to  supply  chains  or  land  management. 
Alternatively, they may have participated (as stakeholders) in scheme and 
standards  development  processes,  whether  within  working  groups  or 
otherwise.  Additionally, 
from  public 
administration or government. 

they  may  have  experience 

7.4.4. Assessment findings should undergo 2 rounds of external peer review. One 
round after the internal review of a draft assessment, and a second and 
final review of a final draft if major issues remain, or significant changes are 
made  after  the  first  round,  prior  to  making  publicly  available  for 
consultation. 

7.4.5. In  cases  where  significant  issues  or  questions  remain  after  the second 

review, a third review of these specific issues may be necessary. 

7.5  Stakeholder consultation – a stakeholder consultation forum shall be developed 
via a website of a defined contact where stakeholders have the ability to provide 
feedback and receive information about the evaluation. 

7.5.1. Stakeholders  should  be  consulted  at  relevant  steps  in  the  assessment 

process such as for the following: 

  The development of the Framework  
  Selection of schemes for evaluation 
  Review  of  draft  assessment  results  –  minimum  one  round  of 

consultation shall be conducted 

  Provision of feedback on an ongoing basis through the Pr eferred by 

Nature website and webinars 

Note:  The  Stakeholder  Consultation  Form  (SFC)  provides  the  principal 
forum  for  engagement  with  stakeholders.  Input  and  feedback  shall  be 
actively encouraged by inviting all stakeholders within the SFC to provide 
input  into  the  assessment  process.  Such  stakeholders  include,  but  not 
limited to the following: 

  Scheme Owners/managers 
  Certification Bodies 

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 

Industry  and  forest-sector  representatives  (individual  companies 
and the associations which represent them) 

  Civil Society Organisations 
  Government bodies and government representatives, particularly 
Competent  Authorities  responsible  for  the  implementation  of  the 
EUTR. 

  Academia and research institutions. 

Ensuring  balanced  representation  is  part  of  the  Project  implementation 
manual, and outside of this documented procedure, which is focussed on 
the application of the SAF only. However, all stakeholders which are part of 
the Project SFC will be notified and have equal opportunity to provide input 
on one or more drafts of the project findings. 

7.5.2. Stakeholders  shall  be  informed  of  the  assessment  process  prior  to the 

selection of schemes and initiation of the assessment process. 

7.5.3. All comments/input from stakeholders shall be recorded and stored. 

7.5.4. The Assessors (Preferred by Nature team responsible for the application of 
the  Assessment  Framework)  shall  review  all  comments/input  from 
stakeholders. 

7.5.5. The  Assessors  shall  respond  in  writing  to  all  comments  and  input, 
recording the action taken, or revisions made, to address each comment. 
These records shall be stored in a file and made publicly available. 

Assessment methodology 

The  main  step  in  this  process  is  the  evaluation  of  how  the  Scheme  is  aligned  with  the 
requirements of the Framework. This consists of a desk review of documentation about  the 
Scheme’s requirements, systems and operations. Also additional sources of information will 
be used,  beyond what can be provided by the Scheme owner itself.  

This section describes the evaluation methodology that will be employed:  

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Figure 2: Scheme evaluation methodology – basic steps 

19.  Assessment methodology – information gathering 

8.1.  As above, the assessment of each indicator should be conducted primarily using 

four sources of information: 

1: Publicly available information from the scheme itself  
2: Direct interviews and discussions with relevant Scheme personnel  
3: Stakeholder input via the Stakeholder Consultative Forum 
4: Outcomes or impacts information 

These are addressed in turn below: 

1: Publicly available information from the scheme itself 

8.2. 

Identify a clear description of the Scheme normative requirement(s) or other core 
documents85  that  are  considered  to  cover  a  corresponding  SAF  indicator,  and 
record these in the report template. 

Note: The Assessor may contact the Scheme manager and ask them to support filling in 
relevant information. However, the Assessor has ownership and remains responsible for 
the content and quality of the input. To this end, all information completed by others shall 
be checked by the Assessor. 

8.2.1.  For each indicator, the following shall be considered by Assessors, using a 
systematic approach, to ensure complete coverage of the Scheme in the 
analysis: 

relevant types of certification standard 

 
  models of certification 
 
  approved  final  versions  of  standards/guidance,  where  the  new 
document has not come into force or is still in a transitional phase  

the use of approve temporary or interim standards 

8.3. 

Identify a clear description of the Scheme GUIDANCE or other tools or resources 
which describe how requirements should be interpreted, that are considered to be 
most relevant to the SAF indicator. 

8.4.  Sources referenced in the Scheme Assessment Report (SAR), shall be described 
in the following way: i) Certification Scheme (if not indicated in the Standard Code); 
ii) Standard Code or name; iii) Version; iv) relevant criterion or Indicator; iii) link on 
the Scheme website. Example: 

85 These may be Scheme guides, interpretations, directives, policies, procedures or advice notes. 

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  PEFC  ST  2002:2013  2015-12-07  Second  Edition,  criterion  5.4.1: 
https://cdn.pefc.org/pefc.org/media/2019-02/023fae13-c278-4104-93e0-
bf48b123bc8b/5aa3f8bc-30c3-5f99-951e-e6a8f6d1d01b.pdf  

8.5.  Provide  a  description  (or  summary)  of  the  normative  requirements  and 

guidance/interpretations.  

8.5.1.  As  a  general  rule  (unless  the  section  is  too  large),  cut/paste  relevant 
section(s)  of  text  into  the  report  finding  for  reference  (“Scheme  Info” 
column in the orange section of the SAR). This shall assist internal and 
peer review processes. 

8.6.  Make a note of any  questions, uncertainties or ambiguities for later consultation 

(via direct interview) with relevant Scheme personnel. 

2: Direct interviews and discussions with relevant Scheme personnel  

8.7. 

Interviews  with  Scheme personnel (and where relevant, related bodies  such as 
assurance providers, accreditation bodies and certificate holders) are expected to 
provide the assessment team with information about the intended functioning of 
schemes  and  deepen  the  understanding  of  the  activities  of  the  scheme 
participants.  

8.8.  At the outset of each Scheme assessment, an ‘initial list’ of information required 
from  the  Scheme  may  be  elaborated,  to  be  presented  as  soon as possible to 
Scheme personnel.  

8.9.  The  subject  matter  for  future  interviews  with  Scheme  personnel,  shall  vary 
according to the questions which remain or gaps which require to be filled in the 
assessment.  

8.10.  Questions  should  be  formulated  by  email  and written responses with evidence 
(additional data, information, guidance or normative documents…) requested in 
return. This will reduce time for note-taking and ensure accurate records of the 
Scheme response are recorded. 

8.11.  If  necessary, follow-up interviews or calls can be conducted by either phone or 
online, to clarify questions or responses in the email exchange. Where possible  
they should be carried out in the language of the interviewee.  

8.12.  Returned  written  responses  (and/or  interview  notes)  should  be  saved  (with  a 

systematic file name) in the relevant file.  

8.13.  Sources referenced in the Scheme Assessment Report (SAR), shall be des cribed 
in  the  following  way:  i)  Certification  Scheme;  ii)  Interview/email  date;  iii) 
Interviewee (position). 

E.g. BV call-14/10/2020-Head of Accreditation. 

E.g. FSC email responsel-09/12/2020-Head of Accreditation. 

3: Stakeholder input via the Stakeholder Consultative Forum (SCF) 

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Via the SCF, interested stakeholders can provide feedback, both on the evaluation and 
on  insights  they  have  about  the  evaluated  Schemes.  This  will  provide  the means to 
gather additional insight about the Schemes, providing a usefu l complement to the desk 
review. Consultation input shall be considered as an information source to be weighed 
alongside other information.  

8.14.  Stakeholder input shall be provided via the Stakeholder Consultative Forum.  

8.15.  Sources referenced in the Scheme Assessment Report (SAR) shall be described 
in  the  following  way:  i)  Code  in  relation  to  Stakeholder  input  register;  ii) 
Organisation 

E.g. [Stakeholder register code] 132 – Forest Trends. 

8.16.  Direct interviewees to follow up on Stakeholder input, shall be conducted u sing the 
same approach (questionnaire templates, etc.) as with Scheme personnel. 

4: Outcomes or impacts information 

Performance or impact data  – where available  – can give greater insight about how a 
Scheme operates in practice. The general premise is that this will give a more complete 
picture of its performance, or the performance of certification schemes in general. 

8.17.  At the level of the Scheme, Principle, Criterion or Indicator, consider any publicly 
available  information  or  data  which  informs  the  evalua tion  of  the  Scheme  in 
relation 
to 
that  relate 
certification/verification schemes in general. The following shall be considered:  

it  has  achieved,  or 

the  results  or 

impacts 

to 

  Data/information  sources  such  as:  research  studies 86,  scientific  articles, 
NGO  reports  or 
investigations,  documented  expert  consultations, 
competent  authority  data,  certificate  databases,  independent  monitors, 
news articles or other stakeholder information. 

  Reports analysing certification scheme impacts and application  
  Examples of audit reports. 
 

Interviewees  with  experts  conducted  using 
(questionnaire templates, etc.) as with Scheme personnel. 

the  same  approach 

8.18.  Consider  the  quality  and  credibility  of  the  data.  Ensure  that  claims  are 

substantiated. 

8.19.  Consider the extent to which publicly available information which focuses on one 
geographic  region  or  Scheme,  may  apply  to  other  regions  or  Schemes. 
Alternatively,  findings  of  NGO  reports  and  other  information  may  show  other 
patterns  in  relation to Schemes (such as their ability to respond to br ibery and 
other forms of corruption).  

86 For example, research or analysis regarding non -conformances of Schemes related to an area of legality. 

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8.20.  Sources  shall  always  be fully referenced so that they are verifiable by external 
parties.  The  Harvard Referencing style shall be used (see this  guide). See the 
following examples of format:   

  Report/article:  Andersen,  D.  (2018).  Illegal  timber  from  natural  forest. 

Nature. Available at: www.fdfgdgsdf.com  

  Legislation: Forest Law 2010.  Law No. 04/2003, 21 October 2010, Article 
12-43 http://www.forestlaw.org/other-publications/forest-law-no-04-na-lao-
pdr/. 

  Webpage/website:  UK  Forestry  Commission  (2020)  Available  from: 
https://timbertransportforum.org.uk/work/good-practice/  [Accessed  19th 
May 2020] 

  Personal  communication:  Law,  James.  United  Kingdom  EUTR 
Competent Authority. (Personal communication, 26th November 2020)  

20.  Assessment methodology – evaluation of coverage 

9.1.  The objective of the evaluation is to understand how well a Scheme is aligned to 

meet EUTR requirements for due diligence, through the use of the SAF.  

9.1.1.  Sections A1 to A3 may be relatively straight-forward to evaluate, as they 
address mostly performance requirements and coverage of the definition 
of timber legality as far as the EUTR is concerned. 

9.1.2.  However, sections A4, A5, B and C address issues of quality assurance 
and their impact on the operational ability of the scheme to ensure a low-
risk (negligible) conclusion in relation to certified products placed on the 
EU market. As a result, it may not necessarily always be the case that a 
gap (Partially Covered or Not Covered conclusion) in relation to a single 
criterion,  may  not  necessary  always  result  in  the  need  to  report  a 
significant  deficiency  or  gap  in  the  Scheme as a whole, but rather just 
point to a potential vulnerability in relation to the Scheme’s robustness or 
potential weakness. 

9.2.  Provide an appropriate justification for coverage by the Scheme of the specific 
indicator  in  the  SAF,  as  necessary.  This  will  follow  the  following  approximate 
format: 

  Description (or summary) of the normative requirements (as per 8.4 above) 
  Discussion of findings, including an overview of issues and risks (based on 
referenced  sources)  relevant  to  the  indicator. Include any Outcomes or 
impacts data or information (as per 8.6 above). 

  Conclusion & Justification which shall be clearly formulated as Covered, 
Partly Covered or Not covered. Include a summary justification of the 
designation to provide the rationale behind the final conclusion. E.g. “based 
on  findings  x,  y  and  z,  it  is  concluded  that  the  indicator  is  PARTLY 
COVERED”. 

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9.2.1.  Record  any  variations  in  conformance  between  types  of  certification 

standard, or certification models. Examples: 

  an area of customary rights may be included within the PEFC FM 
standard, but does not form part of the definition of legality in the 
PEFC COC Controlled Sources section of the COC standard 
  FSC  FM  certification and FSC (FM) Controlled Wood standards 
may cover an indicator, whereas SLIMF certification does not. 

9.3.  Record  the  level  of  conformance  of  the  Scheme  with  the  indicator.  Options 87 
include: 1. Covered, 2. Partly Covered or 3. Not covered. The definitions of the 
options are as follows: 

Conclusion 

Definition 

Explanation 

Covered 

When available Scheme requirements 
and information - and any impacts 
evidence available - indicate the 
coverage of the SAF indicator. 

Partially Covered 

Not Covered 

When available Scheme requirements 
and information - and any impacts 
evidence available - indicate only 
partial coverage of the SAF indicator.  

Alternatively, special concerns about 
Scheme standards, credibility, rigor or 
coverage may exist. 

NOTE: It is important to justify the 
partial coverage, and indicate where 
the issues are which result in a 
Coverage  conclusion not being given. 

When available Scheme requirements 
and information - and any impacts 
evidence available - indicate that there 
is no coverage of the SAF indicator. 

NOTE: It is important to justify a no 
coverage conclusion. 

Coverage  is the ability of the 
Scheme to provide assurance that 
material traded via the Scheme has 
a low (negligible) risk of being 
illegally harvested, traded in line 
with the legality definition of the EU 
Timber Regulation. 

Partial Coverage means the 
Scheme is only partly able – or may 
be compromised in one or more 
ways – to provide assurance that 
material traded via the Scheme has 
a low (negligible) risk of being 
illegally harvested, traded in line 
with the legality definition of the EU 
Timber Regulation. 

The Scheme is not – or 
inadequately – able to provide 
assurance that material traded via 
the Scheme has a low (negligible) 
risk of being illegally harvested, 
traded in line with the legality 
definition of the EU Timber 

87 As a result of having only three possible scores, the option of trying to divide partial coverage into a number of different leve ls 
is avoided, which carries a significant risk of becoming subjective. 

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Not Applicable (N/A) 

When, for whichever reason, the SAF 
indicator does not apply. 

Regulation. 

21.  Assessment methodology – coverage conclusions and risk 

The  Scheme  evaluation process will result in a decision about the extent of alignment or 
coverage  of  a  Scheme  with  the  EUTR  and  the  criteria of the SAF. The Assessor will be 
responsible  to  make  the  decision.  As  with  the  evaluation  itself,  key  considerations  are 
consistency and transparency in relation to the justification for the conclusion.  

In coming to a decision, different sources of information will be used, some of which may 
conflict. It will be important to consider the source, robustness and integrity of each t ype of 
data  or  information  to  assess  how  much  weight  to  assign  to  it  in  the  decision -making 
process. 

10.1.  Within the evaluation of coverage, the framework will require an assessment for 
each  indicator  as  to  if/how  different  a  Scheme  provides  assurance  of  low 
(negligible) risk of ‘legal non-compliance’ for certified material.  

10.2.  The  threshold  of low (negligible ) risk of ‘legal non-compliance’, as well as the 
methodology to determine low risk, can be considered similar to other Preferred by 
Nature risk assessment processes: 

A situation can be considered low risk if the potential legal non -compliances that 
may arise in the case of certified material from that Scheme are: 

temporary lapses. 

 
  unusual/non–systematic; or 
 

limited in their temporal and spatial impact.  

A situation cannot be considered low risk (i.e. risk is specified or non -negligible) if 
the potential legal non-compliances that may arise in the case of certified material 
from that Scheme may: 

  not be temporary, and probably are systematic 
  continue over a long period of time;  
  affect a wide area and/or cause significant damage;  
  not/will not be corrected or adequately responded when identified; or 
  have a significant negative impact on the society, the production of forest 
products and other services, the forest ecosystem and the people directly 
and indirectly affected by forest operations. 

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Glossary of Definitions 

Country  Expert  (CE)  –  A  Preferred  by  Nature staff member engaged to assist with the 
assessment  of  a  Scheme,  who  has  professional  experienced  and/or  a  detailed 
understanding of the country/regional context within which the Scheme, system or standard 
operates. 

Assessor – The Preferred by Nature staff member who is responsible for facilitating and 
managing  the  assessment  of  the  Scheme,  including managing the assessment process, 
preparing and conducting interviews with the Scheme owner, and preparing/revising draft 
and  final  report.  The  Assessor  shall  have  the  necessary  experience  and  competences 
(including language skills required for the Scheme assessment). 

Internal  Reviewer  (IR)  – A Preferred by Nature staff member with senior authority and 
experience to review draft Scheme Assessment Reports. 

Peer Reviewer (PR) –External peer reviewers (free of conflict of interest in relation to the 
schemes under evaluation) that shall review and approve select project outputs, such as the 
Assessment Framework, Assessment Framework Procedures, and Draft or Final Evaluation 
Reports, to ensure that methodologies used are sound and free of any bias.  

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Annex 3: Certification Scheme Assessment 
Framework (SAF) 

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Table of Contents 

1. 

Introduction ....................................................................................................... 261 

2.  Background....................................................................................................... 261 

3.  Defining legality requirements  ......................................................................... 261 

Refining legality definition ............................................................................ 262 

4.  Structure of the Framework ............................................................................. 262 

5.  References  ....................................................................................................... 264 

6.  Glossary ............................................................................................................ 265 

7.  Framework for evaluating certification and verification schemes  .................. 266 

A. Requirements for Certificate Holders  ............................................................. 266 

A.1 Legal Requirements at the forest level ................................................. 266 

A.2 Legal requirements for supply chain entities ........................................ 271 

A.3 Requirements for material control ......................................................... 273 

A.4 General requirements for Certificate Holders ....................................... 275 

A.5 Quality and procedural requirements for Certificate Holders  .............. 275 

B. Requirements for Certification Bodies ............................................................ 276 

B.1 General Certification Body requirements.............................................. 276 

B.2 Certification Body requirements for auditing and certification  ............. 277 

C. Requirements for Certification Schemes ....................................................... 281 

C.1 Transparency ......................................................................................... 281 

C.2 Scheme & standard scope .................................................................... 283 

C.3 Accreditation and oversight ................................................................... 284 

C.4 Certification process .............................................................................. 285 

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22.  Introduction 

This  Framework  has  been  developed  as  part  of  the  outputs  to the project “Study on 
Certification  and  Verification  Schemes  in  the  Forest  Sector  and  for  Wood -based 
Products”, implemented by Preferred by Nature on behalf of the European Commission.  

Part of the project aims to assess certification schemes to clarify the role of certification, 
their functioning and their ability to meet EUTR due diligence requirements.  

23.  Background 

The  objective  of  the  Study is to create a resource of knowledge and reference for  all 
interested and concerned parties in the forest- and wood-based products sector. It should 
help  Competent  Authorities,  Operators  and  Monitoring  Organisations  covered  by  the 
EUTR  in  their  understanding  of potential benefits and shortcomings of certificat ion, in 
particular  in  the  context  of  the  implementation  of  the EUTR. As such, one part of the 
overall  objectives  is  to  create  an  overview  of  existing  certificates,  third -party  verified 
schemes and certifying bodies issuing certificates with regard to forests and wood -based 
products  and to evaluate their respective strengths and weaknesses in respect to the 
EUTR obligations. This should, in turn, encourage stronger standards and transparency of 
certification and third part verification schemes. 

It should be underlined that it is NOT the intention of the study to create a compliance 
checklist  of  certification  schemes.  The  EUTR  continues  to  recognise  third  party 
certification as an important potential tool for risk assessment and risk mitigation, but does 
not  recognise  certification  as  proof  of  compliance. This will not change based on this 
study. 

As part of the above objective, this framework has been developed to allow evaluation of 
the  differences  and  uniformities  between  certificates  and certifying bodies. It includes 
requirements  to  assess  to  which  degree different forest certification schemes provide 
assurance of low (negligible) risk of ‘legal non-compliance’ of certified material.  

The  Framework  aligns  with  the  definitions  and  approach  to  certification  sc hemes  as 
described within the EU Timber Regulation (No. 995/2010) and the associated Guidance 
Document,  along  with  additional  requirements  for  the  use  of  third  party  certification 
schemes as outlined in the Commission implementing Regulation (EU) No 607/2012 and 
specifically Article 4 in the Commission Implementing Regulation (EU) No 607/2012.  

The Framework takes into account verifiers for Article 6 in the EUTR, and documentation 
for  Article  4  of  the  Implementing  Regulation,  as  well  as  a  wide  array  of sustainab ility 
standards and benchmarks used in the areas of forest and wood -based products, among 
other resources identified under References. 

24.  Defining legality requirements 

A key question of this study is to what extend different certification schemes consider t he 
aspects of legality, as included in the EUTR. 

The Framework contains a list of principles, criteria and indicators for the legality of forest 
products,  which  correlate  with  the  definition  of  “applicable  legislation”, defined by the 
EUTR as: legislation in force in the country of harvest covering the following matters:  

– 

rights to harvest timber within legally gazetted boundaries,  

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–  payments  for  harvest  rights  and  timber  including  duties  related  to  timber 

harvesting,  

– 

– 

– 

timber harvesting, including environmental and forest legislation including forest 
management  and  biodiversity  conservation,  where  directly  related  to  timber 
harvesting,  

third parties’ legal rights concerning use and tenure that are affected by timber 
harvesting, and  

trade and customs, in so far as the forest sector is concerned. 

It is noted that national laws include the laws and regulations of all jurisdictions within a 
nation (local, regional, and national). The constitution as well as international laws and 
conventions that nations have ratified are also considered as applicable law. 

Refining  legality definition 

To  enable  a  more  granular  evaluation  of  legality  issues,  the  Framework  has  been 
designed to include criteria under each legality principle. These criteria are subdivisions of 
the Principles and detail the specific legislation a certification scheme should address in 
order to meet the overarching principles defining applicable legislation.  

As an example, the Principle of “legal rights to harvest within the gazette areas” has been 
subdivided into criteria that all are part of the principle level issue of “rights to harvest”. In 
this Framework the Right to harvest has been sub-divided into requirements related to 
applicable legislation within: 

land tenure and management rights 

 
  existence of concession licenses. 
  management and harvesting planning, and 
  harvest permits 

The subsequent use of indicators in this framework are applied in order to enable the 
evaluation under each criterion. 

NOTE: It should be underlined that the criteria and indicators are used only as 
indicative of relevant requirements that could be reflected in  n ational ap plicable 
legislation. 

25.  Structure of the Framework 

The framework uses the terms principles, criteria and indicators to define the different 
levels of requirements determined for assessing certification schemes.  

Principles  of  this  framework:  The  Preferred  by  Nature  Certification  Scheme 
Assessment Framework contains the following principles (broad requirements or subject 
areas to be covered):  

  A: Requirements for Certificate Holders 

o  A.1 Legal Requirements at the forest level 
o  A.2 Legal requirements for supply chain entities 
o  A.3 Requirements for material control 
o  A.4 General requirements for Certificate Holders 
o  A.5 Quality and procedural requirements for Certificate Holders 

  B: Requirements for Certification Bodies 

o  B.1 General Certification Body requirements 

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o  B.2 Certification Body requirements for auditing and certification 

  C: Requirements for Certification Schemes 

o  C.1 Transparency 
o  C.2 Standard setting 
o  C.3 Accreditation and oversight 
o  C.4 Certification process 

Criteria  of  this  framework:  sub-sections  of  requirements  which  help  to  support 
evaluation of the Principles. 

Indicators  of  this  framework:  Quantitative  or  qualitative  variables  which  can  be 
measured  or  described,  and  which  help  to  support  evaluation  of  the  Criterion.  Each 
indicator  is  written  to  be  as  clear  and  incisive  as  possible,  enabling  a  consistent 
assessment that results in a robust picture of potential conformance with the framework. 
Some of the Indicators are accompanied by explanatory guidance where necessary to 
ensure consistency of interpretation. 

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26.  References 

The below documents and reports have been used as references for the development of 
this Framework. Inclusion in this list does not indicate that the Framework complies with 
any of the standards mentioned. 

  Accountability Framework Definitions. 

  CEPI, 2000. Comparative Matrix of Forest Certification Schemes.  

  Commission  Delegated  Regulation  (EU)  No  363/2012  of  23.2.2012  on  the 
procedural rules for the recognition and withdrawal of recognition of monitoring 
organisations as provided for in Regulation (EU) No 995/2010  

  Commission  Implementing  Regulation  (EU)  No  607/2012 of 6 July 2012 on the 
detailed rules concerning the due diligence system and the frequency and nature 
of the checks on monitoring organisations as provided for in Regulation (EU) No 
995/2010  

  CPET,  2015.  Results  of  the  Evaluation  of  Category  A  Evidence:  Forest 

Certification Schemes 

  Dutch  Timber  Procurement  Policy  Framework  for  Evaluating  Evidence  of 

Compliance with Timber Procurement Requirements, 2014. 

  EUTR Guidance Document, adopted 12 February 2016. 

  EUTR Guidance note on Recycled Materials  

  EUTR Guidance on Armed Conflict 

  FSC  Advise  Note  -  Applicable  National  and  Local  Laws  and  Regulations  for 
Controlled Wood for Forest Management Enterprises (FSC-ADV-30-010-01 EN) 

  Fern, 2001. Behind the logo: An environmental and social assessment of forest 

certification schemes 

ISEAL Assurance Code Version 2.0 

ISEAL Credibility Principles v1.0  

ISEAL Impacts Code of Good Practice Version 2.0  

ISEAL Standard Setting Code v6 Dec 2014 

ISEAL Sustainability Benchmarking Good Practice Guide 

ISO 19011:2011 Guidelines for auditing management systems 

ISO/IEC  17021-1:  2015  -  Conformity  Assessment  -  Requirements  for  Bodies 
Providing Audit and Certification of Management Systems 

ISO/IEC  17065:2012  -  Conformity  Assessment  –  Requirements  for  Bodies 
Certifying Products, Processes and Services 

 

 

 

 

 

 

 

 

  Preferred  by  Nature  standard:  Certification  System  Evaluation  v1-0  (LS-18) 

approved 10/02/2017 

  Regulation (EU) No 995/2010 of the European parliament and of the council of 20 
October  2010  laying  down  the  obligations  of  operators  who  place  timber  and 
timber products on the market 

  WWF, 2006. Forest Certification Assessment Guide (FCAG). 

  WWF,  2016.  WWF  Certification  Assessment  Tool  (CAT)Heading  3:  keep  the 

information in subtitles as short as possible 

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27.  Glossary 

Accreditation body: Entity charged with oversight (see Oversight) of a Certification Body.  

Applicable  legislation:  refers  to  the  EUTR  definition  of  applicable  legislation  in  the 
country  of  harvest,  which  is  legislation  in  force in the country of harvest covering the 
following matters:  

rights to harvest timber within legally gazetted boundaries,  

– 
–  payments  for  harvest  rights  and  timber  including  duties  related  to   timber 

harvesting,  
timber harvesting, including environmental and forest legislation including forest 
management  and  biodiversity  conservation,  where  directly  related  to  timber 
harvesting,  
third parties’ legal rights concerning use and tenure that are a ffected by timber 
harvesting, and  
trade and customs, in so far as the forest sector is concerned. 

– 

– 

– 

It  is noted that the legislation in the country of harvest includes international laws and 
conventions that nations have ratified. ‘ 

Certification Body: Body responsible for performing the assessment (may also be known 
as assurance provider)  

Certification Scheme: the requirements (Schemes), as well as the rules and procedures 
for how the Scheme will operate. 

Certificate Holders: Organisation that choose to certify their activity according to Scheme 
requirements. 

Client: The person or enterprise that is seeking assurance of their conformity with the 
requirements in a Scheme. 

Due  Diligence  System  (DDS):  A  set  of  steps  or  actions  taken  to  ensure  that  due 
diligence is exercised. The due diligence system may consist of written guidelines and 
procedures that describe the due diligence process in detail.  

Normative requirements: the specific criteria and indicators contained in the standard(s) 
used by the Scheme. 

Organisation: The person or enterprise that is seeking assurance of their conformance 
with  the  requirements  in  a  Scheme  (synonyms:  operator,  client,  enterprise,  entity, 
participant, producer, member and auditee). 

Oversight: Assessment of an CBs competence to carry out specific assurance tasks. 

Publicly available: Obtainable by any person, without unreasonable barriers of access. 

Scheme:  the  totality  of requirements of the certification scheme, including standards, 
policies, procedures, and guidelines under which the Scheme operate. 

Scheme  owner:  The  organisation  that  determines  the  objectives  and  scope  of  the 
Scheme, as well as the rules for how the Scheme will operate and the standards against 
which  conformance  will  be  assessed.  In  most  cases  this  is  the  Standa rd-setting 
organisation.  

Standard-setting  organisation:  The  organisation  responsible  for  managing  the 
development and revision of the standard(s), applied by the Scheme.  

Supply chain: the network of entities that take legal and/or physical ownership of fo rest 
products in their production, transport, trade, distribution, sale and consumption. A supply 
chain starts from the forest or plantation – where the material is harvested – to the final 
organisation downstream which sells (e.g. retailer) or consumes th e product or material. 

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28.  Framework for evaluating certification and verification schemes 

The table below contains the principles, criteria and indicators used for evaluating certification Schemes. 

Code  Criterion 

Indicators 

Threshold & guidance 

A. Requirements for Certificate Holders 

Requirements  applicable  to the Certificate  Holders.  These include  requirements  to comply  w ith applicable  legislation,  as w ell as requirements  relevant to ensuring  continued 
performance and integrity  of the operations  – as far as is related to legal compliance. 

A.1  Legal Requirements at the forest level 

This principle  relates to how  the scheme  ensures that Certificate  Holders  comply w ith all  applicable  legislation.  This section relates to requirements  of the Scheme  that applies  to 
Certificate  Holders  - or other entities  subject to the normative  requirements  of the Scheme  (e.g. included  w ithin the scope of a certified due diligence  system) - w ithin the Country of 
Harvest. 

A.1.1 Rights to harvest timber within legally gazetted boundaries 

A.1.1.1 

Land tenure and 
management  rights 

A.1.1.1.1.  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  covering land tenure rights, including 
customary rights as w ell as management  rights.   

A.1.1.1.2.  The Scheme  shall include  requirements  to ensure that 
licenses, right of tenure and management  rights, have been 
issued: 

i)  according to the legally  prescribed procedure, 

266 

It should  be clearly described in the standard how  to evaluate the legal 
compliance.  In  this regard it shall not be considered  adequate  to include 
only a generic statement  such as "all land tenure and management 
documents  should be available".  The EUTR  Guidance  states: “an 
operator must  determine  w hether the scheme incorporates a standard 
that includes all  the applicable  legislation.”  See C.2.1.1. 

The  Scheme  should explicitly  address the potential  for corrupt practices 
and include  requirements  to exclude corruption. 

 
 
 
 
 
 
 
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ii) in compliance  w ith third parties' legal  rights concerning  tenure, 

iii) specifying the legally-gazetted  boundaries,  and; 

iv) w ith absence of corrupt practices. 

A.1.1.1.3  The Scheme  shall include  requirements  that ensure the 
existence of legal  business registration, and other relevant legally 
required licenses.   

A.1.1.2.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  regulating  procedures for the issuing of 
concession licenses, including  use of legal  methods  to obtain 
concession licenses and that licenses are covering only legally 
gazetted areas 

A.1.1.2 

Concession  licenses 

It shall  not be considered adequate  to include  only a generic  statement 
such as "Concession  licenses should be available".  See C.2.1.1. 

A.1.1.3 

Management  and 
harvesting planning 

A.1.1.3.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  and legal  obligations  for management 
planning,  including  conducting  forest inventories,  having a forest 
management  plan and related  planning  and monitoring. 

See C.2.1.1. 

A.1.1.3.2  The Scheme  shall include  requirements  that all  legally 
required planning  documents  have been approved prior to 
implementation  of forest harvesting activities. 

A.1.1.3.3  The Scheme  shall include  requirements  to ensure that 
certificate holders meet  legal  requirements  concerning benefit 
sharing they have negotiated  w ith communities.  E.g.  social 
agreements  or social responsibility  agreements  or cahier de 
charges, dependent  on the country.  
A.1.1.4.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  regulating  the issuing of harvesting 
permits,  licenses or other legal  documents  required for specific 
harvesting operations. 

This should  include legal  requirements  related  to agreements  reached 
w ith affected indigenous  peoples and local  communities  through FPIC 
w ith their self-chosen representatives. 

It should  be noted  that in countries w ith high  level of corruption  the mis-
use of permits  (e.g. salvaging  or artisanal  permits)  is large. The  system 
should guarantee  there is no misuse of these permits. 

A.1.1.4 

Harvesting  permits 

A.1.2 Payments for harvest rights and timber including duties related 

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to timber harvesting 

A.1.2.1 

Payment  of royalties 
and harvesting fees 

A.1.2.2 

Value-added  taxes 
and other sales taxes 

A.1.2.1.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  covering payment  of all legally  required 
forest harvesting-specific fees such as royalties, stumpage  fees 
and other volume-based  fees, as w ell as land  area taxes or fees. 

A.1.2.2.2  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  covering different types of sales taxes 
that apply to the material  being  sold, including  selling  material  as 
grow ing forest (standing stock sales). 

A.1.3 Timber harvesting, including environmental and forest 
legislation including forest management and biodiversity 
conservation, where directly related to timber harvesting 

A.1.3.1 

Timber  harvesting 
regulations 

A.1.3.1.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith legal  obligations  for harvesting techniques  and 
technology  including  timing  of harvest, selective cutting, shelter 
w ood regeneration,  clear felling,  transport of timber  from felling 
sites and seasonal limitations  etc. 

This includes  the mis-use of salvaging permits  or other specific 
ministerial  permits,  w ith the intention  of circumventing  harvest 
regulations 

A.1.3.1.2  The Scheme  shall include  requirements  to control 
potential  illegal  activities by third parties w ithin the area managed 
by the operation. 

A.1.3.2 

Protected  sites and 
species 

A.1.3.2.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  related  to protected areas as w ell as 
protected, rare, or endangered  species, including  their habitats 
and potential  habitats. 

The  Scheme  shall ensure that payments of fees are based on correct 
classification of volumes,  qualities,  species, and license  area. 

The  Scheme  shall ensure that payments of value-added  taxes are based 
on correct classification of volumes,  qualities,  species and license  area. 

Typically,  the legislation  includes regulations  related  to the size of felling 
areas, minimum  age and/or diameter  for felling  activities and elements 
that shall be preserved during felling.,  the establishment  of skidding  or 
hauling  trails, road construction, drainage  systems and bridges, planning 
and monitoring  of harvesting activities. In  other w ords, any legally  binding 
codes for harvesting practices shall be considered. 

It is recognised here that customary rights as recognised in international 
law  or the constitution  may in some  cases conflict w ith statutory law . 
There  should be differentiation  betw een activities conducted under 
customary law  and clear illegal  activities  conducted by outsiders w ith no 
customary or other rights. 
Note  that protected areas may include  protected cultural  sites, including 
sites w ith historical  monuments. 
It should  be clear that requirements  for the identification  of protected 
areas is conducted according to the legal  requirements. 

268 

 
 
 
 
 
 
 
 
 
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A.1.3.3 

Environmental 
requirements 

A.1.3.4 

Health  and safety 

A.1.3.2.2  Requirements  that ensure compliance  w ith legislation 
related  to protected areas and habitats,  shall include  that the 
identification  of protected areas is conducted according to the 
legal  requirements. 

A.1.3.3.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  related  to environmental  impact 
assessment in connection  w ith harvesting, acceptable levels of 
damage  and disturbance of soil resources, establishment  of buffer 
zones (e.g. along w atercourses, open areas, breeding  sites), 
maintenance  of retained  trees on felling sites, seasonal limitations 
on harvesting, and environmental  requirements  for forest 
machinery. 
A.1.3.4.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith Health  & Safety legislation. 

A.1.3.5 

Legal  employment 

A.1.3.4.2  The requirements  from point A.1.3.4.1 shall  also cover 
the activities of contractors or other personnel  operating  w ithin the 
area of the license area. 

A.1.3.5.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  for employment  of personnel  involved 
in harvesting (and in-forest processing) activities including  but not 
limited  to requirements  for: contracts and w orking permits, 
obligatory  insurances, certificates of competence  and other 
training  requirements,  and payment  of social and income  taxes.  
A.1.3.5.2  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  for minimum  w orking age and 
minimum  age for personnel involved  in hazardous w ork, legislation 
against forced and compulsory labour,  and discrimination  and 
legislation  allow ing f or freedom  of association. 

269 

NOTE: Topics such as pollution control, use of 
pesticides/herbicides, soil erosion, emissions to air/water etc., are 
included in this indicator if regulated in law in relation to harvesting 
activities. 

Health  and safety requirements  shall  be considered  relate to operations 
in the forest, including  in-forest processing (not office w ork, or activities 
not associated w ith actual forest operations).  Including  but not limited  to 
the use of personal  protective equipment  for persons involved in 
harvesting activities, use of safe felling and transport practices, 
establishment  of protection  zones around harvesting sites, and safety 
requirements  relating  to machinery  used, and legal  and safety 
requirements  in relation  to chemical  usage. 

Legal  employment  requirements  shall be considered relate to operations 
in the forest, including  in-forest processing (not office w ork, or activities 
not associated w ith actual forest operations). 

These are specified in the relevant ILO Conventions ratified by 
most countries. 

 
 
 
 
 
 
 
 
 
 
 
ANNEX 3 : CERTIFICATION SCHEME ASSESSMENT FRAMEWORK (SAF) 

A.1.3.5.3  The requirements  from point A.1.3.5.1 and A.1.3.5.2 
shall also cover the activities  of contractors or other personnel 
operating  w ithin the area of the license area. 

A.1.4 Third parties’ legal rights concerning use and tenure that are 
affected by timber harvesting 

A.1.4.1 

Customary  rights 

A.1.4.1.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith respect for customary tenure rights relevant to 
forest harvesting activities. 
A.1.4.1.2  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  relating  to sharing of benefits. 

A.1.4.2 

Free, Prior  and 
Informed  Consent 

A.1.4.2.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith the internationally  adopted  principles  of 'Free, 
Prior  and Informed  Consent'  in connection  w ith granting  rights to 
forest management. 

Although  the legal  right for FPIC  only refers to indigenous  and tribal 
people,  any certified company  should apply FPIC  in relation  to all affected 
local communities. 

A.1.4.3 

Indigenous  and 
traditional  peoples' 
rights 

A.1.4.3.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith national  legislation  and international  conventions 
ratified that respect the tenure rights of indigenous  and tribal 
peoples  to forest land  as w ell as their right to FPIC. 

Possible  aspects to consider are land tenure;  and the right to use certain 
forest-related resources or practice traditional  activities,  w here these may 
involve forest lands. 

A.1.5 Trade and customs, in so far as the forest sector is concerned 

A.1.5.1 

Classification  of 
species, quantities, 
qualities 

A.1.5.2 

Trade  and transport 

A.1.5.1.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  regulating  how  harvested material  is 
classified in terms  of species, Quantities  and qualities  in 
connection  w ith trade and transport.   
A.1.5.2.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith legally  required  trading permits  as w ell as legally 
required transport documents  that accompany  transport of w ood 
from forest operations. 

270 

Incorrect classification of harvested material  is a w ell-know n method  of 
reducing/avoiding  payment  of legally  prescribed taxes and fees. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
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A.1.5.3 

Offshore trading  and 
transfer pricing 

A.1.5.3.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  regulating  offshore trading and transfer 
pricing.  

Offshore trading  w ith related companies  placed in tax havens  – combined 
w ith the misuse  (abuse) of transfer pricing requirements  – is a w ell-known 
w ay to avoid payment  of legally  prescribed taxes and fees to the country 
of harvest. 
Many  countries have established  legislation  covering transfer pricing and 
offshore trading.  

A.1.5.4 

Customs  regulations 

A.1.5.5 

CITES 

A.1.5.6 

Legislation  requiring 
due diligence  / due 
care procedures 

A.1.5.4.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  covering areas such as export/import 
licenses, and product classification related  to customs (codes, 
quantities,  qualities  and species). 
A.1.5.5.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  related  to CITES  permits  (the 
Convention  on International  Trade in Endangered  Species of Wild 
Fauna  and Flora,  also know n as the Washington  Convention). 
A.1.5.6.1  The scheme  shall  include  requirements  that ensure 
compliance  w ith legislation  covering due diligence/due  care 
procedures, including  e.g. due diligence/due  care systems, 
declaration  obligations,  and /or the keeping  of trade related 
documents,  legislation  establishing  procedures to prevent trade in 
illegally  harvested timber  and products derived from such timber, 
etc. 

A.2  Legal requirements for supply  chain entities 

trade and customs, in so far as the forest sector is concerned. 

Requirements  should include  explicit  information  about the content of the 
scheme   – or make  explicit reference to requirements  as outlined  in the 
EUTR  - w hen the Certificate  Holder  is located in European  Union. 

This section shall apply to Certificate  Holders  - or other entities  subject to the normative  requirements  of the Scheme  (e.g. included  w ithin the scope of a certified due diligence 
system) - w ithin the Country  of Harvest. 

A.2.1. Legal registration 

A.2.1.1 

Legal  Registration 

A.2.1.1.1  The scheme  shall  include  requirements  that  ensure the 
existence of legal  business registration, and other relevant legally 
required licenses. 

Includes  legislation  regulating  the registration  of business 
(business/saw mill license,  operation  visas, tax payment  cards, approvals, 
etc.) and approval of scope of business and processing. 

271 

 
 
 
 
 
 
 
 
 
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A.2.2 Taxes and fees 

A.2.2.1 

Payment  of taxes, 
royalties and fees 

A2.2.1.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  covering payment  of all legally  required 
taxes, royalties and fees. 

The  Scheme  shall ensure that payments of the fees specified at point 
A2.1.1 are based on correct classification of volumes,  qualities,  species 
and license area. 

A.2.2.2 

Value-added  taxes 
and other sales taxes 

A2.2.2.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  covering different types of sales taxes 
that apply to the material  being  sold, including  selling  material  as 
grow ing forest (standing stock sales). 

The  Scheme  shall ensure that payments of value-added  taxes are based 
on correct classification of volumes,  qualities,  species and license  area. 

A.2.3 Trade and transport 

A.2.3.1 

Classification  of 
species, quantities, 
qualities 

A.2.3.2 

Trade  and transport 

A.2.3.3 

Offshore trading  and 
transfer pricing 

A.2.3.1.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  regulating  how  products are classified 
in terms of species, volumes  and qualities  in connection  w ith trade 
and transport.  
A.2.3.2.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith required  trading permits  as w ell as legally 
required transport documents  that accompany  transport of w ood. 
A.2.3.3.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  regulating  offshore trading.   

A.2.3.4 

Customs  regulations 

A.2.3.3.2  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  regulating  transfer pricing. 

A.2.3.4.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  covering areas such as export/import 
licenses, and product classification related  to customs (codes, 
quantities,  qualities  and species). 

272 

Incorrect classification of harvested material  is a w ell-know n method  of 
reducing/avoiding  payment  of legally  prescribed taxes and fees. 

Offshore trading  w ith related companies  placed in tax havens  – combined 
w ith the misuse  (abuse) of transfer pricing requirements  – is a w ell-known 
w ay to avoid payment  of legally  prescribed taxes and fees to the country 
of harvest. 
Many  countries have established  legislation  covering transfer pricing and 
offshore trading.  

It should  be noted  that only transfer pricing  and offshore trading, as far as  
they are legally  prohibited  in the country, can be included  here. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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A.2.3.5 

CITES 

A.2.3.6 

Legislation  requiring 
due diligence  / due 
care procedures 

A.2.3.5.1  The Scheme  shall include  requirements  that ensure 
compliance  w ith legislation  related  to CITES  permits  (the 
Convention  on International  Trade in Endangered  Species of Wild 
Fauna  and Flora,  also know n as the Washington  Convention). 
A.2.3.6.1  The scheme  shall include  requirements  that ensure 
compliance  w ith legislation  covering due diligence/due  care 
procedures, including  e.g. due diligence/due  care systems, 
declaration  obligations,  and /or the keeping  of trade related 
documents,  legislation  establishing  procedures to prevent trade in 
illegally  harvested timber  and products derived from such timber, 
etc. 

A.3  Requirements for material  control 

A.3.1 Material control  

A.3.1.1 

Material  origin  and 
identification 

A.3.1.1.1  The Scheme  shall require systematic processes to 
enable  the identification  of the country of harvest of the material, 
and w here applicable  to a higher  level of detail,  such as the sub-
national  region or concession level.   

Requirements  should include  explicit  information  about the content of the 
scheme   – or make  explicit reference to requirements  as outlined  in  the 
EUTR  - w hen the Certificate  Holder  is located in European  Union. 

Depending  on the System's approach to tracking and sourcing, there 
shall be CoC  systems in place to validate  claims  through  the supply 
chain (product certification systems) or to identify origin  of products to a 
level of detail  appropriate  to the level of risk identified  in the supply chain 
(risk-based Due  Diligence  Systems). 

The  Scheme  shall allow  EUTR  operators to clearly understand  the 
content of the product in relation  to the sources of origin. 

A.3.1.1.2  The Scheme  shall require systematic processes to 
enable  the identification  of the species included  in materials  or 
products included  in the scope of certification. 

The  names of the species of trees included  in all products in the scope 
of certification shall be available  and identified  by common  or trade 
name,  as w ell as scientific name  (genus and species). 

The  Scheme  shall allow  EUTR  operators to clearly understand  the 
content and the source of the product in relation  to the species. 

A.3.1.1.3  The Scheme  shall include  clear and effective measures 
to prevent material  from non-negligible  risk, unverified or 
potentially  illegal  sources from entering  the supply chain and 
mixed  w ith conforming  material. 

Systems to assure segregation  of materials  from unknow n or potentially 
illegal  sources  shall exist. This  may be done via different types of 
systems, but there shall be a w ell-documented  process to assure that 
materials  are not mixed  in cases w here several different material 

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categories (origins or risks) are handled. 

A.3.1.1.4  Where applicable,  the Scheme  shall require  the 
segregation  and tracking of certified (according to each individual 
claim  type) or verified legal  w ood along  the supply chain, using 
appropriate  inventory methods  and documented  controls w here 
necessary to ensure that risks of mixing  are identified,  managed 
and mitigated. 

Chain  of Custody system requirements  shall be formulated  and 
implemented  to assure that material  carrying the certification or 
verification claim  can be traced through processing, trade and transport. 

In  cases w hen the Certificate  Holder  is transforming  materials  into 
products, w ith a corresponding loss of w eight, volume  or number  of 
units, the Scheme  shall ensure yields are checked and verified. 

A.3.2 Recycled material  

A.3.2.1 

Waste material 

A.3.2.1.1  The Scheme  shall have a definition  of w aste  material 
w hich at least covers the definition  of w aste material  as described 
by the EUTR  Guidance  document. 

A.3.2.1.2  The Scheme  shall require systematic processes to 
enable  the identification  of w aste material  that has completed  its 
life cycle and to differentiate this material  from virgin or material 
that are by-products of a manufacturing  process w hich has not 
completed  its lifecycle as defined by the EUTR. 

A.3.2.1.3  The Scheme  shall include  clear and effective measures  to 
prevent “timber  products of a kind  covered by the Annex of the 
EUTR”,  produced from i) reclaimed  material  that has NOT  completed 
its lifecycle and w ould otherw ise have been discarded as w aste”, ii) 
unverified or iii) virgin material  (as defined by the EUTR)  from, 
entering  the supply chain.  

274 

The  Scheme  shall include  requirements  to ensure that “timber  products of a 
kind  covered by the Annex of the EUTR,  produced from material  that has 
completed  its lifecycle and w ould otherw ise have been discarded as w aste”  
included  in the scope of certification/verification  w ill not be mixed  w ith “by -
products of a manufacturing  process that involves material  w hich has not 
completed  its lifecycle”, unverified or virgin material  (as defined by the 
EUTR),  irrespective of the method  applied.  The requirements  below , 
therefore, do not require tracking of all reclaimed  material,  but allow  for risk-
based systems to manage  risk of contamination  w ith pre-consumer,  virgin or 
unknow n material. 
The  Scheme  shall allow  EUTR  operators to clearly understand  the 
content of the product in relation  to the content of the material  in relation 
to virgin and/or reclaimed  materials. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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A.4  General requirements for Certificate Holders 

A.4.1 

Conflict  resolution 

A.4.1.1 The  Scheme  shall  include requirements  that ensure that 
disputes are identified,  recorded and managed,  in a w ay that: 

i) ensures there is a transparent ongoing  process to address the 
issue 
ii) requires for the exclusion from the scope of the certificate 
situations  or areas or forest w here the legality  of tenure or 
management/harvesting  is not defined or is unclear and disputed. 
iii  ensures respect for legally-enshrined  customary tenure rights of 
local communities. 
A.4.1.2 The  scheme shall  include requirements  to ensure that 
certificate holders do not engage in corrupt practices related to illegal 
harvesting. 

Corruption   

A.5  Quality  and procedural requirements for Certificate Holders 

This indicator  relates to the robustness of the Certification  scheme.  It is 
intended  to determine  w hether requirements  are in place for CHs  to 
manage  risks that the legally  enshrined rights of third parties are not 
violated,  in areas of conflict or disputes. 

The  indicator asks if the Scheme  sets requirements  that apply to 
Certificate  Holders  themselves  – it is probably most  relevant to Forest 
management  and Controlled  Wood  Certificate Holders. 

A.5.1 

Internal  procedures 
for Certificate  Holders 

A.5.1.1 The  Scheme  shall  include requirements  for the Certificate 
Holders  to have in place  - and implement  - systems and 
procedures covering all requirements  of the Scheme. 

Scheme  requirements  are w ritten in measurable  terms, w ith guidance  on 
interpretation  if flexibility is required,  or to avoid ambiguity. 

A.5.2 

Qualification  and 
competence 

A.5.3 

Risk  based 
approaches to 
sourcing, trade or 
production 

A.5.1.2 The  Scheme  shall  include requirements  for the Certificate 
Holders  to regularly  review  the proper functioning of their ow n 
procedures. 
A.5.2.1 The  Scheme  shall  include requirements  that ensure that 
certified organisations  have personnel  w ith sufficient qualifications 
and competencies  to consistently and effectively implement 
Scheme  requirements. 
A.5.3.1 If the Scheme  includes an option  to implement  a risk based 
approach to sourcing non-certified material  (Due  Diligence  System), 
it shall: i) contain clear requirements  and ii) ensure consistent 
implementation  of the Due Diligence  System,  for all activities, 
materials  and suppliers included  w ithin the scope of the certification. 
A.5.3.2 The  Scheme  shall  include requirements  that ensure that 
w henever there is a change in the risk related to illegal  harvest, 

275 

Ensuring  the continued  implementation  of procedures is important  to the 
on-going  ability  of the organisation  to meet  certification requirements. 

This requirement  specifies the importance  of ensuring  that certified 
organisations  have qualified,  and competent  staff tasked w ith ensuring 
that the Scheme  requirements  are met  and enforced. 

Changes  in supply chains may  introduce new  risks and these should be 
dealt  w ith prior to including  products from these  new  supply chains in the 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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scope of the certification. 

trade or transport in a supply chain  – or a supply chain covered by 
a DDS  – the risk shall be assessed and mitigated  prior to shipping 
and sale. 
A.5.3.3 In  cases w here other 3rd party schemes  are recognised by 
the due diligence  system as meeting  specific due diligence 
requirements,  the scheme shall include  requirements  that ensure 
that it is clear: 
i) on w hat basis recognition  is made  and;   
ii) how  it is verified that other Schemes  ensure conformance w ith 
the specific due diligence  requirements. 
A.5.3.4 The  Scheme  shall  include requirements  to ensure that the 
DDS  comprises, at a minimum,  the follow ing elements:   
i) a quality management  system,   
ii) procedures for obtaining  access to information  pertinent  to the 
identification  of risk;   
iii) risk assessments, and   
iv) the implementation  of mitigations  measures w hen risks are 
identified. 

B. Requirements for Certification Bodies 

Scheme requirements for Certification Bodies shall be clear and unambiguous and allow the Scheme  owner to verify the level of conformance of each Certification 
Body to these requirements. 

B.1 General Certification Body  requirements 

B.1.1 

Competence  and 
qualifications 

B.1.1.1  The  Scheme  shall  have mechanisms  to ensure 
that auditors, and other relevant personnel  of the 
Certification  Body, are qualified  and competent  to 
evaluate  organisations’  compliance  w ith specific Scheme 
requirements. 

ISO  19011 definition  of competence:  (3.14) Demonstrated  personal 
attributes and demonstrated  ability  to apply know ledge and skills. 

ISEAL:  Auditors need to be able to use their judgement  to come  to a quick 
understanding  of a client’s  performance. Similarly,  individuals  responsible 
for audit  review s and decisions also need to be competent  in their 
responsibilities.  Among  the strategies to mitigate  the risks of non-

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conformity, having competent  auditors is one of the most important.  Basic 
requirements  for supporting  auditor competence  are included  in ISO17065 
(6.1.2) and in ISO  17021-2 Section  7 and Annexes A to D  in that document. 
The  System ow ner must take  ultimate  responsibility  for the competence  of 
auditors w orking in its assurance programme. 

This requirement  relates to the existence of clear requirements  for 
competence  and qualifications  of auditors involved  in evaluating  Scheme 
conformance, as w ell as personnel involved  in the certification decision-
making  process. 

The  requirement  includes ongoing  evaluation  of the CBs. 
This requirement  relates to the existence of clear requirements  for 
competence  and qualifications  of auditors involved  in evaluating  Scheme 
conformance, as w ell as personnel involved  in the certification  decision-
making  process. This is particularly relevant as due diligence  systems often 
include  a variety of legality  issues, rather than traceability. 

ISO  19011: Independence:  the basis for the impartiality  of the audit and 
objectivity  of the audit conclusions. Auditors should be independent  of the 
activity being audited  w herever practicable and should in all  cases act in a 
manner  that is free from bias and conflict of interest. For internal  audits, 
auditors should be independent  from the operating  managers  of the 
function being audited.  Auditors should maintain  objectivity throughout  the 
audit  process to ensure that the audit findings and conclusions are based 
only on the audit  evidence. 
ISEAL:   Scheme  systems [shall]  identify and mitigate  conflicts of interest 
throughout  their operations,  particularly in the assurance process and in 
governance. 

B.1.2 

Impartiality 

B.1.1.2  If the Scheme  includes an option  for the 
Certificate  Holder  to implement  a Due  Diligence  System, 
the scheme shall  ensure that  the auditors and other 
relevant personnel  of the Certification  Body are qualified 
and competent  to evaluate  organisations’  compliance 
w ith related  Scheme  requirements. 
B.1.2.1  The  scheme shall  include requirements  to ensure 
that auditors, and other  personnel relevant  to the 
conformance evaluation  of an organisation  shall be 
impartial  to the entity(-ies) under evaluation. 

B.1.2.2  The  Scheme  shall  include requirements  that 
ensure that the certification decision  process is;  
i) w ell defined and; 
ii) ensures that the decision on certification is conducted 
by positions/bodies  that are impartial  to the auditee. 

B.2 Certification Body  requirements for auditing  and certification 

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B.2.1 

Auditing  process 

B.2.2 

Stakeholder 
consultation 

ANNEX 3 : CERTIFICATION SCHEME ASSESSMENT FRAMEWORK (SAF) 

B.2.1.1  The  Scheme  shall  include requirements  that 
ensure that Certification  Bodies apply a documented 
methodology  for the evaluation  (assessments and audits) 
of clients.  
B.2.1.2  As a minimum,  this methodology  shall include 
procedures for the follow ing activities: 
i) Evaluation  of conformity of organisations  to the 
Schemes  (e.g. audit of sites, or inspection  of records or of 
self-assessment declarations); 
ii) Review  and certification decision; 
iii) Issuance  of a certificate; and 
iv)  Periodic  re-assessment. 

B.2.1.3  The  Scheme  shall  include requirements  that 
ensure that Certification  Bodies have in place  - and 
implement  – specific procedures for audits that include  at 
least the follow ing: 
i) frequency of audits;  (no longer than every 12 months); 
ii) requirements  for on-site (field) visits w here applicable; 
iii) sampling  protocol for audits (if applicable); 
iv) structure and competencies  of the audit team; 
v) the minimum  set of aspects that need  to be checked in 
every audit; 
vi) minimum  content of audit  reports, including  non-
conformances, clarification of scope, audit  process and 
evaluation  findings. 
vii) ability  for unannounced  or short-notice audits in case 
of substantiated  claims  or for other reasons.  
B.2.2.1  The  Scheme  shall  include mechanisms  to ensure 
that Certification  Bodies  conduct consultation  w ith 
stakeholder  (including  rights holders) as appropriate  in 

278 

Certification  procedures shall require field visits to applicant  forest 
management  units  BEFORE  a certificate can be issued. It  is likely  that 
simple  single (FM  and or CoC)  certificates require an on-site assessment 
prior to certificate issue. How ever, consider how  the Scheme  handles  other 
types of certification, including  for example,  group, multisite,  regional 
models  of certification. Does the Scheme  have mechanisms  to ensure all 
sites/members  are evaluated  prior to certificate issue?   

These requirements  relate directly to the procedures implemented  by the 
Certification  Bodies to conduct audits.  The  CB  should have in place 
procedures to ensure that they are follow ing the System requirements  for 
auditing.  The CB  therefore should have in place an efficient set of 
procedures to ensure consistent and uniform  implementation  of the 
System's audit  requirements. 
Regarding  point  ii) Consider  if any flexibility in relation  to f ield visits in the 
FM  context exists and if this is justified.  This is raised in relation  to the 
Covid19  situation,  although  other exceptions may exist. 

This indicator  relates to the robustness of the Certification  scheme.  It is 
intended  to capture requirements  of certification bodies and their ability  to 
detect potential  legal  non-compliances  via stakeholder  consultation 

 
 
 
 
 
 
 
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relation  to audits (only applicable  w here necessary** for 
evaluating  compliance  of certificate holders).  

processes.  

The  scheme shall ensure that the certification holder  has 
a proper stakeholder  consultation  process in place. 

**refers to specific areas of legal requirements  such as, but not limited  to, 
land tenure,  indigenous  and third parties’ rights, FPIC,  legal  requirements 
relating  to directly affected stakeholder  or neighbouring  communities…. 

The  scheme should require that the certification holder  has a good 
stakeholder  consultation  scheme  in place including  an early w arning/ 
grievance mechanism. 

Stakeholder  consultation  is required. For example,  this could be during  the 
evaluation  of compliance  to law s relating  to third parties' customary tenure 
rights to resources.  

Where required,  the time  and place of the consultation  and surveillance 
audits should be made  know n to stakeholders,  in a manner  that can be 
easily understood and accessed by all including  local communities  together 
w ith an culturally appropriate  invitation  to provide comments  about  the 
assessed organisation  (and its activities) to the CB  or accreditation  body. 

Sufficient consultation  w ith external stakeholders  w ill ensure that all 
relevant issues are identified  relating  to compliance  w ith the relevant 
requirements  of the standard   

The  follow ing guidance  indicates  strong stakeholder  consultation  by a CB: 
1 Where  a consultation  process is conducted, it shall be implemented 
adequate  to the size and scale of the CH’s  operation,  based on the 
follow ing: 
1.1 Stakeholder  identification:  the identification  of affected and interested 
stakeholders  and rights-holders in relation  to the forest management 
activities of the CH 
1.2. The CB  shall employ  effective means  to consult stakeholders,  using 
culturally  appropriate  consultation  techniques, and the language  spoken  by 
the recipients and inclusive of w omen, youth and other potentially 
marginalised  groups.   
NOTE:  Techniques  may include:  face to face meetings,  personal  contacts 

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by phone,  email,  or letter, notice published  in the national  and/or local press 
and on relevant w ebsites, local radio announcements,  or local customary 
notice boards. 
1.3. The CB  shall only exclude information  that is considered confidential. 
Stakeholders  shall be asked to provide their consent to the publication  of 
their comments. 
NOTE:  Examples  of consultation  techniques include:  arrangements  for 
individual  or group meetings,  structured interview  by telephone,  contact by 
mail  or email  w ith a request for w ritten comments  to a predetermined  set of 
specific questions. 
1.4 Stakeholder  feedback: Within  sixty (60) days after the end of the 
consultation  period,  the CB  shall respond to all stakeholders  w ho 
participated  in the consultation  process explaining  how  their comments 
w ere taken into account. 
1.5 Consultation  records: The  CB shall  maintain  records of the consultation 
process, including  a list of stakeholders  consulted and the comments 
provided, and evidence that the consultation  w as carried out in 
conformance w ith the requirements  of this standard. 
2 The  CB  shall prepare a summary  of the consultation  process, w hich shall 
include: 
a) The  areas for w hich the stakeholder  consultation  has been conducted 
(e.g. geo-reference data, state, province, supply unit); 
b) A list of the stakeholder  groups invited by the CB  to participate  in the 
consultation; 
c) A summary  of the stakeholder  comments  received. Comments  shall  only 
be published  w ith prior consent from the consulted stakeholder  and not 
associated w ith stakeholder  identifiable  information; 
d) A description of how  the CB  has taken  stakeholder  comments  into 
account, w ith a documented  justification  in each case. 

NOTE:  the interpretation  of stakeholders includes  rights-holders.  

B.2.2 

Corruption 

B.2.2.1  The  Scheme  shall  include mechanisms  to identify 
(or for the Certification  Body to do so) companies 
sanctioned  for engagement  in corrupt practices relevant 
to the forest sector. 

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C. Requirements for Certification Schemes 

C.1 Transparency 

C.1.1 

Transparency 

C.1.1.1 Scheme  requirements  for both Certificate  Holders  and 
Certification  Bodies shall be publicly  available  online.   

Transparency of the requirements  against  w hich certified organisations 
are evaluated  is a key feature of a certification System. 

C.1.1.2 Schemes  shall  include requirements  that ensure that 
relevant information  about the follow ing is freely available: 
i) development  and content of the Scheme; 
ii) how  the system is governed;   
ii) w ho is evaluated  and under w hat process;  
iv) impact  information  and the various w ays in w hich 
stakeholders  can engage. 

C.1.1.3 The  Scheme  shall  include requirements  that ensure that 
an up-to-date register of certified/verified organisations  is 
publicly  available. 

C.1.1.4 The  Scheme  shall  make  summaries  (or full reports) w ith 
relevant findings from audits available  on the internet. 

281 

This requirement  should make  it possible  to identify the certification 
status of named  companies  from their name  or certification code. 
Where these exist online,  registers in the form of searchable  databases 
should include:  names,  sizes and locations of all certified units, 
including  expiry dates, and certificate scope 

The  register should be updated  w ithin a timeframe  that is suitable  and 
meaningful  to the function of conducting  due diligence.  Preferably in 
real time  (typically maximum  24-hour turnaround in data updating). 

At the level of the Certificate  Holder,  the public summary  information 
should – as a minimum  – provide accurate and up-to-date  information 
on: 
i. Scope of the certificate w ith regards to a full list of sites, facilities or 
members  included. 
ii. Scope of the certificate w ith regards to those materials,  products or 
product groups that are included. 
iii.  The date of issue and ordinary date of termination/w ithdraw al  of the 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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certificate. 
iv. The  current status of validity of the certif icate (e.g. active, 
suspended, terminated).  Note:  should  include  a record of periods of 
suspension or termination. 
v. Rationale  for certification decision 
vi. Overview  of findings and description of non-conformances – 
particularly  those w hich relate to  legal  compliance. 

C.1.2 

Impartiality 

C.1.2.1 Procedures  for handling  complaints  and grievances shall 
be in place, made  publicly  available  and implemented.  The 
procedures shall  be clearly publicized,  making  it easy for 
stakeholders  to submit  comments  or complaints  w here 
applicable.   

In  detail,  the follow ing guidance  indicates  a strong complaints 
procedure: 
 

A documented  policy and procedure is developed  and implemented 
to handle comments  and complaints  from stakeholders  (including 
rights-holders) that are related  to any aspect of the Scheme, 
including  but not limited  to: i) Actions by CHs;  ii) Actions by the 
Accreditation Body (if applicable);… 
The  policy is made  public and there shall be no cost-implications  to 
the complainant. 
The  policy/procedure include  mechanisms  for: 
Acknow ledging receipt of complaints. 
Informing  stakeholders  of the complaint  procedure, and providing 
an initial  response to complainants  w ithin a time  period  of tw o (2) 
w eeks; 

 

 
 
 

  Conducting  a preliminary  assessment to determine  w hether 
evidence provided in a complaint  is or is not substantial; 

  Dialogue  w ith complainants  that aims  to solve complaints  assessed 

 

 

as substantial  before further actions are taken; 
Providing  information  on the steps to be taken  by the Scheme/CB 
in order to resolve the complaint,  as w ell as how  a precautionary 
approach w ill be used, shall be included  w ith the complaint; 
Implementing  a process (e.g. field verification and/or desk 
verification) to verify a complaint  assessed as substantial  by the 
Scheme  or CB, w ithin tw o (2) months  of its receipt; 

  Determining  the corrective action  to be taken by suppliers  and the 
means  to enforce its implementation,  if a complaint  has been 
assessed and verified as substantial.   
Verifying w hether corrective action has been taken  by suppliers 

 

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 

and w hether it is effective; 
Informing  the complainant,  the Certification  body, or other 
stakeholders,  as necessary. 

  Recording  and filing  all complaints  received and actions taken. 

C1.3 

Conflict  of interest 
and corruption 

C.1.3.1  The  Certification  Scheme  shall have in place 
requirements  at all  levels of the scheme (normative  requirements 
for CHs,  requirements  for CBs,  and for the scheme functioning) 
to manage  risks of corruption and conflict of interest. 

C.2 Scheme & standard  scope 

Note:  section C2 is not specifically referring to EUTR  issues but has been included  as part of the evaluation  of schemes to understand sche me  structures. 

C.2.1 

Standard  adaptation 
to the national  or 
subnational  context 

C.2.1.1 International  standards shall be adapted  to the national 
or subnational  context in w hich they are being implemented  and 
contain a list of applicable  legislation,  or the Scheme  shall 
enable/require  detailed  evaluation  of applicable  legislation  in a 
national  context. 

National  adaptation  of standards shall enable  assessment of 
compliance  to applicable  legislation.  This could be done by ensuring 
that lists of applicable  legislation  are available  from the Scheme  ow ner 
or be available  at the level of the Certificate  Holder. 

The  Scheme  shall ensure the applicable  law s that shall be complied 
w ith, are clearly specified and available  to the actors of the scheme 
(CBs and certificate holders). In  this regard it shall not be considered 
adequate  to include only a generic  statement  such as "all relevant law s 
and regulations  regarding  harvesting shall be met".  Either  the Scheme:   

 

 

determines  the list of legislation 

or requires the Certificate Holder  to do so. While  this second option 
is possibly less rigorous a process (a Certificate  Holder  may have 
few er resources to dedicate to building  such a list), at least the 
Certificate  Holder  and list are subject to evaluation  by the 
Certification  Body. So, there is some  assurance that applicable 
legislation  w ill not be missed  out.   

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Purpose  of this is to clarify that w henever contractors or outsourced 
entities  are used they are subject to the same  requirements  are the 
Certificate  Holder  (w here harvesting contractors in the forest or 
subcontracted processing). E.g.  an FM  CH  cannot subcontract 
harvesting and therefore avoid dealing  w ith harvesting law s. 
These requirements  refer to Scheme,  not the  Certificate  Holder  or 
operator. 

C.2.2 

International 
conventions and 
treaties 

C.2.2.1 The  Scheme  shall  include a list of the relevant 
international  conventions  to w hich the country has ratified, and 
w hich hold legal  force in the country. 

C.2.3 

Use of contractors 

C.2.3.1 The  requirements  for forest managers  and supply chain 
entities  shall be applicable  to the organisation’s  contractors and 
outsourcing facilities.   

C.2.4 

Endorsing  and 
recognising  of other 
Schemes  and 
systems 

C.2.4.1 If the Scheme  includes the recognition  or endorsement 
of other schemes or systems, it shall ensure coverage and 
consistent implementation  of EUTR  requirements  at all levels. 

C.3 Accreditation  and oversight 

C.3.1 

Accreditation 

C.3.1.1 The  Scheme  shall  include a system for accreditation  or 
oversight of Certification  Bodies to ensure that CBs  have in place 
the required procedures, capacity and competencies. 

C.3.1.2 The  Scheme  shall  ensure that the requirements  and 
process for accreditation  is publicly  available. 

C.3.1.3 The  Scheme  shall  make  publicly  available,  an up-to-date 
list and details of all accredited Certification  Bodies 

C.3.1.4 The  Accreditation Body shall have mechanisms  to ensure 
that relevant personnel  are qualified  and competent  to evaluate 
Certification  Body’s performance  in relation  to Scheme 
requirements. 

C.3.2 

Oversight mechanism 

C.3.2.1 The  Scheme  shall  ensure that the competence  and 
consistent performance of Certification  Bodies  is regularly 
evaluated.   

The  review  of performance should be used for subsequent follow  up 
and implementation  of corrective actions w here shortcomings  are 
identified. 

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Performance  shall employ  both desk-based AND  field 
approaches, including: 
i) Stakeholder  consultation 
ii) In-field  evaluation  of the performance  of the Certification  Body, 
w hether via on-site inspections of certified forests/ supply chain 
entities  or w itness audits of audit  personnel. 

C.3.2.2 The  Scheme  shall  include requirements  that ensure that 
the oversight mechanism  applies  a clear basis for:  
i) establishing  conformance;   
ii) raising corrective actions for non-conformance,  and ensuring 
closure w ithin timeframes  to avoid legal non-compliance,  and;  

iii) certification issue (or maintenance)  decision making. 

C.3.2.3 The  Scheme  shall  specify the approach  to be used in 
oversight, ensuring that the oversight mechanism  is independent 
of the Certification  Bodies being  assessed.  
C.3.2.4  The Scheme  shall  define the frequency of oversight or 
the procedure for determining  the frequency, applicable  in the 
case of risk-based oversight. 

ISEAL  assurance code: Oversight of Certification  Bodies  is typically 
managed  through an ISO  17011  accreditation  process, but can be 
accomplished  in other w ays, depending on the needs of the Schemes. 
For example,  a Schemes  system could employ  an independent 
assurance body to review  the System.  Alternatively,  a System  ow ner 
could arrange to oversee the w ork of Certification  Bodies  directly, 
recognising  that this model  provides less independence  and requires 
the ow ner to have the competencies  described in this section. Less 
formal Systems  could develop a scrutiny committee  of peers or 
stakeholders  to oversee the assurance process. In  all models  of 
oversight, independence  of the oversight mechanism  from the CB  is 
necessary. 
Regarding  C.3.2.2.ii)  consider the impact  of deadlines  for corrective 
actions on compliance  of ‘legal  requirements.  If in breach w ith EUTR, 
the law  may not allow  for long correction periods (e.g. 6months).  So it is 
relevant to know  for how  long a certified forest/operator is allow ed to 
sell certified products after an audit  has identified  ‘major’  shortcomings. 

The  procedures to conduct oversight of Certification  activities by the 
Scheme  ow ner, should  be developed  and implemented  in a w ay that 
ensures the impartiality  and independence  of the Scheme  ow ner. 

The  frequency of evaluations  should ideally  be at least every 12 months   

C.4.1.1 The  Scheme  shall  include requirements  that ensure that 
the Certification  Bodies  applies  a clear basis for:  
i) establishing  conformance;   
ii) raising corrective actions for non-compliance,  and;   
iii) certification decision  making. 

Clarity  in the performance threshold for organisations  seeking 
certification should be clear and unambiguous.  The  procedures for 
Certification  Bodies should ensure that a uniform  threshold is applied  to 
evaluate  conformance by auditees. 

This criterion  relates to the ability  of the Certification  Bodies  to make 
consistent decisions on conformance  by certificate holders. This is 
important  as clarity of conformance thresholds are necessary for the 

285 

C.4 Certification process 

C.4.1 

Compliance 
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client to understand the requirements  they are supposed to meet  and 
for the auditors to be able  to make  consistent decisions of conformance. 

Scheme  evaluation  of the Certificate  Holder  shall be performance-
based, or system/and  performance based. The requirements  for 
certification audits must  include assessment  of systems and 
documentation  together w ith verification of outcomes  adequate  to 
ensure that both system and performance requirements  in the standard 
are being  met. 

Applicable  certification standards have auditable  indicator(s) for each 
criterion or are w ritten in a w ay that they require an absolute  level of 
performance (as opposed to merely  relative improvement  or the 
existence of a process)  

C.4.1.2 The  Scheme  requirements  for establishing  conformance 
should enable  comparison  w ith the definition  of negligible  and 
non-negligible  risk as outlined  in the EUTR  and associated 
guides.  

C.4.1.3 The  Scheme  shall  include requirements  that ensure that 
the above requirements  are in line w ith the requirements  of the 
EUTR  to prohibit  illegal  material  or material  w ith a non-negligible 
risk category being  placed on the EU  market. 
C.4.1.4 the Scheme  shall include  requirements  that ensure that 
the decision process to certify organisations,  or maintain 
certification of CHs,  is free from conflict of interest and includes 
checks and balances. 

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Annex 4: Scheme Assessment  Report 
Programme for the Endorsement of Forest 
Certification (PEFC) 

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Table of Contents 

Summary ................................................................................................................... 289 
Introduction ................................................................................................................ 295 
Acronyms ................................................................................................................... 296 
Glossary of terms used, specific to this report ............................................................. 296 
1.  Overview of Certification Scheme ........................................................................ 297 
2.  About this report ................................................................................................. 303 
2.1. Report Structure ............................................................................................... 303 
2.2. Overview of the certification standards used for this analysis ............................ 304 
3.  Evaluation methodology ...................................................................................... 305 
4.  Overview of findings............................................................................................ 306 
5.  Evaluation........................................................................................................... 310 
A. Requirements for Certificate Holders................................................................... 310 
A.1a Legal Requirements at the forest level - Forest management certification . 310 
A.1b Legal Requirements at the forest level - Input from non-PEFC certified forest
 ....................................................................................................................... 344 
A.2a Legal requirements for supply chain entities - Certificate Holders ............. 370 
A.2b Legal requirements for supply chain entities - Non-PEFC certified supply 
chains ............................................................................................................. 378 
A.3 Requirements for material control .............................................................. 391 
A.4 General requirements for Certificate Holders ............................................. 406 
A.5 Quality and procedural requirements for Certificate Holders ....................... 410 
B. Requirements for Certification Bodies ................................................................. 428 
B.1 General Certification Body requirements.................................................... 428 
B.2 Certification Body requirements for auditing and certification ...................... 437 
C. Requirements for Certification Schemes ............................................................. 446 
C.1 Transparency............................................................................................ 446 
C.2 Scheme & standard scope ........................................................................ 457 
C.3 Accreditation and oversight ....................................................................... 463 
C.4 Certification process ................................................................................. 474 

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Summary  

The Programme for the Endorsement of Forest Certification (PEFC) is one of the World’s 
largest voluntary forest certification schemes with over 320 million certified hectares and 
27,000 certified supply chain entities. It is the largest forest certificatio n scheme in terms 
of certified forest area. 

PEFC  operates  a  third-party  certification  system,  whereby  it  sets  the  normative  and 
benchmark standards together with guidance and procedural documents. The scheme 
has support from International Accreditation Forum (IAF) in recognizing bodies allowed to 
accredit  the  certification  bodies.  In  addition  to  the  accreditation  process,  certification 
bodies shall be notified by PEFC88 before issuing certificates. Evaluations of Certificate 
holders include field audits. 

The scheme recognises national forest certification system standards. The recognition 
process  and  incorporation  into  the  PEFC  family  of  new  national  forest  certification 
systems is known as ‘endorsement’ and includes assessments made by an independent 
assessor and recognition of PEFC Council. After five years of the approval date, endorsed 
systems shall initiate a standard review process in relation to their standards.  

PEFC National Governing Bodies (NGBs) play multiple roles in assuring the credibility of a 
system  in  a  specific  country.  NGBs  conduct  notification  of  certification  bodies  (CBs), 
without that CBs cannot issue PEFC FM certificates. Simultaneously, NGBs have a role in 
forest certification system setting, appointing a standardizing body or acting th emselves 
as a standardizing body and responsible for maintaining the forest certification system. At 
the international level, NGBs are part of PEFC Council Board together with International 
Stackeholders,  accepting  new  National  Governing  Bodies  and  changes   of  Scheme, 
including normative and Benchmark standards. Similarly, Accreditation Bodies are part of 
IAF, involved in accepting new Accreditation Bodies.  

Certification Bodies conduct assessments and issue certificates to organisations. Various 
organisations can apply for certification at the forest or supply chain level, from single to 
groups  of  forestry  companies;  smallholders  and  community  groups;  from  sawmills, 
traders, manufacturers and printers.  

PEFC operates two certification approaches which apply to forests: i) certification of forest 
– and forest management – organisations and supply-chain entities; and ii) certification of 
a risk-based due-diligence mechanism for managing non-PEFC-certified material inputs 
into PEFC-certified products. 

PEFC's Forest Management (FM) standard is a benchmark standard based on 6 criteria 
(chapter 8) and 94 requirements. Certification at the forest level is based on standards 
developed by the national forest certification system, which conform to the set of rules and 
requirements  defined  by  PEFC  International. 89  The  development  of  PEFC  standards 
includes consultation with stakeholders.  

PEFC’s Chain of Custody (CoC) standard is a global standard, applied as-is, to all supply 
chain  entities  wishing  to  sell  PEFC  certified  products  with  a  PEFC  claim.  PEFC  has 
integrated a due diligence mechanism into its CoC standard to allow the mixing of PEF C -
certified material and non-PEFC-certified material in the manufacture of PEFC-certified 
products,  whilst  at  the  same  time  avoiding  raw  material  from  controversial  sources. 
PEFC’s definition of controversial sources includes illegally harvested and traded wood.    

88 PEFC International or National Governing Body 
89 PEFC ST 1003:2018 Sustainable Forest Management, is the latest benchmark standard developed by PEFC International 
to which national standards are independently assessed against and must conform to, in order to become PEFC endorsed. 

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Finally, the system provides for the inclusion of recycled wood material via the Chain of 
Custody standard. 

Overall findings  

PEFC is a fully-developed certification scheme, which includes many of the processes 
and elements that would be expected of such a global certification scheme. Across the 
three main subject areas of this study – requirements for Certificate Holders, Certification 
Bodies  and  for  the Scheme itself  – PEFC was assessed as partially covered for each 
broad  topic  area  that  was  evaluated.  In  other  words,  at  the  indicator  level,  study 
conclusions were often a mixture of alignment with the scheme assessment framewo rk 
(coverage) but also partial coverage and sometimes no coverage. 

Out of the 84 indicators of the scheme assessment framework evaluated within the study, 
30  were  concluded  as  Covered,  39  as  Partially  Covered  and  14  as  Not  Covered.  1 
indicators were concluded as Not Applicable.  

It should be noted that this reflects an evaluation that has only considered the normative 
and guidance documents relevant to the scheme, along with the websites of FSC and 
ASI. Consideration of impact studies and other information relating to the performance of 
certification  schemes  in  general,  are  included  in  a  Meta-report  which brings together 
findings in relation to all five schemes. 

Legal requirements at the forest level 

The  first  part  of  this  study  addressed  legal  requirements at the forest level for forest 
management certification, evaluating how PEFC ensures that Certificate Holders comply 
with all applicable legislation. The study concluded that legal requirements at the forest 
level are mostly Covered by PEFC Forest Management standard (PEFC ST 1003: 2018), 
and  Partially  Covered  as  far  as  the  Controlled  Sources requirements within the COC 
standard (PEFC ST 2002: 2020) are concerned.  

Of the 27 indicators assessed, 15 were evaluated as covered, 9 were partially covered 
and 3 are not covered for PEFC Forest Management. Across the same 27 indicators in 
the case of Controlled Sources requirements, only 6 were evaluated as Covered, 15 as 
partially covered and 6 as not covered.  In both cases, many of the identified gaps related 
to  ambiguities,  omissions,  or  cases  where  no  clear  reference  was made within PEFC 
standard requirements to an aspect of forest legality included in the framework.  

For  Controlled  Sources,  however,  all  indicators  related  to  trade and customs are not 
covered.  The  definition  of  controversial  sources  does  not  appear  to  cover  legal 
compliance in relation to trade, transport and customs 90, for non-certified forest entities 
included  within  the  due  diligence  requirements  of  the  scheme.  This  represents  a 
significant gap within the scheme. 

PEFC requires that the international Sustainability benchmark standard is adapted to the 
national  context  in  which  it  is  being  implemented  by  forest  organisation.  On  most 
occasions, the four national forest certification standard evaluations conducted (for Brazil, 
China,  Russia  and  Romania)  corroborated  the  findings  of  the  international  level 
evaluation. Although, it must be noted that these standards had not yet been updated to 
the current version of the international Sustainable Forest Management (FM) benchmark 
standard (PEFC ST 1003: 2018). 

90 Note: in the context of the EUTR, trade, transport and customs laws are only relevant within the country of harvest.  

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In fact, as of the date of this report, no countries have yet an approved national standard 
that  has  been  updated  from  the  previous  version  of  the  international FM benchmark 
standard (PEFC ST 1003: 2010) to the current version. At the same time, two approved 
standards  (Brazil  and  Ireland)  are  still  developed  based  on  the  initial  version  of  the 
standard, developed in 1998  - “Pan European Operational Level Guidelines”, although 
both  schemes  are  currently  in  a  process  of  review  for  compliance  with  PEFC  ST 
1003:2018. However, the delays in updating all national FM standards to meet updated 
benchmarks, represents a significant gap in the PEFC system. 

There are streamlined certification procedures for Group Certification. T his approach to 
certification was also evaluated within the scope of this study and evaluated as deemed 
not to impact the integrity of the system. 

Legal requirements at the supply chain level  

Significant gaps in the PEFC system were found at the supply chain level, where several 
legal requirements covering trade and transport in so far as the forest sector is concerned 
(applicable to the country of harvest, in the context of this study) were not covered or only 
partially covered. 

Firstly,  the  study  addressed  requirements  for  legal  compliance  by  Certificate holders 
which are supply chain entities, focussing on the PEFC CoC standard. This standard is  
applicable  to  all  certified  supply  chain  entities  within  the  PEFC  system.  Of  the  10 
indicators evaluated, 3 were concluded as Partially Covered, while 7 as Not Covered. This 
is considered a significant gap within the PEFC system. 

While the normative requirements of the accreditation standard require Certificate bodies 
to collect information related to the legal status of the certificate holder, the requirement 
for legal business registration and the holding of other relevant legally required licenses is 
not made a requirement of Certificate Holders within the CoC standard. While indicators 
relating  to  CITES  and  due  diligence  were  assessed  as  partially  covered,  Certificate 
holders  are  not  required  to  comply  with  legislation  concerning  taxes  and  fees,  how 
products are classified, trading permits, offshore trading, transfer pricing, export/import 
licenses. 

There  is  a  second  major  gap  within  the  due  diligence  requirements  for  non -certified 
material  entering  the  PEFC  system  that  form  part  of  the  PEFC  Controlled  Source 
requirements for supply-chain entities. Here, the PEFC due diligence process does not 
include  the  evaluation  of  risks  of  legal  non-compliance  in  relation  to:  legal  business 
registration; trade, transport and customs, or the payment of taxes and fees  within the 
country of origin.  As a result, of the 10 indicators within this principle, all were evaluated 
as Not Covered. 

Material control 

Via  the  PEFC  CoC  standard  and  other  normative  requirements,  the  PEFC  system 
maintains  a  system  of  material  control,  tracking  and traceability, similar to other fully-
developed certification schemes.  

In  the  case  of  material  derived  from  Controlled  Sources,  the  control  system includes 
systematic processes to enable the identification of the country of harvest of the mat erial 
as well as the species included in certified materials or products. However, where only 
PEFC-certified products are sourced, the implementation of a Due Diligence system to 
obtain information related to the country of harvest and species is voluntary  only. 

PEFC standard requirement includes clear and effective measures to prevent material 
from non-negligible risk, unverified or potentially illegal sources from entering the supply 
chain.  However,  the  CoC  system  does  not  include  any validation of certif ied volumes 

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transferred from sellers to purchasers vertically up and down supply chains, meaning that 
risks  of  errors - or even fraudulent activity  – exist in relation to the volumes of PEFC-
certified products sold along supply chains. However, it is also not a concern specific to 
PEFC, but many of the schemes evaluated within this study.  

A  further  gap  to  be  noted  regards  reclaimed  timber.  PEFC  descriptions  of  recycled 
material described in Terms and definition of the COC standard (PEFC ST 2002: 2020), 
do not entirely align with the definition of waste material as defined in – and excluded from 
the requirements of  – the EU Timber Regulation and associated guidance documents. 
This discrepancy between PEFC and EU definitions means material might enter the PEFC 
system without the required due diligence. 

Other requirements for certificate holders 

Requirements for CoC certificate holders related to conflict resolution  – specifically that 
disputes are identified, recorded and managed in a robust and transparent  way – are 
covered. However, conflict resolution is assessed as partially covered for FM certification 
because standard requirements do not extend to requiring the exclusion from the scope of 
a certificate situations or forest areas where the legality of tenure or management is not 
defined, unclear or disputed. certificate holders do not engage in corrupt practices related 
to illegal harvesting. In the case of requirements that certificate holders do not engage in 
corrupt practices related to illegal harvesting, this is addressed within the PEFC system 
for FM certification. For CoC certification, there is no requirement that certificate holders 
do not engage in corrupt practices related to illegal harvesting. 

General  requirements  for  certificate  holders  related  to  Quality  and  procedural 
requirements are mostly addressed within the PEFC system. Documented systems and 
procedures  covering  all  requirements  of  the  relevant standards are required both for 
Forest Management and Chain of Custody certification. At the same time, PEFC requires 
that  certified  organisations  have  personnel  with  sufficient  competencies  to implement 
Scheme requirements.  

In relation to requirements for risk-based approaches to sourcing (Due Diligence Systems) 
for non-certified material, PEFC was concluded as partially covering the quality indicators. 
Normative  requirements  are  described for the consistent implementation of a DDS for 
sourcing non-certified material. Whenever there is a change in the risk profile for a supply 
chain covered by a DDS, the risk shall be assessed and mitigated prior to shipping and 
sale.  

However,  some  important  issues  arise  elsewhere.  Due  diligence  procedures  are 
described in Annex 1 of the PEFC CoC standard. However, there are no requirements or 
guidance  on  what  basis  –  or  how  -  the schemes shall be evaluated by the certificate 
holder other than that they cover the activities included in the term controversial sources 
and  are  covered  by  a  supported  by  third-party  certification.  At  the  same  time,  DDS 
procedures defined in the COC standard are such that it is not clear that the system will 
always capture risks present within supply-chains.  

Requirements for Certification Bodies 

Quality  requirements  for  Certification  Bodies  were generally evaluated as Covered (6 
indicators),  based  on  PEFC  normative  requirements,  with  some  notable  exceptions 
(resulting in 2 Partially Covered indicators, 1 not covered).  

Covered indicators concerned Certification Bodies having mechanisms to ensure auditor 
(and other relevant personnel of the Certification Body) qualifications and competence, as 
well as to ensure impartiality in the conformance evaluation process. PEFC ensures that 
Certification Bodies have and apply a documented methodology and procedures for the 
evaluation of conformity of organisations and issuance of certificates. 

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Important indicators that are partially covered are related to the frequency of audits, as 
these  may  exceed  12  months  in  the  case  of  CoC  certification.  In  the  case  of  forest 
management, it is not clear if standards consistently includes the ability for unannounced 
or short-notice audits in case of substantiated claims or for other reasons.   

At the same time, stakeholder consultation is concluded as partially covered. For forest 
management,  not all national schemes include stakeholder consultation for evaluating 
compliance of certificate holders. In the case of Chain of custody, there is no requirement 
to conduct stakeholder consultation. 1 indicator is partially covered. 

One important gap was identified: there are no mechanisms or formal processes for the 
scheme  -  or  requirements  for  Certification  Body  -  to  proactively  identify  companies 
sanctioned for engagement in corrupt practices relevant to the forest sector.  

Other requirements of the Certification scheme 

In  relation  to  scheme  transparency,  1  indicator  was  assessed  as  covered.  Of  the  4 
indicators  evaluatued  as  partially  covered  and  1  not  covered,  some  of  these  cover 
important issues:  

Most of the procedures and standards related to the Scheme are publicly a vailable on 
internet.  However,  some  procedures  related  to  the  accreditation  process  and  impact 
information are not publicly available. 

A register of certified/verified organisations is publicly available. The database allows a 
user to identify the certification status of named companies from their name or certification 
code. However, the database does not include information about certified forest areas or 
locations within the scope of the certificate. At the same time, the Scheme is not requiring 
that summary audit reports are publicly available on the internet. 

In  relation  to issues of accreditation and oversight, most indicators were evaluated as 
covered  based  on  the  normative  requirements.  PEFC  has  in  place  a  system  for  the 
accreditation and oversight of Certification Bodies to ensure that CBs have in place the 
required  procedures,  capacity  and  competencies.  Some  of  the  procedures  used  for 
accreditation are publicly available, however not all of them. For example, standards used 
in  the  assessment  of  Accreditation  or  Certification  Bodies applicants, are not publicly 
available. 

The  PEFC  system  includes  an  oversight  mechanism  which  is  independent  of  the 
Certification Bodies and includes requirements to ensure the frequency of oversight or a 
procedure for determining the frequency. However, while the PEFC system includes in 
field evaluation of Certification bodies, stakeholder consultation does not form part of the 
accreditation or evaluation process.  

PEFC ensures that the oversight mechanism for Certificate Holders applies a clear basis 
for establishing conformance, raising corrective actions for non -conformance, ensuring 
closure within defined timeframes, and certification issue/maintenance decision making.  

Certification  bodies  may  issue  corrective  actions  to  certificate  holders  for  non-
conforma)nces (up to 3 months for major non-conformities and up to 12 months for minor 
non-conformities, according to different audit types) acros. This approach ensures that 
non-conformances in relation to PEFC requirements are addressed systematically and 
within a specific timeframe. It is also an approach similar to that employed by almost all 
forest certification schemes. 

In the case of surveillance and re-certification audits, the timeframes permitted to address 
and  close  non-conformities  are  such  that  there  is  a  possible  risk that illegal (or non -
negligible) wood products may enter the EU market without mitigation having taken place. 
This could occur if a non-conformity which represented an infringement of legislation was 

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issued to a certificate holder.  It is possible the non-conformity would not be addressed for 
a period of up to 3 or 12 months, during which production or trade was still taking place.  

This  PEFC  system  includes  requirements  to  develop  procedures,  capacity   and 
competencies. The list and details of all accredited Certification Bodies are up to date and 
publicly available and PEFC International includes a system to ensure qualification and 
competence of National Accreditation Bodies. 

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Introduction  

The  objective  of  the  Study is to create a resource of knowledge and reference for all 
interested and concerned parties in the forest- and wood-based products sector. It should 
help  Competent  Authorities,  Operators  and  Monitoring  Organisations  covered  by  the 
EUTR  in  their  understanding  of potential benefits and shortcomings of certification, in 
particular  in  the  context  of  the  implementation  of  the EUTR. As such, one part of the 
overall  objectives  is  to  create  an  overview  of  existing  certificates,  third -party  verified 
schemes and certifying bodies issuing certificates with regard to forests and wood -based 
products  and to evaluate their respective strengths and weaknesses in respect to the 
EUTR obligations. This should, in turn, encourage stronger standards and transparency of 
certification and third part verification schemes. 

It should be underlined that it is NOT the intention of the study to create a compliance 
checklist  of  certification  schemes.  The  EUTR  continues  to  recognise  third  party 
certification as an important potential tool for risk assessment and risk mitigation, but does 
not  recognise  certification  as  proof  of  compliance. This will not change based on this 
study. 

As part of the above objective, this framework has been developed to allow evaluation of 
the  differences  and  uniformities  between  certificates  and certifying bodies. It includes 
requirements  to  assess  to  which  degree different forest certification schemes provide 
assurance of low (negligible) risk of ‘legal non-compliance’ of certified material.  

The  Framework  aligns  with  the  definitions  and  approach  to  certification  schemes  as 
described within the EU Timber Regulation (No. 995/2010) and the associated Guidance 
Document,  along  with  additional  requirements  for  the  use  of  third  party  certification 
schemes as outlined in the Commission implementing Regulation (EU) No 607/2012 and 
specifically Article 4 in the Commission Implementing Regulation (EU) No 607/2012.  

The Framework takes into account verifiers for Article 6 in the EUTR, and documentation 
for  Article  4  of  the  Implementing  Regulation,  as  well  as  a  wide  array  of sustainability 
standards and benchmarks used in the areas of forest and wood -based products, among 
other resources identified under References. 

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Acronyms 

PEFC   

Programme for the Endorsement of Forest Certification 

CoC 

FM 

Chain of Custody 

Forest Management 

Cerflor  

Brazilian Forest Certification Programme 

SFI 

SAR 

SAF 

EU 

Sustainable Forest Initiative 

Scheme Assessment Report 

Scheme Assessment Framework 

European Union 

EUTR   

Regulation (EU) No 995/2010 of the European Parliament 

Glossary of terms used, specific to this report 

International  level  –  Normative  and  guidance  documents,  systems and procedures 
developed by PEFC international, and relevant to the functioning of the whole scheme.  

National level – Normative and guidance documents, systems and procedures developed 
by each PEFC national member, that is relevant to the specific country or region.  

National  scheme   –  National  PEFC  member  with  a certification scheme endorsed by 
PEFC in the country. 

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29.  Overview of Certification Scheme 

Background 

The Programme for the Endorsement of Forest Certification (PEFC) is an international 
non-profit and non-governmental organization promoting responsible forest management 
around the World. With more than 320 million hectares of certified forest, this is the largest 
forest certification scheme in terms of forest certified area.  

The PEFC program was founded in 1999 (initially as Pan-European Forest Certification)  
in response to the specific requirements of small and family forest owners. The scheme 
acts as an umbrella organization endorsing national forest certification systems based on 
a defined process, where multiple external resources are used.  

National  forest  certification  systems  undergo  third-party  assessment  against  PEFC's 
Sustainability  Benchmarks 
international 
requirements.  They  become  PEFC  national  members,  once  they  have  demonstrated 
conformance  with  PEFC  international  requirements  and  are  approved  by  the  PEFC 
General Assembly.  PEFC national members generally maintain their own names 91.  

to  ensure  consistency  with 

the  PEFC 

PEFC is the membership associated organisation, with the vast majority of international 
members  being  related  to  the  commercial  forest  sector.  Currently  has  56  national 
members, but some members92, have not developed a certification system and/or this may 
not yet have been endorsed by PEFC International. Currently PEFC has endorsed 48 
national forest certification systems (herein referred to as national schemes).  

Global Governance 

PEFC International is registered in Geneva, Switzerland and is the entity responsible for 
developing and maintaining the normative framework; PEFC brand; and trademark. PEFC 
International  provides services to partners and stakeholders around the  world. This is 
supplemented by the work of national members, which provide services to partners and 
constituents at local level.  

International Accreditation Forum (IAF) is the sole entity providing recognition of bodies 
allowed to accredit the certification bodies. It was founded in 1993 with the purpose of 
operating  a  program  for  the  accreditation  of  organisations  working  with  conformity 
assessment, to ensure that certification of products, processes or services in one region 
or  country  should  be  accepted  in  other  regions  or  countries.  PEFC  is an associated 
member of the IAF.  

The PEFC certification system operates as a third-party system where PEFC International 
is  responsible  for  the  development,  maintenance  and  interpretation  of  the  PEFC 
normative  framework.  Certification  Bodies  evaluate  the  conformity  of  organisations 
applying for – or already holding – certification, against the requirements of the normative 
framework.  These  Certification  Bodies  must  be  accredited  and  notified  to  conduct 
evaluations  and  issue  PEFC  certificates.  As  the  certification  bodies  evaluate  the 
conformity of organisations, the accreditation bodies check that certification bodies follow 
the  relevant  accreditation  requirements.  Notification  could  be  carried  out  by  PEFC 
International or a National Governing Body (NGB) and allows certification bodies to issue 
PEFC certificates. All NGBs are also Accreditation bodies. 

91 Example: Certflor in Brazil or SFI in the USA and Canada 
92 Example: PAFC Congo 

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Scheme endorsement process 

PEFC is an umbrella of endorsed national forest certification systems.  

National  standards  are  developed  by  a standardizing body, which can be the NGB or 
another entity. When the national forest certification system is ready, an application for 
endorsement  and  mutual  recognition is submitted to PEFC International. According to  
PEFC, the process usually takes about 22 weeks.  

An external assessment is made, with PEFC International is involved in the appointment 
of the evaluating organisation. Based on the recommendation from external assessment, 
the PEFC Board of Directors recommends the endorsement of the system to the PEFC 
General  Assembly.  The  PEFC  General  Assembly  then  decides  on  the  endorsement 
following the PEFC Council Statutes. When endorsed, the national system becomes part 
of the PEFC umbrella. After endorsement, multiple steps are defined for maintaining the 
endorsement.  Endorsed systems shall start a review process after five years from the 
approval date. 

To  ensure  that  national  standards  are  developed  according  to  PEFC  International 
requirements,  the  standardizing  body  follows  the “PEFC Sustainability benchmark” as 
defined in PEFC GD 1007. According to the PEFC Sustainability benchmark, a national 
standard is required to demonstrate conformance with one or more of the following:  

–  Sustainable Forest Management standard  - PEFC ST 1003, Sustainable Forest 

Management – Requirements; 

–  Standard setting procedures - PEFC ST 1001, Standard Setting – Requirements; 
–  Group requirements where group certification of forest management is part of the 
system - PEFC ST 1002, Group Forest Management Certification Requirements; 
–  Chain of custody standard  - PEFC ST 2002,  Chain of Custody of Forest Based 

Products – Requirements; 

–  system’s administrative procedures: 

o 

o 

for  notification  of  certification  bodies: PEFC GD 1004,  Administration of 
PEFC scheme, chapter 5; 
for PEFC logo licensing: PEFC GD 1004, Administration of PEFC scheme , 
chapter 6; 
for complaints and dispute resolution: PEFC GD 1004,  Administration of 
PEFC scheme, chapter 8; 
–  procedures for certification and accreditation: 

o 

o  TD Annex 6 (PEFC ST 1004), Certification and Accreditation Procedures, 

for forest management certification; 
o  PEFC  ST  2003,  Requirements 

for  Certification  Bodies  operating 
Certification against the PEFC International Chain of Custody Standard, for 
chain of custody certification. 

Accreditation and Notification Process 

Organisations  seeking  to  certify  against  the  PEFC  certification  standards  shall  be 
accredited and notified. Accreditation is carried out by an accreditation body, signatory of 
the  Multilateral  Recognition  Arrangement  (MLA)  for  product  certification.  Multilateral 
Recognition  Arrangement  (MLA)  for  product  certification  is  managed  by  International 
Accreditation  Forum  (IAF).  Notification  is  done  by  PEFC  International  or  National 
Governing Body (NGB).  

 

In  the  case  that  there  is  no  national  PEFC  member  in  a  specific  country, 
notification is conducted by PEFC International, and accreditation could be done 
by  any  member  of  IAF,  signatory  of  MLA.  IAF  contains  more  than  100 
accreditation bodies that can support this process.  

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 

In  the  case  that a national member is active in a country, then notification and 
accreditation  must  be  done  by  the  NGB,  as  it  is  mandatory  for  NGB  to  be  a 
member  of  IAF  –  MLA.  Once  approved,  the  Certification Body will enter into a 
notification agreement with PEFC. Accreditation shall be issued against ISO/IEC 
17065:2021, and PEFC ST 2002 and PEFC ST 2003 shall be followed.  

PEFC  standards  do  not  require  annual  audits  by  accreditation  body/NGB/PEFC 
International of certification bodies. It might be required by IAF, based on ISO standards, 
but these procedures are not publicly available. According to standards developed by 
PEFC, documented procedures and internal audits are developed by each certification 
body. The results of internal audits are provided to PEFC International or the NGB.  

Currently,  the  number  of  certification  bodies  globally  accredited  to  audit  to  PEFC 
standards is 144. These Certification Bodies have varying scopes for their accreditation, 
differing by technical and geographical scope. 

Certification Standards 

The two main types of certification within the PEFC system are Forest Management (F M) 
and Chain of Custody (CoC).  

Forest Management  

PEFC Forest Management certification is based on the PEFC benchmark standard with 
six operation criteria, which intend to set out best practices for forest management and are 
applicable  worldwide (see Box 1). Each principle has a number of indicators providing 
practical ways to ascertain if the criterion is being followed. Criteria of chapter 8, togeth er 
with other chapters of PEFC ST 1003: 2018 are the backstone of developing national 
standards. 

PEFC  forest  management  certification  is  solely  available  in  countries  with  national 
schemes and all national standards shall be endorsed by PEFC (as described in Scheme 
endorsement process). Information available on the PEFC website shows that, to date, no 
country has an approved national standard which has been updated to conform with the 
latest PEFC -  Sustainable Forest Management standard, PEFC ST 1003: 2018.  

Box 1 Criterion of Chapter 8 - PEFC ST 1003: 2018 

Criterion  1: Maintenance  or appropriate  enhancement  of forest resources and their contribution  to the global 
carbon cycle 
Criterion  2: Maintenance  of forest ecosystem health  and vitality  
Criterion  3: Maintenance  and encouragement  of productive functions of forests (w ood and non-w ood) 
Criterion  4: Maintenance,  conservation and appropriate  enhancement  of  
biological  diversity in forest ecosystems 
Criterion  5: Maintenance  or appropriate  enhancement  of protective functions in forest management  (notably 
soil and w ater) 
Criterion  6: Maintenance  or appropriate  enhancement  of socio-economic   
functions and conditions 

Chain of custody 

PEFC Chain of Custody certification applies to manufacturers, processors and traders of 
PEFC certified forest products, and ensures that materials and products which are sold 
with PEFC claims originate from certified forests, controlled sources, reclaimed materials, 
or a mixture of these. It allows certified companies to make sales claims in relation to their 
PEFC products. 

The current version of the standard is PEFC ST 2002: 2020 Chain of Custody of F orest 
and Tree Based Products – Requirements. This standard formally replaced the previous 
2013  version  on  14  February  2020. However, the transition date for its use by PEFC 
certificate holders is 14 February 2022. After this date, companies still certified against the 

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2013  version  will  need  to  update  their  system  according  to  the  2020  version,  in 
preparation for certification against this version during their next external audit. Only the 
2020 version of the chain of custody standard was evaluated in this study.  

PEFC Chain of Custody certification allows for the mixing of PEFC certified materials with 
non-certified materials, under special conditions. The non-certified materials must meet 
the ‘PEFC Controlled Sources’ requirements (this does not apply to recycled materials). 
These requirements seek to ensure that the non-certified input does not originate from 
controversial sources, defined by PEFC as deriving from: 

a)  Activities  not  complying with applicable local, national or international legislation on 
forest management, including but not limited to forest management practices; nature and 
environmental protection; protected and endangered species; property, tenure and land -
use  rights  for  indigenous  peoples,  local  communities  or  other  affected  stakeholders; 
health, labour and safety issues; anti-corruption and the payment of applicable royalties 
and taxes. 
b) Activities where the capability of forests to produce a range of wood and non -wood 
forest products and services on a sustainable basis is not maintained or harvesting levels 
exceed a rate that can be sustained in the long term. 
c)  Activities  where  forest  management  does  not  contribute  to  the  maintenance, 
conservation or enhancement of biodiversity on landscape, ecosystem, species or genetic 
levels. 
d)  Activities  where  ecologically  important  forest  areas  are  not  identified,  protected, 
conserved or set aside. 
e) Activities where forest conversions occur, in other than justified circumstances where 
the conversion: 

i. is in compliance with national and regional policy and legislation applicable for 
land use and forest management, and 
ii. does not have negative impacts on ecologically important forest areas, culturally 
and socially significant areas, or other protected areas, and 
iii. does not destroy areas of significantly high carbon stock, and  
iv.  makes  a  contribution  to  long-term  conservation,  economic,  and/or  social 
benefits. 

f) Activities where the spirit of the ILO Declaration on Fundamental Principles and Rights 
at Work (1998) is not met. 
g) Activities where the spirit of the United Nations Declaration on the Rights of Indigenous 
Peoples (2007) is not met. 
h) Conflict timber. 
i) Genetically modified trees. 

As  PEFC  Controlled  Sources  are  an  integral part of Chain of Custody standard, only 
organisations certified against the Chain of Custody standard are able to use wood from 
uncertified sources in PEFC products. PEFC Controlled Sources cannot be applied at the 
forest management certification level. 

For PEFC Controlled Sources, a due diligence system is required to be implemented by 
the CoC certified organisation, in order to source non -certified material. Appendix 1 of 
Chain of Custody standard contains the requirements for this due diligence system.  

PEFC Material Categories  

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There are different material categories, or claims, that can be used in the manufacture of 
products – or sold – under PEFC Chain of Custody certification: 

  PEFC 100%, which comprises material from PEFC certified forests and has only 
been handled by Chain of Custody certified organisations in the supply chain.  
  PEFC  Controlled  Sources,  which  comprises  material  that  was  evaluated  as 
Controlled  Source through a due diligence process and therefore has not only 
been handled by certified organisations in the supply chain. Controlled Sources 
claims can only be used business to business and not as a final claim category for 
consumers. 

  X% PEFC Certified which contains a mixture of PEFC 100% and PEFC Controlled 

Sources material.  

Sales  claims  which  include  these  categories  can  be  made  on  sales  and  delivery 
documents for the different PEFC certified products. 

Group certification models 

At both the FM and CoC levels, individual small organisations can join together to form a 
group and apply for group certification, to share the costs and workload of obtaining and 
maintaining certification. In each case, a Group Entity (a person or group of persons, such 
as  a  cooperative,  association  or  company)  takes  responsibility  for  establishing  and 
managing a system ensuring compliance of the Group Members.  

For  both  FM  and  CoC  Group  certification,  there  are  reduced  external  auditing 
requirements,  whereby  Certification  Bodies  audit  annually just a sample of the Group 
Members, along with the Group Entity. This reduced external auditing is compensated by 
the fact the Group Entity is required to conduct audits of all Group Members on an annual 
basis, the results of which are audited by the Certification Body during the audit.  

Verifying PEFC Certificates  

PEFC  maintains  a  public  certificate  database,  which  can  be  accessed  at 
https://www.pefc.org/find-certified.  Certificates  are  searchable  using  various  queries 
including business name, country, certificate number, certification type, and product type. 
The database contains the following information available for each certificate: certificate 
and  license  codes,  address  and  contact  information  of  the  certified  organisation, 
certification validity and dates, group members and sites, and product types.  

Information  provided  by  PEFC  informed  this  study  that  a  new public database will be 
made  available  in  2021.  The  new  system  may  include  additional  information,  in 
comparison to the existing database. 

Policy and standard development  

PEFC  has  a development, review and revision process for its international standards, 
benchmark  standards,  national  standards,  procedural  documents,  and  guidance 
documents. Details of the current consultations are published on their website 93, where 
anyone  can  sign  up  to  the  relevant  consultation.    A  regularly  updated  overview  and 
schedule of the development, review and revision processes can also be checke d from 
the website.94  

The  PEFC  Council  technical  documents  development  procedure,  PEFC  GD  1003, 
specifies  how  documents  of  the  normative  framework  are  developed,  reviewed  and 

93 https://consultations.pefc.org/  
94 https://consultations.pefc.org/system/calendar  

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revised. This involves the establishment of a Working Groups. Two permanents grou ps 
are established: for chain of custody and for sustainable forest management. PEF C GD 
1003  includes  detailed  steps  that  are  required  to  be  followed  at  each  stage  in  a 
development process, which includes public consultation.   

Stakeholder engagement  

Stakeholder engagement forms an integral part of standard development processes as 
well as requirements of FM certificate holders. At the broader level, different aspects the 
scheme are open for stakeholder input through the consultation platform7.  

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30.  About this report 

1.1 Report Structure 

The PEFC scheme has been evaluated on two levels: 

 

International  level  –  all  applicable  global  documents  and  information  were 
evaluated, considering how the scheme is structured and functions globally; and  

  National level – where a sample of four countries were selected for a closer look, 
to  see  how  the  international  requirements  and  processes  are  reflected  in 
nationally-endorsed schemes, and if they follow the PEFC scheme’s international 
requirements, thus providing evidence to feed into the findings at the international 
level, where possible. The four countries are Brazil, China, Romania and Russia.  

In  this  version  of  this  draft  report  (version  0.31),  the  findings  from  the  national -level 
evaluations have been incorporated into the findings of the international-level evaluation 
and are, thus, presented in summary only. The national-level reports will be annexed as 
notes to later versions of this report.  

This  study  is  based  on  the  Scheme  Assessment  Framework  (SAF)  (as  descr ibed  in 
Section 3 below), the first two sub-sections cover the legal requirements to be addressed 
by Certificate Holders. The first section (A1) focusses on legal requirements at the forest 
level,  whilst  the  second  section  (A2)  focusses  on legal requiremen ts for supply chain 
entities. Due to the size and complexity of the scheme the findings for these two sections 
have each been split into two sections, each with an additional letter suffix:  

  A.1a Legal Requirements at the forest level – Forest management certification 

This covers full PEFC Forest Management certification, drawing mainly from the 
following standards: PEFC ST 1003: 2018 Sustainable Forest Management, and 
PEFC  ST  1002:  2018  Group  Forest  Management  Certification.  As  described 
above, these are the international PEFC standards that national schemes’ forest 
management standards are independently assessed against and must conform to, 
in order to become PEFC endorsed. 

For this reason, the national-level evaluations are also important in the evaluation  
of PEFC, to allow the incorporation findings relating to how the national schemes 
compare against the international-level requirements. 

  A.1b Legal Requirements at the forest level – Input non-PEFC certified forest.  

This  covers  non-PEFC-certified  material  entering  the  PEFC  system  via  the 
Controlled Sources requirements within the CoC standard: PEFC ST 2002: 2020 
Chain of Custody of Forest and Tree Based Products – Requirements. 

  A.2a Legal requirements for supply chain entities – Certificate holders 

This  covers  a  part  of  CoC  standard  and  the  requirements  that  are  directly 
applicable to COC certificate holders (PEFC ST 2002: 2020 Chain of Custody of 
Forest and Tree Based Products – Requirements, excluding Annex 1). 

  A.2b  Legal  requirements  for supply chain entities – Non-PEFC certified supply 

chains 

This  covers  non-PEFC-certified  material  entering  the  PEFC  system  via  the 
Controlled Sources requirements within the CoC standard: PEFC ST 2002: 2020 
Chain of Custody of Forest and Tree Based Products – Requirements – Annex 1, 
and refers to the non-certified supply chain entities between the forest gate and 
the point of export in the country of harvest.  

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The splitting of these sections, assists with the readability of the report and mirrors 
the two types of inputs may be used in certified products: PEFC-certified material 
(from certified forests) and PEFC Controlled Sources (non PEFC-certified material, 
controlled by the certificate holder, to minimise the risk that the non -certified input 
originates  from  controversial  sources)  with  different  requirements  that  are 
applicable for each input type. 

2.1 Overview  of  the  certification  standards  used  for  this 

analysis 

Type 

Normative 
 
  Certification  and Accreditation  Procedures - Annex 6 

PEFC  ST  1001: 2017 Standard-setting  – Requirements 

General  

Forest 
Managem ent 

 

 

 
 

 
 

 

 
 
 

 
 
 

 
 
 
 

Various ISO  standards  

PEFC  GD  1001: 2008  Structure of the PEFC  technical documentation  – general 
requirements 
PEFC  GD  1002: 2019  Acceptance of PEFC  members 
PEFC  GD  1003: 2009  PEFC  Council  technical  documents  development  procedures – 
requirements 
PEFC  GD  1004: 2009  Administration  of PEFC  scheme 
PEFC  GD  1006: 2012  PEFC  Notification  of Certification  Bodies  operating  Chain  of 
Custody Certification  in Countries  w ithout Authorised Bodies  
PEFC  GD  1007: 2017  Endorsement  and Mutual  Recognition  of Certification  Systems 
and their Revision 
PEFC  GD  1008: 2019  PEFC  Information  and Registration  System  – Data  Requirements 
PEFC  GD  1009: 2018  Nomination  and Election  Procedures for the PEFC  Council  Board 
PEFC  GL7  2007 PEFC  Council  procedures f or the investigation  and resolution  of 
complaints  and appeals 
PEFC  ST  1003: 2018 Sustainable  Forest Management 
PEFC  ST  1002: 2018 Group Forest Management  Certification 
PEFC  ST  2003: 2020 Requirements  for Certification  Bodies  operating  Certification 
against the PEFC  International 
ILO  169 
Various ISO  standards 
PEFC  Checklist  - Sustainable  Forest Management  (PEFC  ST  1003:2018) 
PEFC  ST  2002: 2020 Chain  of Custody of Forest and Tree Based Products  – 
Requirements. 

Chain of 
Custody 

NOTE:  this version of the Chain  of Custody standard formally  replaced the previous 2013 
version on 14 February 2020. How ever, the transition  date for its use by PEFC  certificate 
holders is 14 February 2022. After this date, companies  still certified against  the 2013  version 
w ill need to prepare their system according to the 2020 version, in preparation  for certification 
against this version during  their next external audit. 

 

 

PEFC  ST  2003: 2020 Requirements  for Certification  Bodies  operating  Certification 
against the PEFC  International 
Various ISO  standards 

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31.  Evaluation methodology 

The scheme is evaluated against Scheme Assessment Framework (SAF) and Scheme 
Assessment  Procedure  (SAP)  in  order  to  assess  how  the  scheme  covers  relevant 
requirements of the EUTR, and the criteria defined by the European Commission as the 
basis for this Study. 

For each indicator, we will have a conclusion that will show the level of conformance of 
the Scheme with the indicator: 

Conclusion  Definition 

Covered 

When  available  Scheme  requirements  and 
information  - and any impacts  evidence 
available  - indicate  the coverage of the SAF 
indicator. 

Explanation 
Coverage  is the ability  of the Scheme  to 
provide assurance that material  traded via 
the Scheme  has a low  (negligible)  risk of 
being  illegally  harvested, traded in line 
w ith the legality  definition  of the EU  Timber 
Regulation. 

When  available  Scheme  requirements  and 
information  - and any impacts  evidence 
available  - indicate  only partial coverage of the 
SAF indicator.   

Partially 
Covered 

Alternatively,  special concerns about  Scheme 
standards, credibility,  rigor or coverage may 
exist. 

NOTE:  It is important  to justify the partial 
coverage, and indicate  w here the issues are 
w hich result in a Coverage  conclusion not 
being  given. 
When  available  Scheme  requirements  and 
information  - and any impacts  evidence 
available  - indicate  that there is no coverage of 
the SAF indicator. 

NOTE:  It is important  to justify a no coverage 
conclusion. 
When,  for w hichever reason, the SAF indicator 
does not apply.   

Not Covered 

Not 
Applicable 
(N/A) 

Partial  Coverage  means  the Scheme  is 
only partly able  – or may  be compromised 
in one or more  w ays – to provide 
assurance that material  traded via the 
Scheme  has a low  (negligible)  risk of 
being  illegally  harvested, traded in line 
w ith the legality  definition  of the EU  Timber 
Regulation.   

The  Scheme  is not  – or inadequately  – 
able to provide assurance that material 
traded via the Scheme  has a low  
(negligible)  risk of being  illegally 
harvested, traded in line w ith the legality 
definition  of the EU  Timber  Regulation.   

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32.  Overview of findings 

Summary 

Conclusion 

Summary 

a - Forest management certification 

b - Input from non-PEFC certified forest 

Conclusion 

Requirement Section 
D.  Requirements for Certificate Holders 
A.1 Legal Requirements 
at the forest level 
A.1.1 Rights  to harvest timber 
w ithin legally  gazetted 
boundaries 

Partially covered 

5 indicators   are 
covered  
2 indicators  are 
partially  covered 

Indicators  related to land tenure, management 
rights, and concession license are almost 
covered. Standard  requires to cover legislation 
but not explicitly requiring  legal  methods  to 
obtain  these documents.  2 indicators are 
covered and 2 partially  covered. 

Partially covered 

1 indicator  is 
covered 
6 indicators  are 
partially  covered 

PEFC  standard requirements  cover legislation 
related  to forest management,  harvesting 
planning  and permits.  3 indicators assessed as 
covered. 

Indicators  related to land tenure and management 
rights, and concession licenses are partially  covered. 
The  standard includes  applicable  legislation  on forest 
management  as w ell as tenure and land-use  rights 
for indigenous  peoples, local  communities  or other 
affected stakeholders.  How ever, a specific reference 
to legislation  in the case w hen there are no 
indigenous  peoples, local communities  or other 
affected stakeholders  is not made.   

For other indicators of this criterion, the PEFC 
international  standard includes  compliance  w ith 
applicable  local, national  or international  legislation 
on forest management.  How ever, it does not make 
clear reference to legally-gazetted  boundaries and 
legal  business registration. 

Indicators  related to management  and harvesting 
planning  are partially  covered. Indicator  related  to 
harvesting permits  is covered.   

The  PEFC  standard includes compliance  w ith 
applicable  local, national  or international  legislation 
on forest management  but does not make  clear 
references to certain aspects of management 
planning;  the requirement  for legally  required 
planning  documents  to be approved before the 
implementation;  legislation  regulating  the issuing of 
harvesting permits,  licenses or other legal 
documents  required  for specific harvesting 
operations. 

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A.1.2 Payments  for harvest 
rights and timber  including 
duties related  to timber 
harvesting 

Partially covered 

2 indicators  are 
partially  covered 

PEFC  standard  includes compliance  w ith 
legislation  related  to the payment  of applicable 
royalties and taxes but does not explicitly 
request compliance  w ith legislation  regulating   
value-added  taxes; stumpage  fees, other 
volume-based  fees, land  area taxes. 

Partially covered 

2 indicators  are 
partially  covered  

The  PEFC  standard includes compliance  w ith 
legislation  related  to the payment  of applicable 
royalties and taxes but does not explicitly  request 
compliance  w ith legislation  regulating   value-added 
taxes; stumpage  fees, other volume-based  fees, land 
area taxes. 

A.1.3 Timber  harvesting, 
including  environmental  and 
forest legislation  including 
forest management  and 
biodiversity conservation, 
w here directly related to 
timber  harvesting 

Partially covered 

5 indicators  are 
covered 
3 indicators  are 
partially  covered  

Indicators  related to timber  harvesting 
regulations  are almost  covered. Note  that the 
PEFC  standard requires control of potential 
illegal  activities by third parties w ithin the 
managed  area. At the same  time,  it requires 
compliance  w ith forest management  legislation. 
How ever, clear references to compliance  w ith 
legislation  regulating  harvesting techniques and 
technologies  is not made.  1 covered and 1 
partially  covered. 

Indicators  related to protected sites and 
species are almost  covered. The  PEFC 
standard requires compliance  w ith legislation 
regulating  protected and endangered  species, 
but does not include  clear reference to 
legislation  regulating  the identification  of 
protected areas. 1 covered and 1 partially 
covered. 

Indicator  related  to environmental  requirements 
is partially  covered. Specific references to 
compliance  w ith legislation  regulating 
environmental  impact  assessments is not 
made.  1 indicator partially  covered. 

Indicators  related to health  and safety and legal 
employment  are covered by the national 
standards, although  the international  standard 
is not clear for legal  employment.  These  3 
indicators how ever w ere concluded as covered. 

Partially covered 

3 indicators  are 
covered 
5 indicators  are 
partially  covered  

Indicators  related to timber  harvesting regulations 
are almost  covered. Standard  requests comply  w ith 
forest management  legislation.  How ever, an explicit 
request to compliance  w ith legislation  regulated 
harvesting techniques  and technology  is not made.  1 
covered and 1 partially  covered. 

Indicators  related to protected sites and species are 
almost  covered. Standard includes  compliance  w ith 
legislation  regulating  protected and endangered 
species, but not clearly reference legislation 
regulating  the identification  of protected  areas. 1 
covered and 1 partially  covered. 

Indicator  related  to environmental  requirements  is 
partially  covered. Specific references to compliance 
w ith legislation  regulating  environmental  impact 
assessment is not made.  1 indicator  partially 
covered. 

PEFC  standard requirements  cover the indicator 
related  to health  and safety. Indicators  related to 
legal  employment  are almost  covered. Standard 
requests comply  w ith forest management  legislation. 
How ever, a specific reference to compliance  w ith 
legislation  contracts and w orking permits,  obligatory 
insurances, certificates of competence  and other 
training  requirements,  and payment  of social and 
income  taxes, is not made  w ithin the PEFC 
normative  requirements.  1 indicator covered and 1 
partially  covered. 

A.1.4 Third  parties’  legal 
rights concerning use and 

Covered 

Indicators  related to customary rights; Free, 
Prior  and Informed  Consent;  and Indigenous 

Covered 

Indicators  related to customary rights; Free, Prior 
and Informed  Consent;  and Indigenous  and 

307 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
tenure that are affected by 
timber  harvesting 

4 indicators  are 
covered  

A.1.5 Trade  and customs, in 
so far as the forest sector is 
concerned 

Partially covered 

1 indicator  is 
covered 
2 indicators  are 
partially  covered 
3 indicators  are not 
covered  

ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

4 indicators  are 
covered  

traditional  peoples'  rights are covered by the 
standard requirements.  4 indicators covered. 

Not Covered 

6 indicators  are not 
covered 

Indicators  related to the classification of species, 
quantities,  qualities;  trade and transport; Offshore 
trading  and transfer pricing; Customs  regulations; 
CITES  and Legislation  requiring  due diligence  / due 
care procedures are not covered.  

The  definition  of controversial sources (3.7) includes 
forest and tree-based material  sourced from 
activities not complying  w ith applicable  local, 
national,  or international  legislation  on  forest 
management,  including  forest management  practices 
and other areas of law . How ever, the definition  does 
not appear to cover legal  compliance  in relation  to 
trade, transport and customs, for non-certified forest 
entities  included  w ithin the due diligence 
requirements  of the scheme. 

and traditional  peoples' rights are covered by 
the standard requirements.  4 indicators 
covered. 

Indicators  related to the classification of 
species, quantities,  qualities;  and trade and 
transport are partially  covered.  

There  is a requirement  to comply  w ith 
applicable  local, national  and international 
legislation  on forest management.  How ever, 
clear reference to complying  w ith legislation 
regulating  how  harvested material  is classified 
or related  to trade and transport is not made.  2 
indicators partially  covered. 

Indicator  related  to CITES  is covered. The 
international  PEFC  standard does not have 
explicit  requirements  related  to CITES  permits, 
but all national  standard assessed have 
requirements  related to CITES.  1 indicator 
covered. 

Indicators  related to offshore trading; transfer 
pricing; customs regulations;  and legislation 
requiring  due diligence  / due care procedures 
are evaluated  as not covered. While  there is a 
requirement  to comply w ith applicable  local, 
national  and international  legislation  on forest 
management,  no clear reference is made  to 
compliance  in relation  to these areas of law . 3 
indicators concluded  as not covered. 

A.2 Legal requirements 
for supply chain entities 
A.2.1. Legal registration 

a - Certificate Holders 

b - Input from non-PEFC certified forest 

Partially covered 

1 indicator  is not 
covered  

Indicator  related  to legal  registration  is 
assessed as not covered. The certification body 
is collecting  information  related  to the legal 
status of the certificate holder. How ever, legal 
business registration or other relevant legally 
required licenses are not specifically required to 

Not Covered 

1 indicator  is  
not covered 

Indicator  related  to legal  registration  is assessed as 
not covered. Standard  requirements  include forest 
and tree-based material  sourced from activities not 
complying  w ith applicable  local, national  or 
international  legislation  on forest management, 
including  forest management  practices and other 

308 

 
 
 
 
 
 
 
 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

be ascertained or evaluated.  Simultaneously, 
there is no requirement  in the chain of custody 
standard to ensure the existence of legal 
business registration or other relevant legally 
required licenses. 

A.2.2 Taxes and fees 

Not Covered 

A.2.3 Trade  and transport 

2 indicators  are  
not covered  
Partially covered 

2 indicators  are  
partially  covered 
5 indicators  are not 
covered  

Standard  has no requirement  to ensure 
compliance  w ith legislation  covering taxes and 
fees. 

Standard  has no requirement  to ensure 
compliance  w ith legislation  regulating  how  
products are classified, trading  permits, 
offshore trading, transfer pricing, export/import 
licenses. 5 indicators  not covered. 

Not Covered 

2 indicators  are  
not covered  
Not Covered 

7 indicators  are  
not covered  

Indicator  related  to CITES  is assessed as 
partially  covered. When  CH  is not implementing 
a DDS,  there is no requirement  to ensure 
compliance  w ith CITES  legislation,  but if the 
Certificate  Holder  is implementing  a DDS,  then 
the requirement  is included.  1 indicator partially 
covered. 

Indicator  related  to due diligence/  due care 
procedures is assessed as partially  covered. 
There  is no specific reference ensuring 
compliance  w ith legislation  covering due 
diligence/due  care procedures. Appendix 1 is 
effectively a due diligence  mechanism,  but it 
does not apply to  all certificate holders 
themselves.  1 indicator partially  covered. 

309 

areas of law . This definition  is specific to forest 
management  only. It does not appear to include 
compliance  relevant to the supply chain legality, 
covering legislation  relevant to business registration 
and other relevant legally  required licenses that 
applies  to supply chain entities. 

Standard  has no requirement  to ensure compliance 
w ith legislation  covering taxes and fees. 

Standard  requirements  include forest and tree-based 
material  sourced from activities not complying  w ith 
applicable  local, national  or international  legislation 
on forest management,  including  forest management 
practices and other areas of law . This definition  is 
specific to forest management  only. It does not 
appear to include compliance  w ith trade and 
transport legislation  (Classification  of species, 
quantities,  qualities;  Trade and transport; Offshore 
trading  and transfer pricing; Customs  regulations; 
CITES;  Legislation  requiring  due diligence  / due care 
procedures). 7 indicators not covered. 

 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

33.  Evaluation 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A. Requirements for Certificate Holders 

Requirements applicable to the Certificate Holders. These include requirements to comply with applicable legislation, as well  as requirements relevant to ensuring continued performance and integrity of the operations 
– as  far as is related to legal compliance. 
A.1a Legal Requirements at the forest level - Forest management certification 

Principle  A.1a relates to how  the scheme  ensures that Certificate  Holders  comply w ith all applicable  legislation  at the forest level.  It applies  to Single  and Group Certification.  The standar d 
assessed in this section: PEFC  ST  1003: 2018.   

Note:  Section  A1 is split into tw o components:  A.1a w ith findings related to a forest certified by PEFC  and A.1b w ith findings related  to w hat is happening  in the non-certified forest subject to 
Controlled  Sources requirements. 

A.1a.1 Rights to harvest 
tim ber w ithin legally 
gazetted boundaries 

A.1a.1.1  Land tenure 

and 
management 
rights 

A.1a.1.1.1. The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
covering land 
tenure rights, 
including 
customary rights 
as well as 
management 
rights.  

PEFC ST 1003: 2018 

Findings 

Covered 

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 

Single Forest management certification  
There are generic indicators stating that all applicable legislation 
shall be identified and accessible for the organization (6.3.1.1) and 
that applicable legislation on forest management shall be followed 
by the certificate holder (6.3.1.2).  

According to PEFC ST 1003: 2018 - 6.3.2.1 and 6.3.2.2 legislation 
covering land tenure rights, including customary rights, are required 
to be met by the certificate holder.  

Group Forest management certification 
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018.  

Findings at the national level. 

310 

 
 
 
 
 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

The four national level evaluations corroborate the findings at the 
international level. Although, according to the findings from C.2.1.1, 
national standards assessed  on this project has been developed 
based on the previous version of Forest Management standard.  

Justification 

This indicator is concluded as covered for single and group forest 
management certification.   

and taxes. 

6.3.2.1 The standard requires that property rights, tree ownership and 
land tenure arrangements shall be clearly defined, documented and 
established for the relevant  management unit. Likewise, legal, 
customary and traditional rights related to the forest land shall be 
clarified, recognised and respected. 

6.3.2.2 The standard requires that forest practices and operations shall 
be conducted in recognition of the established framework of legal, 
customary and traditional rights such as outlined in ILO 169 and the UN 
Declaration on the Rights of Indigenous Peoples, which shall not be 
infringed upon without the free, prior and informed consent of the 
holders of the rights, including the provision of compensation where 
applicable. Where the extent of rights is not yet resolved, or is in dispute, 
there are processes  for just and fair resolution.  In such cases forest 
managers shall, in the interim, provide meaningful opportunities for 
parties to be engaged in forest management decisions whilst respecting 
the processes  and roles and responsibilities laid out in the policies and 
laws where the certification takes place. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the fol lowing PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 

311 

 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

A.1a.1.1.2. The 
Scheme shall 
include 
requirements to 
ensure that 
licenses, right of 
tenure and 
management 
rights, have 
been issued: 

i)  according to 
the legally 
prescribed 
procedure, 

ii) in compliance 
with third 
parties' legal 
rights 
concerning 
tenure, 

iii) specifying 
the legally-
gazetted 
boundaries, 
and; 

iv) with absence 
of corrupt 
practices. 

PEFC ST 1003: 2018 

6.1.2 The standard requires that inventory and mapping of forest 
resources  shall be established and  
maintained, adequate to local and national conditions and in 
correspondence with the requirements 
described in this international benchmark standard. 

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest man agement and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

6.3.1.3 The standard requires that where no anti-corruption legislation 
exists, the organisation must take alternative anti-corruption measures 
appropriate to the risk of corruption. 

6.3.2.1 The standard requires that property rights, tree ownership and 
land tenure arrangements shall be clearly defined, documented and 
established for the relevant  management unit. Likewise, legal, 
customary and traditional rights related to the forest land shall be 
clarified, recognised and respected. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 

312 

Findings and Justification 

Findings 

Conclusion 

Partially 
Covered 

Single Forest management certification  
In reference to part i), there are generic indicators stating that all 
applicable legislation shall be identified and accessible for the 
organization (6.3.1.1) and that applicable legislation on forest 
management shall be followed by the certificate holder (6.3.1.2). 
However, the requirements to ensure that licenses, right of tenure 
and management rights, have been issued according to the legally 
prescribed procedure, is not specifically mentioned.  

In reference to parts ii) and iii), PEFC ST  1003: 2018 - 6.3.2.1, 
defines compliance with third parties’ legal rights. Generic indicators 
state that all applicable legislation should be identified and 
accessible for the organization (6.3.1.1) and that applicable 
legislation shall be followed by the certificate holder (6.3.1.2). 
According to indicator PEFC ST 1003: 2018 – 6.1.2, the certificate 
holder should establish inventory and mapping of forest resources, 
which should cover legally-gazetted boundaries.  

In reference to part iv) PEFC ST 1003: 2018 - 6.3.1.3, defines that 
anti-corruption measures should be taken if there is no legislation in 
the country. In countries where anti -corruption legislation is in place, 
this should be followed by the certificate holder (6.3.1.2).  

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018.  

Findings at the national level 

The four national level evaluations corroborate the findings at the 
international level. In all four national standards, the requirement for 
the absence of corruption practice is not mentioned. In addition, in 
the case of China, there is no requirement to ensure that licenses, 
right of tenure and management rights, have been issued in 
compliance with third parties' legal rights concerning tenure. 
Although, according to the findings from C.2.1.1, national standards 
assessed  on this project has been developed based on the previous 
version of Forest Management standard.  

 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1a.1.1.3 The 
Scheme shall 
include 
requirements 
that ensure the 
existence of 
legal business 
registration, and 
other relevant 
legally required 
licenses.  

PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 

Justification 

This indicator is concluded as partially covered for single and group 
forest management certification. There is no requirement to ensure that 
licenses, right of tenure and management rights, have been issued 
according to the legally prescribed procedure, is not specifically 
mentioned.  

PEFC ST 1003: 2018  

Findings 

Covered  

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 

313 

Single Forest management certification  
There are generic indicators stating that all applicable legislation 
shall be identified and accessible for the organisation (6.3.1.1) and 
that applicable legislation shall be followed by the certificate holder 
(6.3.1.2). It is not clear if PEFC International includes legal business 
registration and other relevant legally required licenses within their 
interpretation of “applicable local, national and international 
legislation on forest management”.  

It is the case that ISO 9000: 2015 requires certification bodies to 
document legal status as a part of the application for certification. 
However, legal business registration or other relevant legally 
required licenses are not specifically required to be ascertained or 
evaluated. At the same time, the process of documenting the legal 
status is carried out as a part of the application and is not subject to 
evaluation as part of annual audits.  

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018. 

Findings at the national level. 

The four national level evaluations (Brazil, China, Russia, and 
Romania) covered the requirements of this indicator. Although, 
according to the findings from C.2.1.1, national standards assessed 
on this project has been developed based on the previous version of 
Forest Management standard.  

 
 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1a.1.2  Concession 

licenses 

Partially 
Covered 

A.1a.1.2.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
regulating 
procedures for 
the issuing of 
concession 
licenses, 
including use of 
legal methods to 
obtain 
concession 
licenses and 
that licenses are 
covering only 
legally gazetted 
areas 

the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 

Justification 

This indicator is concluded as covered for single and group forest 
management certification. In the assessment of national schemes, 
all assessed  standards covered these requirements even though 
they were developed based on a previous version of the PEFC 
International standard. Therefore, this indicator is concluded as 
covered, based on the national level assessments.  

PEFC ST 1003: 2018 

Findings 

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 

314 

Single Forest management certification 
At the international level, standard PEFC ST 1003: 2018 does not 
explicitly include the term “concession license”. However, there are 
generic indicators stating that all applicable legislation shall be 
identified and accessible for the organisation (6.3.1.1) and that 
applicable legislation shall be followed by the certificate holder 
(6.3.1.2).   

It is not clear if PEFC International consistently includes legal 
methods to obtain concession licenses within their interpretation of 
“applicable local, national and international legislation on forest 
management”. Simultaneously, normative requirements do not 
explicitly request to include only legally gazetted areas within 
concession licenses. 

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018.   

Findings at the national level 
Two national-level evaluations (Brazil and Russia) corroborate the 
partial coverage finding at the international level. The use of legal 
methods to obtain concession licenses is not addressed by the  
current standards from Brazil and Russia. For Romania and China, 
this indicator is not applicable. Although, according to the findings 
from C.2.1.1, national standards assessed  on this project has been 
developed based on the previous version of Forest Management 
standard. 

 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 

Justification 

This indicator is concluded as partially covered for single and group 
forest management certification. It is not clear if PEFC International 
consistently includes legal methods to obtain concession licenses 
within their interpretation of “applicable local, national and 
international legislation on forest management”.  Simultaneously, 
normative requirements do not require that these cover only legally 
gazetted areas. 

A.1a.1.3  Management 
and harvesting 
planning 

A.1a.1.3.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation and 
legal obligations 
for management 
planning, 
including 
conducting 
forest 
inventories, 
having a forest 
management 
plan and related 
planning and 
monitoring. 

PEFC ST 1003: 2018 

Findings 

Covered 

4.3.2 The standard requires that forest management shall comprise the 
cycle of inventory and planning, implementation, monitoring and 
evaluation, and shall include an appropriate assessment of the social, 
environmental and economic impacts of forest management practices. 
This shall form a basis for a cycle of continuous improvement. 

6.2 Management plan 
6.2.1 The standard requires that management plans shall be: 
a) elaborated and periodically updated or continually adjusted; 
b) appropriate to the size and use of the forest area; 
c) based on applicable local, national and international legislation as well 
as existing land-use or other official plans; and 
d) adequately covering forest resources. 
6.2.2 The standard requires that management plans shall take into 
account the different uses or functions of the managed forest area. 
6.2.3  The standard requires that management plans shall include at 
least a description of the current forest management unit, long -term 
objectives, and the average annual allowable cut, including its 
justification. 
6.2.4 The standard requires that the annually allowable use of non -wood 
forest products shall be  
included in the management plan where forest management covers 
commercial use of non-wood 
forest products at a level which can have an impact on their long -term 
sustainability. 
6.2.5 The standard requires that management plans specify ways and 
means to minimise the risk of degradation and damage to forest 

Single Forest management certification  
There are generic indicators stating that all applicable legislation 
shall be identified and accessible for the organisation (6.3.1.1) and 
that applicable legislation shall be followed by the certificate holder 
(6.3.1.2). It is not clear if PEFC International consistently includes 
legislation regulating conducting of forest inventories, having a 
forest management plan and related planning and monitoring within 
their interpretation of “applicable local, national and international 
legislation on forest management”. 

According to PEFC ST 1003: 2018 - 6.2, management planning is 
required, and inventory and mapping of the forest shall be 
established and maintained. PEFC ST 1003: 2018 – 4.3.2 requires 
implementing a plan based on monitoring and evaluation of social, 
environmental, and economic impacts.  

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018. 

Findings at the national level 
The four national level evaluations (Brazil, China, Russia, and 
Romania) covered the requirements of this indicator. Although, 
according to the findings from C.2.1.1, national standards assessed 
on this project has been developed based on the previous version of 
Forest Management standard. 

315 

 
 
 
 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

Justification 

This indicator is concluded as covered for single and group forest 
management certification. In the assessment of national schemes, all 
assessed  standards covered these requirements even though they 
were developed based on a previous version of the PEFC International 
standard. Therefore, this indicator is concluded as covered, based on 
the national level assessments. 

ecosystems. 
6.2.6 The standard requires that management plans shall take into 
account the results of scientific research. 
6.2.7  The standard requires that a summary of the management plan, 
appropriate to the scope and scale of forest management, shall be 
publicly available and shall include information on the general objectives 
and forest management principles. 
6.2.8 The standard requires that the publicly    available summary of the 
management plan may exclude confidential business and personal 
information and other information made confidential by applicable 
legislation or for the protection of cultural sites or sensitive natural 
resource features. 

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 

316 

 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1a.1.3.2 The 
Scheme shall 
include 
requirements 
that all legally 
required 
planning 
documents have 
been approved 
prior to 
implementation 
of forest 
harvesting 
activities. 

PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 
PEFC ST 1003: 2018  
6.2.1 The standard requires that management plans shall be: 
a) elaborated and periodically updated or continually adjusted; 
b) appropriate to the size and use of the forest area; 
c) based on applicable local, national and international legislation as well 
as existing land-use or other official plans; and 
d) adequately covering forest resources. 

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 

317 

Findings 

Covered 

Single Forest management certification  
PEFC International requirements include an indicator with a general 
statement that all applicable legislation should be identified and 
accessible for the organisation (6.3.1.1) and that applicable 
legislation shall be followed by the certificate holder (6.3.1.2). At the 
same time, according to PEFC ST 1003: 2018 – 6.2.1. c) 
management plan shall be based on legislation.  

It is not clear if PEFC International consistently includes legislation 
related to the approval of planning documents prior to the 
implementation of forest harvesting activities within their 
interpretation of “applicable local, national and international 
legislation on forest management” or that management planning 
“shall be based on legislation”. 

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018.   

Findings at the national level 
The four national level evaluations (Brazil, China, Russia, and 
Romania) covered the requirements of this indicator. Although, 
according to the findings from C.2.1.1, national standards assessed 
on this project has been developed based on the previous version of 
Forest Management standard. 

Justification 

This indicator is concluded as covered for single and group forest 
management certification. In the assessment of national schemes, all 
assessed  standards covered these requirements even though they 

 
 
 
 
 
 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1a.1.4  Harvesting 

permits 

A.1a.1.4.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
regulating the 
issuing of 
harvesting 
permits, 
licenses or other 
legal documents 
required for 
specific 
harvesting 
operations. 

PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system , 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 
PEFC ST 1003: 2018 
6.2 Management plan 
6.2.1 The standard requires that management plans shall be: 
a) elaborated and periodically updated or continually adjusted; 
b) appropriate to the size and use of the forest area; 
c) based on applicable local, national and international legislation as well 
as existing land-use or other 
official plans; and 
d) adequately covering forest resources. 
6.2.2 The standard requires that management plans shall take into 
account the different uses or  
functions of the managed forest area. 
6.2.3  The standard requires that management plans shall include at 
least a description of the current forest management unit, long -term 
objectives, and the average annual allowable cut, including its 
justification. 
6.2.4 The standard requires that the annually allowable use of non -wood 
forest products shall be  
included in the management plan where forest management covers 
commercial use of non-wood 
forest products at a level which can have an impact on their long -term 
sustainability. 
6.2.5 The standard requires that management plans specify ways and 
means to minimise the risk of degradation and damage to forest 
ecosystems. 
6.2.6 The standard requires that management plans shall take into 
account the results of scientific  
research. 
6.2.7  The standard requires that a summary of the management plan , 
appropriate to the scope and scale of forest management, shall be 
publicly available and shall include information on the general 
objectives and forest management principles. 
6.2.8 The standard requires that the publicly available summary of the 
management plan may exclude 
confidential business and personal information and other information 
made confidential by  
applicable legislation or for the protection of cultural sites or sensitive 
natural resource features. 

318 

were developed based on a previous version of the PEFC International 
standard. Therefore, this indicator is concluded as covered, based on 
the national level assessments.  

Findings 

Covered  

Single Forest management certification  
There are generic indicators stating that all applicable legislation 
shall be identified and accessible for the organisation (6.3.1.1) and 
that applicable legislation shall be followed by the certificate holder 
(6.3.1.2). Additionally, according to PEFC ST  1003: 2018 - 6.2, the 
management plan shall be based on applicable local, national and 
international legislation. These indicators make it impossible to 
avoid including harvesting licenses. 

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018.   

Findings at the national level 
Russia and Romania national -level evaluation partial covered the 
requirements of this indicator. For Russia, there is a general 
indicator that all applicable legislation shall be followed, but there is 
no reference to compliance with legislation regulating the issuing of 
harvesting permits. In case of Romania, there are no specific 
requirements regarding the harvesting permits, licenses or other 
legal documents required for specific harvesting operations. Brazil 
and China covered the requirements of this indicator. Although, 
according to the findings from C.2.1.1, national standards assessed 
on this project has been developed based on the previous version of 
Forest Management standard. 

Justification 

This indicator is concluded as covered for single and group forest 
management certification.  

 
 
 
 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 

319 

Payments 

A.1a.2 
for 
harvest  rights  and  timber 
including duties rel ated to 
timber harvesting 

 
 
 
 
 
 
 
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Code 

Criterion 

Indicators 

Standard reference 

A.1a.2.1  Payment of 

royalties and 
harvesting 
fees 

A.1a.2.1.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
covering 
payment of all 
legally required 
forest 
harvesting-
specific fees 
such as 
royalties, 
stumpage fees 
and other 
volume-based 
fees, as  well as 
land area taxes 
or fees. 

PEFC ST 1003: 2018 

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation . 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 

Findings and Justification 

Findings 

Conclusion 

Partially 
Covered 

Single Forest management certification  
According to PEFC ST 1003: 2018 6.3.1.2 legislation related to the 
payment of applicable royalties and taxes are required to be met by 
the certificate holder. It is not clear if PEFC International includes 
legislation regulating stumpage fees and other volume-based fees, 
as well as land area taxes or fees within their interpretation of 
“applicable royalties and taxes”. 

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018.   

Findings at the national level 
Romania national-level evaluation corroborates the partial coverage 
finding at the international level, as a reference to legislation 
regulating payments of royalties is not made. Based on the 
normative requirements of the Romanian Forest Certification 
Scheme this indicator is considered as partially covered, considering 
that the reference to the legislation regulating payments of royalties 
and harvesting fees is made in general terms. Brazil, China, and 
Russia covered the requirements of this indicator. Although, 
according to the findings from C.2.1.1, national standards assessed 
on this project has been developed based on the previous version of 
Forest Management standard. 

Justification 

This indicator is concluded as partially covered for single an d group 
forest management certification. A specific reference to compliance 
with legislation regulating stumpage fees, and other volume -based 
fees, as  well as land area taxes or fees, is not made. 

A.1a.2.2  Value-added 

taxes and 
other sales 
taxes 

A.1a.2.2.2 The 
Scheme shall 
include 
requirements 

PEFC ST 1003: 2018 

Findings 

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 

Single Forest management certification  
According to PEFC ST 1003: 2018 6.3.1.2 legislation related to the 

Partially 
Covered 

320 

 
 
 
 
 
 
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Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

that ensure 
compliance with 
legislation 
covering 
different types 
of sales taxes 
that apply to the 
material being 
sold, including 
selling material 
as growing 
forest (standing 
stock  sales). 

determine how these compliance obligations apply to the organisation. 

Note: For a country which has si gned a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 

payment of applicable royalties and taxes are required to be met by 
the certificate holder. It is not clear if PEFC International includes 
legislation regulating value-added tax or other sales taxes that apply 
to the material being sold, including selling material as growing 
forest (standing stock sales) within their interpretation of “applicable 
royalties and taxes”. 

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018.   

Findings at the national level 
Romania national-level evaluation corroborates the partial coverage 
finding at the international level, as a reference to the legislation 
regulating value-added taxes and other sale taxes is not made. 
Based on the normative requirements of standard, this indicator is 
considered as partially covered, considering that the reference to 
the legislation regulating value-added taxes and other sale taxes is 
made in general terms. Although, according to the findings from 
C.2.1.1, national standards assessed on this project has been 
developed based on the previous version of Forest Management 
standard. 

Justification 

This indicator is concluded as partially covered for single and group 
forest management certification. A specific reference to compliance 
with legislation regulating value-added tax or other sales taxes that 
apply to the material being sold, including selling material as growing 
forest (standing stock sales) is not made. 

forest 

A.1a.3  Timber  harvesting, 
including  environmental 
legislation 
and 
forest 
including 
management 
and 
biodiversity  conservation, 
where  directly  related  to 

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Findings and Justification 

Conclusion 

timber harvesting 

A.1a.3.1  Timber 

harvesting 
regulations 

A.1a.3.1.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legal obligations 
for harvesting 
techniques and 
technology 
including timing 
of harvest, 
selective 
cutting, shelter 
wood 
regeneration, 
clear felling, 
transport of 
timber from 
felling sites and 
seasonal 
limitations etc. 

This includes 
the mis-use of 
salvaging 
permits or other 
specific 
ministerial 
permits, with the 
intention of 
circumventing 
harvest 
regulations 

PEFC ST 1003: 2018 

Findings 

Partially 
Covered 

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; heal th, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

Single Forest management certification  
There are generic indicators stating that all applicable legislation 
shall be identified and accessible for the organisation (6.3.1.1) and 
that applicable legislation shall be followed by the certificate holder, 
including but not limited to forest management practices (6.3.1.2).  

PEFC ST 1003: 2018 – 8.3.4. requires that the certificate holder 
does not exceed the harvesting level (quota) for wood and non -
wood products. According to PEFC ST 1003: 2018 – 8.3.3. 
management, harvesting and regeneration operations shall be 
carried out in a way that does not reduce the productive capacity of 
the site.  

It is not clear if PEFC International consistently includes legislation 
regulating harvesting techniques and technology including the timing 
of harvest, selective cutting, shelter wood regeneration, clear felling, 
transport of timber from felling sites and seasonal limitations.  

8.3.3 The standard requires that management, harvesting and 
regeneration operations shall be carried out at a time, and in a way, that 
does not reduce the productive capacity of the site, for example by 
avoiding damage to soil and retained stands and trees. 

Group Forest management certification According to PEFC GD 
1007: 2017, group certification follows the requirements as per 
PEFC ST 1003: 2018.   

8.3.4 The standard requires that harvesting levels of both wood and non-
wood forest products shall not exceed a rate that can be sustained in the 
long term, and optimum use shall be made of the harvested products. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 

Findings at the national level 
Romania and Russia national -level evaluations corroborate the 
partial coverage finding at the international level. In Russia, there is 
a general statement that all applicable legislation shall be followed. 
However, a specific mention of harvesting techniques is not made. 
In case of Romania, there is no reference in the standard to the 
specific regulatory framework for harvesting techniques. 
Brazil and China covered the requirements of this indicator.  
Although, according to the findings from C.2.1.1, national standards 
assessed  on this project has been developed based on the previous 
version of Forest Management standard. 

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Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1a.3.1.2 The 
Scheme shall 
include 
requirements to 
control potential 
illegal activities 
by third parties 
within the area 
managed by the 
operation. 

management certification standard(s) shall meet the requireme nts of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 

Justification 

This indicator is concluded as partially covered for single and group 
forest management certification. Specific references to compliance with 
legislation regulating harvesting techniques and technology including 
the timing of harvest, selective cutting, shelter wood regeneration, clear 
felling, transport of timber from felling sites and seasonal limitations are 
not made. 

PEFC ST 1003: 2018 

Findings 

Covered  

6.3.1.4 The standard requires that measures shall be implemented to 
address protection of the forest from unauthorised activities such as 
illegal logging, illegal land use, illegally initiated fires, and other illegal 
activities. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 

Single Forest management certification  
According to PEFC ST 1003: 2018 – 6.3.1.4, the certificate holder 
shall implement measures to protect the forest from potential illegal 
activities. 

Group Forest management certification According to PEFC GD 
1007: 2017, group certification follows the requirements as per 
PEFC ST 1003: 2018.   

Findings at the national level 
Brazil and China national-level evaluation corroborate the coverage 
finding at the international level. Russia and Romania national-level 
evaluation do not corroborate the findings at the international level.  

Russia does not distinguish between illegal activities conducted 
under customary law and illegal activities conducted by outsiders, 
with no customary rights and therefore this indicator is assessed  as 
partially covered. Romania's national scheme does not make any 
reference related to illegal activiti es, and therefore the conclusion is 
not covered. Although, according to the findings from C.2.1.1, 
national standards assessed  on this project has been developed 
based on the previous version of Forest Management standard. 

Justification 

This indicator is concluded as covered for single and group forest 
management certification. Control of potential illegal activities is 
directly addressed in the normative requirement at the level of PEFC 

323 

 
 
 
 
 
 
 
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Indicators 

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Findings and Justification 

Conclusion 

International.    

A.1a.3.2  Protected 
sites and 
species 

A.1a.3.2.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
related to 
protected areas 
as well as 
protected, rare, 
or endangered 
species, 
including their 
habitats and 
potential 
habitats. 

PEFC ST 1003: 2018 

Findings 

Covered  

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnersh ip 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

8.4.3 The standard requires that protected, threatened and endangered 
plant and animal species shall not be exploited for commercial purposes. 
Where necessary, measures shall be taken for their protection and, 
where relevant, to increase their population. 

8.4.11 The standard requires that infrastructure shall be planned and 
constructed in a way that minimises damage to ecosystems, especially 
to rare, sensitive or representative ecosystems and genetic reserves, 
and that takes threatened or other key species – in particular, their 
migration patterns – into consideration. 

8.5.1 The standard requires that protective functions of forests for 
society, such as their potential role in erosion control, flood prevention, 
water purification, climate regulation, carbon sequestration and other 
regulating or supporting ecosystem services shall be maintained or 
enhanced. 

Single Forest management certification  
There is a generic indicator stating that all applicable legislation 
shall be identified and accessible for the organisation (6.3.1.1). 
According to PEFC ST 1003: 2018 6.3.1.2 applicable legislation 
shall be followed by the certificate holder, including but not limited to 
nature and environmental protection; protected and endangered 
species. 

In addition, according to PEFC ST 1003: 2018 – 8.4.3, 8.4.11, 8.5.1, 
8.5.2 and 8.6.3 the protection of: - protected, threatened and 
endangered plant and animal (8.4.3);  
- rare, sensitive or representative ecosystems and genetic reserves 
(8.4.11) 
- forests  for society, such as their potential role in erosion control, 
flood prevention, water purification, climate regulation, carbon 
sequestration and other regulating or supporting ecosystem services 
(8.5.1) 
- specific historical, cultural or spiritual significance and areas 
fundamental to meeting the needs of indigenous peoples and local 
communities (8.6.3) 

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018. 

Findings at the national level 
The four national level evaluations (Brazil, China, Russia, and 
Romania) covered the requirements of this indicator.  Although, 
according to the findings from C.2.1.1, national standards assessed 
on this project has been developed based on the previous version of 
Forest Management standard. 

8.5.2 The standard requires that areas that fulfil specific and recognised 

Justification 

324 

 
 
 
 
 
 
 
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Findings and Justification 

Conclusion 

protective functions for society shall be mapped, and forest management 
plans and operations shall ensure the maintenance or enhancement of 
these functions. 

8.6.3 The standard requires that sites with recognised specific historical, 
cultural or spiritual significance and areas fundamental to meeting the 
needs of indigenous peoples and local communities (e.g. health, 
subsistence) shall be protected or managed in a way that takes due 
regard of the significance of the site. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 
PEFC ST 1003: 2018 

8.4.2 The standard requires that i nventory, mapping and planning of 
forest resources shall identify, protect, conserve or set aside ecologically 
important forest areas. 

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 

325 

A.1a.3.2.2 
Requirements 
that ensure 
compliance with 
legislation 
related to 
protected areas 
and habitats, 
shall include 
that the 
identification of 
protected areas 
is conducted 
according to the 

This indicator is concluded as covered for single and group forest 
management certification. The protection of sites and species is 
directly addressed in the normative requirement at the level of PEFC 
International.   

Partially 
Covered 

Findings 

Single Forest management certification 
There is a generic indicator stating that all applicable legislation 
shall be identified and accessible for the organisation (6.3.1.1). 
According to PEFC ST 1003: 2018 6.3.1.2 applicable legislation 
shall be followed by the certificate holder, including but not limited to 
nature and environmental protection; protected and endangered 
species. It is not clear if PEFC International consistently includes 
legislation regulating the identification of protected areas. 

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 

 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

legal 
requirements. 

the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 
PEFC ST 1003: 2018 

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 

326 

A.1a.3.3  Environmental 

requirements 

A.1a.3.3.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
related to 
environmental 
impact 
assessment  in 
connection with 
harvesting, 

requirements as per PEFC ST 1003: 2018.  

Findings at the national level 
Russia and China national-level evaluation corroborate the partial 
coverage finding at the international level. Standards do not include 
a specific requirement that the identification of protected areas is 
conducted according to the legal requirements. A general 
requirement that all applicable legislation shall be followed is 
available. Brazil and Romania national-level evaluation covered the 
requirements of this indicator. Although, according to the findings 
from C.2.1.1, national standards assessed  on this project has been 
developed based on the previous version of Forest Managemen t 
standard. 

Justification 

This indicator is concluded as partially covered for single and group 
forest management certification. A specific reference to compliance 
with legislation regulating the identification of protected areas is not 
made. 

Findings 

Partially 
Covered 

Single Forest management certification  
There are generic indicators stating that all applicable legislation 
shall be identified and accessible for the organisation (6.3.1.1) and 
that applicable legislation shall be followed by the certificate holder, 
including but not limited to forest management practices and nature 
and environmental protection (6.3.1.2).  

In addition, according to PEFC ST 1003: 2018 – 8.5.1 and 8.5.3, at 
the international level, erosion control is required, and techniques 
applied shall be suitable for sensitive soils. However, there is no 

 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

acceptable 
levels of 
damage and 
disturbance of 
soil resources, 
establishment of 
buffer zones 
(e.g. along 
watercourses, 
open areas, 
breeding sites), 
maintenance of 
retained trees 
on felling sites, 
seasonal 
limitations on 
harvesting, and 
environmental 
requirements for 
forest 
machinery. 

species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

8.2.9 The standard requires that pesticides, such as chlorinated 
hydrocarbons whose derivatives remain biologically active and 
accumulate in the food chain beyond their intended use, and any 
pesticides banned by international agreement, shall be prohibited. 
Note: “Pesticides banned by international agreements” are defined in the 
Stockholm Convention on Persistent Organic Pollutants. 

8.5.1 The standard requires that protective functions of forests for 
society, such as their potential role in erosion control, flood prevention, 
water purification, climate regulation, carbon sequestration and other 
regulating or supporting ecosystem services shall be maintained or 
enhanced. 

8.5.3 The standard requires that special care shall be given to forestry 
operations on sensitive soils and erosion-prone areas as well as in areas 
where operations might lead to excessive erosion of soil into 
watercourses. Techniques applied and the machinery used shall be 
suitable for such areas. Special measures shall be taken to minimise the 
pressure  of animal populations on these areas. 

PEFC GD 1007: 2017 
5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 

specific reference to the legal obligations related to this activity. 

It is not clear if PEFC International consistently includes within its 
interpretation of forest management practices and nature and 
environmental protection (6.3.1.2), legislation regulating 
environmental impact assessment in connection with harvesting, 
acceptable levels of damage and disturbance of soil resources, the 
establishment of buffer zones (e.g. along watercourses, open areas, 
breeding sites), maintenance of retained trees on felling sites, 
seasonal limitations on harvesting, and environmental requirements 
for forest machinery. 

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018.  

Findings at the national level 
Russia and China national-level evaluation corroborate the partial 
coverage finding at the international level. Standards do not include 
a specific reference to legislation related to environmental impact 
assessment  in connection with points of this indicator.  Brazil and 
Romania national-level evaluation covered the requirements of this 
indicator. Although, according to the findings from C.2.1.1, national 
standards assessed  on this project has been developed based on 
the previous version of Forest Management standard. 

Justification 

This indicator is concluded as partially covered for single and group 
forest management certification. Specific references to compliance with 
legislation regulating environmental impact assessments in connection 
with harvesting, acceptable levels of damage and disturbance of soil 
resources, the establishment of buffer zones (e.g. along watercourses, 
open areas, breeding sites), maintenance of retained trees on felling 
sites, seasonal limitations on harvesting, and environmental 
requirements for forest machinery are not made.  

It is not clear if PEFC International consistently includes these within its 
interpretation of forest management practices and nature and 

327 

 
 
 
 
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Conclusion 

A.1a.3.4  Health and 

safety 

A.1a.3.4.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
Health & Safety 
legislation. 

… 

PEFC ST 1003: 2018 

environmental protection (6.3.1.2). 

Findings 

Covered 

Single Forest management certification 
There are generic indicators stating that all applicable legislation 
shall be identified and accessible for the organisation (6.3.1.1) and 
that applicable legislation shall be followed by the certificate holder, 
including but not limited to health, labour and safety issues (6.3.1.2).  

According to PEFC ST 1003: 2018 – 6.3.4.1 and 6.3.4.2 health, 
safety, and work  conditions should be followed by the workers. At 
the same time, it is recommended to use as a guide for specifying 
national standards, the ILO Code of Good Practice on Safety and 
Health in Forestry Work. 

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018.  

Findings at the national level 
The four national level evaluations corroborate the findings at the 
international level (see report Annexes for details). Although, 
according to the findings from C.2.1.1, national standards assessed 
on this project has been developed based on the previous version of 
Forest Management standard. 

Justification 

This indicator is concluded as covered for single and group forest 
management certification. Health & Safety legislation is directly 
addressed in the normative requirement at the level of PEFC 
International. 

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

6.3.4.1 The standard requires that forest operations shall be planned, 
organised and performed in a manner that enables health and accident 
risks  to be identified and all reasonable measures to be applied to 
protect workers  from work-related risks.  Workers  shall be informed about 
the risks  involved with their work and about preventive measures. 

6.3.4.2 The standard requires that working conditions shall be safe, and 
guidance and training in safe working practices shall be provided to all 
those assigned to a task  in forest operations. Working hours and leave 
shall comply with national laws or applicable collective agreements.  
Note: Guidance for specifying national standards can be obtained from 
the ILO Code of Good Practice: Safety and Health in Forestry Work. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 

328 

 
 
 
 
 
  
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Standard reference 

Findings and Justification 

Conclusion 

A.1a.3.5  Legal 

employment 

recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 
PEFC ST 1003: 2018  

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management pra ctices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

6.3.4.3 The standard requires that wages of local and migrant forest 
workers  as well as of contractors and other operators operating in 
PEFC-certified areas shall meet or exceed at least legal, industry 
minimum standards or, where applicable, collective bargaining 
agreements. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 

329 

A.1a.3.5.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation for 
employment of 
personnel 
involved in 
harvesting (and 
in-forest 
processing) 
activities 
including but not 
limited to 
requirements 
for: contracts 
and working 
permits, 
obligatory 
insurances, 
certificates of 
competence 
and other 
training 
requirements, 
and payment of 
social and 

Findings 

Covered  

Single Forest management certification  
There are generic indicators stating that all applicable legislation 
shall be identified and accessible for the organisation (6.3.1.1) and 
that applicable legislation shall be followed by the certificate holder, 
including but not limited to health, labour and safety issues (6.3.1.2).  

According to PEFC ST 1003: 2018 – 6.3.4.3 wages of forest 
workers  for certificate holder and contractors shall meet legal 
requirements.  

It is not clear if PEFC International consistently includes with the 
definition of labour, legislation regulating employment of personnel 
involved in harvesting activities including working permits, obligatory 
insurances, certificates of competence and other training 
requirements, and payment of social and income taxes. 

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018.   

Findings at the national level 
The four national level evaluations covered the requirements of this 
indicator (see report Annexes for details). Although, according to the 
findings from C.2.1.1, national standards assessed on this project 
has been developed based on the previous version of Forest 
Management standard. 

 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

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Standard reference 

Findings and Justification 

Conclusion 

income taxes.  

A.1a.3.5.2 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation for 
minimum 
working age and 
minimum age 
for personnel 
involved in 
hazardous work, 
legislation 
against forced 
and compulsory 
labour, and 
discrimination 
and legislation 
allowing for 
freedom of 
association. 

recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 
PEFC ST 1003: 2018  

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

6.3.3.1 The standard requires that forest practices and operations shall 
comply with fundamental ILO conventions. 

6.3.4.3 The standard requires that wages of local and migrant forest 
workers  as well as of contractors and other operators operating in 
PEFC-certified areas shall meet or exceed at least legal, industry 
minimum standards or, where applicable, collective bargaining 
agreements. 

PEFC GD 1007: 2017 

330 

Justification 

This indicator is concluded as covered for single and group forest 
management certification.  In the assessment of national schemes, all 
assessed  standards covered these requirements even though they 
were developed based on a previous version of the PEFC International 
standard. Therefore, this indicator is concluded as covered, based on 
the national level assessments.  

Findings 

Covered  

Single Forest management certification  
There are generic indicators stating that all applicable legislation 
shall be identified and accessible for the organisation (6.3.1.1) and 
that applicable legislation shall be followed by the certificate holder, 
including but not limited to health, labour and safety issues (6.3.1.2). 
It is not clear if PEFC International consistently includes with the 
definition of labour, legislation for minimum  working age and the 
minimum age for personnel involved in hazardous work, legislation 
against forced and compulsory labour, and discrimination and 
legislation allowing for freedom of association. 

However, according to 1003: 2018, 6.3.3.1 requires complying with 
fundamental ILO conventions. ILO conventions include 
requirements for minimum working age and the minimum age for 
personnel involved in hazardous work, legislation against forced and 
compulsory labour. PEFC ST 1003: 2018, 6.3.4.3 stating that 
collective bargain agreements legislation should be followed.  

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018.   

Findings at the national level 
Brazil Romana and China national-level evaluation this indicator as 
covered. Russia national scheme has requirements related to no 
violations of labour guarantees and social obligations in relation to 
workers.  However, standard does not include a requirement related 

 
 
 
 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC S T 
1002, Group Forest Management Certification – Requirements; 
… 

to minimum working age. Although, according to the findings from 
C.2.1.1, national standards assessed on this project has been 
developed based on the previous version of Forest Management 
standard. 

Justification 

This indicator is concluded as covered for single and group forest 
management certification. Legislation for minimum working age are 
followed based on the requirement to complying with fundamental 
ILO conventions. 

A.1a.4  Third  parties’  legal 
rights  concerning  use and 
tenure that are affecte d by 
timber harvesting 

A.1a.4.1  Customary 

rights 

A.1a.4.1.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
respect for 
customary 
tenure rights 
relevant to 
forest 
harvesting 
activities. 

PEFC ST 1003: 2018 

Findings 

Covered 

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

Single Forest management certification 
Standard requirement PEFC ST 1003: 2018 - 6.3.2.1. includes that 
property rights, tree ownership and land tenure arrangements shall 
be clearly defined, documented and established for the relevant 
management unit. Additionally that legal, customary and tra ditional 
rights related to the forest land shall be clarified, recognised and 
respected. 

According to PEFC ST 1003: 2018 - 6.3.2.2 customary and 
traditional rights are to be included in standard requirements. Forest 
practices and operations shall be conducted in recognition of the 
established framework of legal, customary and traditional rights 
such as outlined in ILO 169 and the UN Declaration on the Rights of 
Indigenous Peoples.  

In addition, there are generic indicators stating that all applicable 
legislation shall be identified and accessible for the organisation 

331 

 
 
 
 
 
 
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Indicators 

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Findings and Justification 

Conclusion 

6.3.2.1 The standard requires that property rights, tree ownership and 
land tenure arrangements shall be clearly defined, documented and 
established for the relevant management unit. Likewise, legal, 
customary and traditional rights related to the forest land shall be 
clarified, recognised and respected. 

6.3.2.2 The standard requires that forest practices and opera tions shall 
be conducted in recognition of the established framework of legal, 
customary and traditional rights such as outlined in ILO 169 and the UN 
Declaration on the Rights of Indigenous Peoples, which shall not be 
infringed upon without the free, prior and informed consent of the 
holders of the rights, including the provision of compensation where 
applicable. Where the extent of rights is not yet resolved, or is in dispute, 
there are processes  for just and fair resolution.  In such cases forest 
managers shall, in the interim, provide meaningful opportunities for 
parties to be engaged in forest management decisions whilst respecting 
the processes  and roles and responsibilities laid out in the policies and 
laws where the certification takes place. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 
PEFC ST 1003: 2018 - 6.3.1.1 The standard requires that the 
organisation shall identify and have access to the legislation applicable 
to its forest management and determine how these compliance 
obligations apply to the organisation. 

332 

A.1a.4.1.2 The 
Scheme shall 
include 
requirements 
that ensure 

(6.3.1.1) and that applicable legislation shall be followed by the 
certificate holder, including but not limited to tenure and land-use 
rights for indigenous peoples, local communities or other affected 
stakeholders (6.3.1.2). 

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018.   

Findings at the national level 
Brazil Russia and China national -level evaluation corroborate the 
coverage evaluation from the international level. For Romania, this 
indicator is not applicable (see report Annexes for details). Although, 
according to the findings from C.2.1.1, national standards assessed 
on this project has been developed based on the previous version of 
Forest Management standard. 

Justification 

This indicator is concluded as covered for single and group forest 
management certification. Legislation regulation customary tenure 
rights relevant to forest harvesting activities is directly addressed in 
the normative requirement at the level of PEFC International. 

Findings 

Covered 

Single Forest management certification  
There are generic indicators stating that all applicable legislation 
shall be identified and accessible for the organisation (6.3.1.1) and 

 
 
 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

compliance with 
legal obligations 
concerning 
benefit sharing 
they have 
negotiated with 
communities or 
customary 
users.  E.g. 
social 
agreements or 
social 
responsibility 
agreements or 
cahier de 
charges, 
dependent on 
the country. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

PEFC ST 1003: 2018 - 6.3.1.2 The standard requires that the 
organisation shall comply with applicable local, national and  
international legislation on forest management, including but not limited 
to forest management practices; nature and environmental protection; 
protected and endangered species; property, tenure and land-use rights 
for indigenous peoples, local communities or other affected 
stakeholders; health, labour and safety issues; anti -corruption and the 
payment of applicable royalties and taxes. 

PEFC ST 1003: 2018 

6.3.2.1 The standard requires that property rights, tree ownership and 
land tenure arrangements shall be clearly defined, documented and 
established for the relevant management unit. Likewise, legal, 
customary and traditional rights related to the forest land shall be 
clarified, recognised and respected. 

6.3.2.2 The standard requires that forest practices and operations shall 
be conducted in recognition of the established framework of legal, 
customary and traditional rights such as outlined in ILO 169 and the UN 
Declaration on the Rights of Indigenous Peoples, which shall not be 
infringed upon without the free, prior and informed consent of the 
holders of the rights, including the provision of compensation where 
applicable. Where the extent of rights is not yet resolved, or is in dispute, 
there are processes  for just and fair resolution.  In such cases forest 
managers shall, in the interim, provide meaningful opportunities for 
parties to be engaged in forest management decisions whilst respecting 
the processes  and roles and responsibilities laid out in the policies and 
laws where the certification takes place. 

that applicable legislation shall be followed by the certificate holder, 
including but not limited to tenure and land-use rights for indigenous 
peoples, local communities or other affected stakeholders (6.3.1.2). 
It is not clear if PEFC International consistently includes within this 
requirement, compliance with legal obligations concerning benefit 
sharing. 

Standard requirement PEFC ST 1003: 2018 - 6.3.2.1. includes that 
property rights, tree ownership and land tenure arrangements shall 
be clearly defined, documented and established for the relevant 
management unit. Additionally that legal, customary and traditional 
rights related to the forest land shall be clarified, recognised and 
respected.  

According to PEFC ST 1003: 2018 - 6.3.2.2 forest practices and 
operations shall be conducted in recognition of the established 
framework of legal, customary and traditional rights such as outlined 
in ILO 169 and the UNDRIP. ILO 169 (Articles 2, 15 and 35) and 
UNDRIP (Article 32) address the sharing of benefits from the 
exploitation of resources to which they hold rights.  

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018.  

Findings at the national level 
Brazil Russia and China national level evaluations corroborate the 
coverage evaluation from the international level. For Romania, this 
indicator is not applicable (see report Annexes for details). Although, 
according to the findings from C.2.1.1, national standards assessed 
on this project has been developed based on the previous version of 
Forest Management standard. 

Justification 

ILO 169, Article 2  
1. Governments shall have the responsibility for developing, with the 
participation of the peoples concerned, co-ordinated and systematic 
action to protect the rights of these peoples and to guarantee respect for 

This indicator is concluded as covered for single and group forest 
management certification. Legislation regulation sharing of benefits 
is at least indirectly addressed (through ILO 169) in the normative 
requirement at the level of PEFC International. 

333 

 
 
 
 
 
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Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

their integrity. 
2. Such action shall include measures for: 
(a) ensuring that members of these peoples benefit on an equal footing 
from the rights and opportunities which national laws and regulations 
grant to other members of the population; 
Article 15 
1. The rights of the peoples concerned to the natural resources 
pertaining to their lands shall be specially safeguarded. These rights 
include the right of these peoples to participate in the use, management 
and conservation of these resources. 
2. In cases  in which the State retains the ownership of mineral or sub -
surface resources or rights to other resources  pertaining to lands, 
governments shall establish or maintain procedures through which they 
shall consult these peoples, with a view to ascertaining whether and to 
what degree their interests would be prejudiced, before undertaking or 
permitting any programmes for the exploration or exploitation of such 
resources  pertaining to their lands. The peoples concerned shall 
wherever possible participate in the benefits of such activities, and shall 
receive fair compensation for any damages which they may sustain as a 
result of such activities. 
Article 35  
The application of the provisions of this Convention shall not adversely 
affect rights and benefits of the peoples concerned pursuant to other 
Conventions and Recommendations, international instruments, treaties, 
or national laws, awards, custom or agreements. 

UNDRIP 
Article 32 
… 
2. States shall consult and cooperate in good faith with the indigenous 
peoples concerned through their own representative institutions in order 
to obtain their free and informed consent prior to the approval of any 
project affecting their lands or territories and other resources, particularly 
in connection with the development, utilization or exploitation of mineral, 
water or other resources. 
PEFC ST 1003: 2018 - 6.3.1.1 The standard requires that the 
organisation shall identify and have access to the legislation applicable 
to its forest management and determine how these compliance 

334 

A.1a.4.2  Free, Prior 

and Informed 
Consent 

A.1a.4.2.1 The 
Scheme shall 
include 
requirements 

Findings 

Covered 

Single Forest management certification  
There are generic indicators stating that all applicable legislation 

 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

that ensure 
compliance with 
the 
internationally 
adopted 
principles of 
'Free, Prior and 
Informed 
Consent' in 
connection with 
granting rights 
to forest 
management. 

obligations apply to the organisation. 

Note: For a country whi ch has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

PEFC ST 1003: 2018 - 6.3.1.2 The standard requires that the 
organisation shall comply with applicable local, national and  
international legislation on forest management, including but not limited 
to forest management practices; nature and environmental protection; 
protected and endangered species; property, tenure and land-use rights 
for indigenous peoples, local communities or other affected 
stakeholders; health, labour and safety issues; anti -corruption and the 
payment of applicable royalties and taxes. 

PEFC ST 1003: 2018 

6.3.2.2 The standard requires that forest practices and operations shall 
be conducted in recognition of the established framework of legal, 
customary and traditional rights such as outlined in ILO 169 and the UN 
Declaration on the Rights of Indigenous Peoples, which shall not be 
infringed upon without the free, prior and informed consent of the 
holders of the rights, including the provision of compensation where 
applicable. Where the extent of rights is not yet resolved, or is in dispute, 
there are processes  for just and fair resolution.  In such  cases forest 
managers shall, in the interim, provide meaningful opportunities for 
parties to be engaged in forest management decisions whilst respecting 
the processes  and roles and responsibilities laid out in the policies and 
laws where the certification takes place. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and  mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 

shall be identified and accessible for the organisation (6.3.1.1) and 
that applicable legislation shall be followed by the certificate holder, 
including but not limited to tenure and land-use rights for indigenous 
peoples, local communities or other affected stakeholders (6.3.1.2).  

Standard requirement PEFC ST 1003: 2018 - 6.3.2.1. includes that 
property rights, tree ownership and land tenure arrangements shall 
be clearly defined, documented and established for the relevant 
management unit. Additionally that legal, customary and traditional 
rights related to the forest land shall be clarified, recognised and 
respected.  

It is not clear if PEFC International consistently includes within the 
above requirements, ensuring compliance with the internationally 
adopted principles of 'Free, Prior and Informed Consent' in 
connection with granting rights to forest management. 

However, according to PEFC ST 1003: 2018 - 6.3.2.2 forest 
practices and operations shall be conducted in recognition of the 
established framework of legal, customary and traditional rights 
such as outlined in ILO 169 and the UNDRIP. ILO 169 (Articles 2, 
15 and 35) and UNDRIP (Article 32) address the exploitation of 
resources  to which Indigenous and Tribal Peoples hold rights, via 
processes  that imbibe the principles of FPIC.  

In 6.3.2.2 the concept of 'Free, Prior and Informed Consent' is 
addressed directly as a requirement within the forest management 
standard. 

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018.   

Findings at the national level 
Not applicable for China, Russia and Romania. For Brazil, this 
indicator is covered through ILO 169 and United Nations Declaration 
on the Rights of Indigenous Peoples. Although, according to the 
findings from C.2.1.1, national standards assessed on this project 
has been developed based on the previous version of Forest 
Management standard. 

335 

 
 
 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

Justification 

This indicator is concluded as covered for single and group forest 
management certification.  

PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 
ILO 169 
Article 2  
1. Governments shall have the responsibility for developing, with the 
participation of the peoples concerned, co-ordinated and systematic 
action to protect the rights of these peoples and to guarantee respect for 
their integrity. 
2. Such action shall include measures for: 
(a) ensuring that members of these peoples benefit on an equal footing 
from the rights and opportunities which national laws and regulations 
grant to other members of the population; 
Article 35 The application of the provisions of this Convention  shall not 
adversely affect rights and benefits of the peoples concerned pursuant 
to other Conventions and Recommendations, international instruments, 
treaties, or national laws, awards, custom or agreements. 
Article 15 
1. The rights of the peoples concerned to the natural resources 
pertaining to their lands shall be specially safeguarded. These rights 
include the right of these peoples to participate in the use, management 
and conservation of these resources. 
2. In cases  in which the State retains the ownership of mineral or sub-
surface resources or rights to other resources  pertaining to lands, 
governments shall establish or maintain procedures through which they 
shall consult these peoples, with a view to ascertaining whether and to 
what degree their interests would be prejudiced, before undertaking or 
permitting any programmes for the exploration or exploitation of such 
resources  pertaining to their lands. The peoples concerned shall 
wherever possible participate in the benefits of such activities, and sh all 
receive fair compensation for any damages which they may sustain as a 
result of such activities. 
Article 35  
The application of the provisions of this Convention shall not adversely 
affect rights and benefits of the peoples concerned pursuant to other 
Conventions and Recommendations, international instruments, treaties, 

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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1a.4.3 

Indigenous 
and traditional 
peoples' rights 

A.1a.4.3.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
national 
legislation and 
international 
conventions 
ratified that 
respect the 
tenure rights of 
indigenous and 
tribal peoples to 
forest land as 
well as their 
right to FPIC. 

or national laws, awards, custom or agreements. 

UNDRIP 
Article 32 
… 
2. States shall consult and cooperate in good faith with the indigenous 
peoples concerned through their own representative institutions in order 
to obtain their free and informed consent prior to the approval of any 
project affecting their lands or territories and other resources, particularly 
in connection with the development, utilization or exploitation of mi neral, 
water or other resources. 
PEFC ST 1003: 2018  

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall co mply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

6.3.2.1 The standard requires that property rights, tree ownership and 
land tenure arrangements shall be clearly defined, documented and 
established for the relevant management unit. Likewise, legal, 
customary and traditional rights related to the forest land shall be 
clarified, recognised and respected. 

6.3.2.2 The standard requires that forest practices and operations shall 
be conducted in recognition of the established framework of legal, 
customary and traditional rights such as outlined in ILO 169 and the UN 

337 

Findings 

Covered 

Single Forest management certification  
Two generic indicators state that all applicable legislation shall be 
identified and accessible for the organisation (6.3.1.1) and that 
applicable legislation shall be included within forest management 
standards, including but not limited to tenure and land-use rights for 
indigenous peoples, local communities or other affected 
stakeholders (6.3.1.2). 

According to PEFC ST 1003: 2018 - 6.3.2.2 forest practices and 
operations shall be conducted in recognition of the established 
framework of legal, customary and traditional rights such as outlined 
in ILO 169 and the UNDRIP. ILO 169 (Articles 2, 15 and 35) and 
UNDRIP (Article 32) address the exploitation of resources to which 
Indigenous and Tribal Peoples hold rights, via processes that imbibe 
the principles of FPIC. In 6.3.2.2 the concept of 'Free, Prior and 
Informed Consent' is addressed directly as a requirement within the 
forest management standard. 

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018.   

Findings at the national level 
Brazil Russia and China national -level evaluation corroborate the 
coverage evaluation from the international level. For Romania, this 
indicator is not applicable (see report Annexes for details). Although, 

 
 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

according to the findings from C.2.1.1, national standards assessed 
on this project has been developed based on the previous version of 
Forest Management standard. 

Justification 

This indicator is concluded as covered for single and group forest 
management certification. Requirements that respect the tenure 
rights of indigenous and tribal peoples to forest land, as well as their 
right to FPIC, is directly addressed in the normative requirement at 
the level of PEFC International. 

Declaration on the Rights of Indigenous Peoples, which shall not be 
infringed upon without the free, prior and informed consent of the 
holders of the rights, including the provision of compensation where 
applicable. Where the extent of rights is not yet resolved, or is in dispute, 
there are processes  for just and fair resolution.  In such cases forest 
managers shall, in the interim, provide meaningful opportunities for 
parties to be engaged in forest management decisions whilst respecting 
the processes  and roles and responsibilities laid out in the policies and 
laws where the certification takes place. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainabl e Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 

A.1a.5 Trade and custom s,  
in  so  far  as  the  forest 
sector is concerned 

A.1a.5.1  Classification 

of species, 
quantities, 
qualities 

A.1a.5.1.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
regulating how 
harvested 

PEFC ST 1003: 2018 

Findings 

Partially 
Covered 

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnershi p 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

Single Forest management certification  
There are generic indicators stating that all applicable legislation 
shall be identified and accessible for the organisation (6.3.1.1) and 
that applicable legislation on forest management shall be followed 
by the certificate holder (6.3.1.2). However, while these indicators 
include legislation in relation to forest management and forest 
management practices, they do not appear to include legislation 

338 

 
 
 
 
 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

material is 
classified in 
terms of 
species, 
quantities and 
qualities in 
connection with 
trade and 
transport.  

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall m eet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 

regulating how harvested material is classified in terms of species, 
quantities and qualities in connection with trade and transport. 

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018.   

Findings at the national level 
Russia and China national-level evaluation do not cover the 
requirements of this indicator.   
Brazil national-level evaluation covered the requirements of this 
indicator. For Romania, this indicator is evaluated as partially 
covered because no specific reference to classification of volumes, 
qualities, species, and license area are made. A requirement that 
forest management should comply with legislation applicable to 
forest management issues is made. Although, according to the 
findings from C.2.1.1, national standards assessed on this project 
has been developed based on the previous version of Forest 
Management standard. 

Justification 

This indicator is concluded as partially covered for single and group 
forest management certification. Requirements that ensure 
compliance with legislation regulating how harvested material is 
classified in terms of species, quantities and qualities in connection 
with trade and transport, are partially included by PEFC International 
as a requirement within forest management standards.   

A.1a.5.2  Trade and 

transport 

A.1a.5.2.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legally required 
trading permits 
as well as 
legally required 

PEFC ST 1003: 2018 

Findings 

Partially 
Covered 

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 

Single Forest management certification  
There are generic indicators stating that all applicable legislation 
shall be identified and accessible for the organisation (6.3.1.1) and 
that applicable legislation on forest management shall be followed 
by the certificate holder (6.3.1.2). However, while these indicators 
include legislation on forest management and forest management 
practices, they do not appear to include legislation regulating trading 
permits as well as legally required transport documents that 

339 

 
 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

transport 
documents that 
accompany 
transport of 
wood from 
forest 
operations. 

applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine  whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 
PEFC ST 1003: 2018 

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 

340 

A.1a.5.3  Offshore 

trading and 
transfer 
pricing 

A.1a.5.3.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
regulating 
offshore trading 
and transfer 
pricing.  

accompany the transport of wood from forest operations. 

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018.   

Findings at the national level 
Russia, Romania and China national level do not cover the 
requirements of this indicator.  Brazil national -level evaluation 
covered the requirements of this indicator. Although, according to 
the findings from C.2.1.1, national standards assessed  on this 
project has been developed based on the previous version of Fore st 
Management standard. 

Justification 

This indicator is concluded as partially covered for single and group 
forest management certification. Requirements that ensure 
compliance with legislation regulating trading permits as well as 
legally required transport documents that accompany the transport 
of wood from forest operations are partially included by PEFC 
International as a requirement within forest management standards. 

Findings 

Not 
Covered 

Single Forest management certification  
There are generic indicators stating that all applicable legislation 
shall be identified and accessible for the organisation (6.3.1.1) and 
that applicable legislation on forest management shall be followed 
by the certificate holder (6.3.1.2). However, while these indicators 
include legislation in relation to forest management and forest 
management practices, they do not appear to include legislation 
regulating offshore trading and transfer pricing. 

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018.   

Findings at the national level 

 
 
 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

and taxes. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 
PEFC ST 1003: 2018 

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 

341 

Brazil national-level evaluation covered the requirements of this 
indicator. For Russia there is no legislation related to offshore 
trading and therefore is not applicable. China and Romania do not 
cover the requirements of this indicator. Although, according to the 
findings from C.2.1.1, national standards assessed on this project 
has been developed based on the previous version of Forest 
Management standard.  

Justification 

This indicator is concluded as not covered for single and group 
forest management certification. Requirements that ensure 
compliance with legislation regulating offshore trading and transfer 
pricing do not appear to be included by PEFC International as a 
requirement within forest management standards. 

Findings 

Single Forest management certification  
There are generic indicators stating that all applicable legislation 
shall be identified and accessible for the organisation (6.3.1.1) and 
that applicable legislation on forest management shall be followed 
by the certificate holder (6.3.1.2). However, while these indicators 
include legislation in relation to forest management and forest 
management practices, they do not appear to include legislation 
covering export/import licenses, and product classification related to 
customs (codes, quantities, qualities and species). 

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018.   

Findings at the national level 
Russia, Romania national-level evaluation corroborate the not 
coverage finding at the international level.  Brazil national-level 
evaluation covered the requirement of this indicator. For China there 
is no possible for forest management entities to export products and 
therefore is not applicable. Although, according to the findings from 

Not 
Covered 

A.1a.5.4  Customs 

regulations 

A.1a.5.4.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
covering areas 
such as 
export/import 
licenses, and 
product 
classification 
related to 
customs (codes, 
quantities, 
qualities and 
species). 

 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1a.5.5  CITES 

applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regi onal, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 

C.2.1.1, national standards assessed on this project has been 
developed based on the previous version of Forest Management 
standard. 

Justification 

This indicator is concluded as not covered for single and group 
forest management certification. Requirements that ensure 
compliance with legislation regulating export/import licenses, and 
product classification related to customs (codes, quantities, qualities 
and species), do not appear to be included by PEFC International as 
a requirement within forest management standards. 

PEFC ST 1003: 2018  

Findings 

Covered 

8.4.3 The standard requires that protected, threatened and endangered 
plant and animal species shall not be exploited for commercial purposes. 
Where necessary, measures shall be taken for their protection and, 
where relevant, to increase their population. 
Note: The requirement does not preclude trade according to CITES 
requirements. 

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obli gations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 

Single Forest management certification  
There are generic indicators stating that all applicable legislation 
shall be identified and accessible for the organisation (6.3.1.1) and 
that applicable legislation on forest management shall be followed 
by the certificate holder (6.3.1.2). However, while these indicators 
include legislation in relation to forest management and forest 
management practices, they do not appear to include legislation that 
ensures compliance with legislation related to CITES permits. 

According to 8.4.3. the threatened and endangered plant and animal 
species shall not be exploited for commercial purposes and should 
be protected. However, there is no specific reference to legal 
obligations related to this activity. 

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST  1003: 2018.   

Findings at the national level 
Brazil Russia and China national level assess  this indicator as 
covered. For Romania, this indicator is not applicable. Although, 
according to the findings from C.2.1.1, the national standards 
assessed  on this project have been developed based on the 
previous version of international Forest Management standard. 

A.1a.5.5.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
related to 
CITES permits 
(the Convention 
on International 
Trade in 
Endangered 
Species of Wild 
Fauna and 
Flora, also 
known as the 
Washington 
Convention). 

342 

 
 
 
 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 
applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 

PEFC ST 2002:2020 Appendix 1 “1.4.: The organisation procuring raw 
material originating from species listed in Appendix I to III of CITES shall 
comply with applicable legislation relating to CITES.” 
… 
PEFC ST 1003: 2018 

6.3.1.1 The standard requires that the organisation shall identify and 
have access to the legislation applicable to its forest management and 
determine how these compliance obligations apply to the organisation. 

Note: For a country which has signed a FLEGT Voluntary Partnership 
Agreement (VPA) between the European Union and the producing 
country, the “legislation applicable to forest management” is defined by 
the VPA agreement. 

6.3.1.2 The standard requires that the organisation shall comply with 
applicable local, national and  international legislation on forest 
management, including but not limited to forest management practices; 
nature and environmental protection; protected and endangered 
species; property, tenure and land-use rights for indigenous peoples, 
local communities or other affected stakeholders; health, labour and 
safety issues;  anti-corruption and the payment of applicable royalties 
and taxes. 

PEFC GD 1007: 2017 

5 PEFC Sustainability Benchmark 
The objective of the endorsement process is to determine whether an 
applicant system meets the PEFC Sustainability Benchmark. The 

343 

Justification 

This indicator is concluded as covered for single and group forest 
management certification. On the assessment of national schemes, all 
assessed  standards covered these requirements even if the standard is 
developed based on a previous version of the standard. Therefore, the 
conclusion of this indicator is covered based on assessment from the 
national level 

Not 
Covered 

Findings 

Single Forest management certification  
There are generic indicators stating that all applicable legislation 
shall be identified and accessible for the organisation (6.3.1.1) and 
that applicable legislation on forest management shall be followed 
by the certificate holder (6.3.1.2). However, while these indicators 
include legislation in relation to forest management and forest 
management practices, they do not appear to include requirements 
that ensure compliance with legislation covering due diligence/due 
care procedures. 

Group Forest management certification  
According to PEFC GD 1007: 2017, group certification follows the 
requirements as per PEFC ST 1003: 2018.   

Findings at the national level 
Brazil national-level evaluation covered the requirements of this 
indicator. Romania national-level evaluation does not cover the 
requirements of this indicator as there is no specific reference 
related to legislation covering due diligence/due care procedures. In 
China and Russia, this indicator is not applicable, as no legislation 

A.1a.5.6  Legislation 

requiring due 
diligence / due 
care 
procedures 

A.1a.5.6.1 The 
scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
covering due 
diligence/due 
care 
procedures, 
including e.g. 
due 
diligence/due 
care systems, 
declaration 
obligations, and 
/or the keeping 
of trade related 
documents, 
legislation 
establishing 

 
 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

procedures to 
prevent trade in 
illegally 
harvested 
timber and 
products 
derived from 
such timber, etc. 

applicant system, submitted for PEFC Council endorsement and mutual 
recognition shall demonstrate conformance with the following PEFC 
requirements: 
- the content of the (regional, national or sub-national) forest 
management certification standard(s) shall meet the requirements of 
PEFC ST 1003, Sustainable Forest Management – Requirements; 
… 
- where group certification of forest management is part of the system, 
the group certification model shall meet the requirements of PEFC ST 
1002, Group Forest Management Certification – Requirements; 
… 

requiring due diligence is in place. Although, according to the 
findings from C.2.1.1, national standards assessed on this project 
has been developed based on the previous version of Forest 
Management standard. 

Justification 

This indicator is concluded as not covered for single and group 
forest management certification. Requirements that ensure 
compliance with legislation covering due diligence/due care 
procedures do not appear to be included by PEFC International as a 
requirement to be included within forest management standards. 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1b Legal Requirements at the forest level - Input from non-PEFC certified forest 

This section relates to  requirements  of the Scheme  that applies  to Certificate  Holders  applying  the normative  requirements  of the Scheme  relating  to its due diligence  system. The standard 
assessed in this section: PEFC  ST  2002: 2020, Indicator  3.7 and Appendix 1.   
Note:  Section  A is split into tw o components:  A.1a w ith findings related  to a forest certified by PEFC  and A.1b w ith findings related to the  non-certified forest subject to Controlled  Sources 
requirements. 

A.1b.1 Rights to harvest 
tim ber w ithin legally 
gazetted boundaries 

A.1b.1.1  Land tenure 

and 
management 
rights 

A.1b.1.1.1. The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
covering land 
tenure rights, 
including 
customary rights 

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

Findings 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Partially 
Covered 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 

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Conclusion 

Findings and Justification 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

According to the definition of Controversial sources (3.7), legislation 
covering land tenure rights are required to be met for indigenous 
peoples, local communities or other affected stakeholders. However, 
a specific reference to legislation in case when there are no 
indigenous peoples, local communities or other affected 
stakeholders is not made.  

Justification 

This indicator is concluded as partially covered for controlled 
sources.  A specific reference is made to compliance with legislation 
covering land tenure rights for indigenous peoples, local 
communities or other affected stakeholders. However, a reference to 
legislation in case when there are no indigenous peoples, local 
communities or other affected stakeholders is not made.  

Code 

Criterion 

Indicators 
as well as 
management 
rights.  

Standard reference 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due di ligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

7.1.2 For PEFC product groups where only input material used was 
delivered with a PEFC claim by a supplier covered by a PEFC 
recognised certificate, an organisation may implement the PEFC DDS 
by meeting the following requirements: 

a) In order to enable PEFC certified and uncertified entities further down 
the supply chain to implement a DDS, the organisation shall, upon 
request, provide the information specified in Appendix 1, 2.1 for material 
passed on with a PEFC claim. If the organisation does not possess  the 
requested information, the request shall be passed on to relevant 
supplier(s) of the organisation (Appendix 1, 2.2). 

b) Where internal or external substantiated concerns on the origin of 
input material from controversial sources are raised, the organisation 
shall follow up on these concerns following Appendix 1, 4. 

c) The organisation shall define, document and implement a 
commitment and a procedure, also covering forest and tree based 
material/products not covered by the organisation’s PEFCchain of 
custody, ensuring that where it is known to the organisation, or where it 
has received substantiated concerns, that forest and tree based 
material/products originates in illegal sources (controversial sources, 
3.7a), it shall not be placed on the market until the concern has been 
resolved in accordance with Appendix 1, 4. 

PEFC ST 2002: 2020 Appendix 1 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

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Code 

Criterion 

Indicators 
A.1b.1.1.2. The 
Scheme shall 
include 
requirements to 
ensure that 
licenses, right of 
tenure and 
management 
rights, have 
been issued: 

i)  according to 
the legally 
prescribed 
procedure, 

ii) in compliance 
with third 
parties' legal 
rights 
concerning 
tenure, 

iii) specifying 
the legally-
gazetted 
boundaries, 
and; 

iv) with absence 
of corrupt 
practices. 

Standard reference 
PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

Conclusion 
Partially 
Covered 

Findings and Justification 

Findings 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certifi cate Holder derive from controversial sources.  

In reference to parts i), ii) and iii), the definition of Controversial 
sources  (3.7) includes applicable legislation on forest management 
as well as tenure and land-use rights for indigenous peoples, local 
communities or other affected stakeholders. However, the 
requirement that licenses, right of tenure and management rights, 
have been issued according to the legally prescribed procedure – 
and specifying the legally-gazetted boundaries - is not specifically 
included. At the same time, a specific reference to compliance with 
legislation covering land tenure rights is not made in case that 
general there are no indigenous peoples, local communities or other 
affected stakeholders. 

In reference to part iv) there is no mention that issuing of rights and 
licences are issued in the absence of corrupt practices, but 
controversial sources definition (3.7) includes anticorruption 
legilsation.  

Justification 

This indicator is concluded as partially covered for controlled 
sources.  A specific reference to compliance with legislation covering 
the issuing of rights and licences according to the legally prescribed 
procedure, specifying legally-gazetted boundaries, is not made 

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Code 

Criterion 

Indicators 

Standard reference 

A.1b.1.1.3 The 
Scheme shall 
include 
requirements 
that ensure the 
existence of 
legal business 
registration, and 
other relevant 
legally required 
licenses.  

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the  definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

Conclusion 

Partially 
Covered 

Findings and Justification 
within the PEFC normative requirements. There is no inclusion for 
legislation covering land tenure rights if there is no indigenous 
peoples, local communities or other affected stakeholders. 

Findings 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

It is not clear if the definition of controversial sources (3.7) 
“applicable local, national or international legislation on forest 
management, including but not limited to forest management 
practices” includes legal business registration and other relevant 
legally required licenses. 

Justification 

This indicator is concluded as partially covered for controlled 
sources.  A specific reference to compliance with legislation 
regulating legal business registration is not made.  

A.1.1.2  Concession 

licenses 

A.1b.1.2.1 The 
Scheme shall 
include 

PEFC ST 2002: 2020 

Findings 

Partially 
Covered 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 

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Criterion 

ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Conclusion 

Indicators 
requirements 
that ensure 
compliance with 
legislation 
regulating 
procedures for 
the issuing of 
concession 
licenses, 
including use of 
legal methods to 
obtain 
concession 
licenses and 
that licenses are 
covering only 
legally gazetted 
areas 

Standard reference 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

Appendix 1, 6.1 Forest and tree based material/products from un known 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

Findings and Justification 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that th e 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

It is not clear if PEFC International consistently includes legal 
methods to obtain concession licenses within their interpretation of 
controversial sources “applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices”. Simultaneously, normative requirements do 
not explicitly request to include only legally gazetted areas within 
concession licenses. 

Justification 

This indicator is concluded as partially covered for controlled 
sources.  It is not clear if PEFC International consistently include s 
legal methods to obtain concession licenses within their 
interpretation of controversial sources, as well as ensuring that 
licences only cover legally gazetted areas. 

A.1b.1.3  Management 
and 
harvesting 
planning 

A.1b.1.3.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 

Findings 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 

Partially 
Covered 

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Criterion 

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Indicators 
legislation and 
legal obligations 
for management 
planning, 
including 
conducting 
forest 
inventories, 
having a forest 
management 
plan and related 
planning and 
monitoring. 

Standard reference 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due di ligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

Findings and Justification 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Conclusion 

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

It is not clear if the definition of controversial sources “applicable 
local, national or international legislation on forest management, 
including but not limited to forest management practices” includes 
compliance with legislation and legal obligations for management 
planning, including conducting forest inventories, having a forest 
management plan and related planning and monitoring. 

Justification 

This indicator is concluded as partially covered for controlled 
sources.  A specific reference to compliance with legislation and 
legal obligations for management planning, including conducting 
forest inventories, having a forest management plan and related 
planning and monitoring is not made within the PEFC normative 
requirements.  

A.1b.1.3.2 The 
Scheme shall 
include 
requirements 
that all legally 
required 
planning 
documents have 
been approved 

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Findings 

Partially 
Covered 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

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Code 

Criterion 

Indicators 
prior to 
implementation 
of forest 
harvesting 
activities. 

Conclusion 

Standard reference 
Forest and tree based material sourced from: 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

Findings and Justification 
Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

It is not clear if the definition of controversial sources “applicable 
local, national or international legislation on forest management, 
including but not limited to forest management practices” includes 
requirements that all legally required planning documents have been 
approved prior to the implementation of forest harvesting activities. 

PEFC ST 2002: 2020 Appendix 1 

Justification 

A.1b.1.4  Harvesting 

permits 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

This indicator is concluded as partially covered for controlled 
sources.  A specific reference to requirements that all legally required 
planning documents have been approved prior to the 
implementation of forest harvesting activities is not made within the 
PEFC normative requirements.  

Findings 

Covered 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 

A.1b.1.4.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
regulating the 
issuing of 
harvesting 
permits, 
licenses or other 
legal documents 
required for 

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Code 

Criterion 

Indicators 
specific 
harvesting 
operations. 

Standard reference 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

Findings and Justification 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

Conclusion 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

There are generic indicators (3.7. a) stating wood originated from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1). The definition of controversial sources “applicable 
local, national or international legislation on forest management, 
including but not limited to forest management practices” make it 
impossible to avoid including harvesting licenses. 

Justification 

This indicator is concluded as covered for controlled sources.  

Payments 

A.1b.2 
for 
harvest  rights  and  timber 
including duties rel ated to 
timber harvesting 

A.1b.2.1  Payment of 

royalties and 
harvesting 
fees 

A.1b.2.1.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
covering 
payment of all 
legally required 
forest 
harvesting-
specific fees 
such as 
royalties, 

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

Findings 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Partially 
Covered 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 

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Code 

Criterion 

Indicators 
stumpage fees 
and other 
volume-based 
fees, as  well as 
land area taxes 
or fees. 

Standard reference 
applicable royalties and taxes. 

Findings and Justification 
sourced by the Certificate Holder derive from controversial sources.  

Conclusion 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

There are generic indicators (3.7. a) stating wood originated  from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

It is not clear if the definition of controversial sources “applicable 
local, national or international legislation on forest management, 
including but not limited to…the payment of applicable royalties and 
taxes” includes compliance with legislation covering payment of all 
legally required forest harvesting-specific fees such as stumpage 
fees and other volume-based fees, as well as land area taxes or 
fees. 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

Justification 

A.1b.2.2  Value-added 

taxes and 
other sales 
taxes 

A.1b.2.2.2 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
covering 
different types 
of sales taxes 
that apply to the 
material being 
sold, including 
selling material 
as growing 
forest (standing 
stock  sales). 

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 

352 

Partially 
Covered 

This indicator is concluded as partially covered for controlled 
sources.  A specific reference to compliance with legislation covering 
payment of stumpage fees and other volume-based fees, as well as 
land area taxes or fees is not made within the PEFC normative 
requirements.  

Findings 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated from 

 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Standard reference 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

Findings and Justification 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

Conclusion 

It is not clear if the definition of controversial sources “applicable 
local, national or international legislation on forest management, 
including but not limited…to the payment of applicable royalties and 
taxes” includes compliance with legislation covering VAT and other 
sales taxes that apply to the material being sold, including selling 
material as growing forest (standing stock sales). 

Justification 

This indicator is concluded as partially covered for controlled 
sources.  A specific reference to compliance with legislation covering 
VAT and other sales taxes that apply to the material being sold, 
including selling material as growing forest (standing stock sales) is 
not made within the PEFC normative requirements.  

Code 

Criterion 

Indicators 

forest 

A.1b.3  Timber  harvesting, 
including  environmental 
legislation 
and 
forest 
including 
management 
and 
biodiversity  conservation, 
where  directly  related  to 
timber harvesting 

A.1b.3.1  Timber 

harvesting 
regulations 

A.1b.3.1.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legal obligations 
for harvesting 
techniques and 
technology 
including timing 

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

Findings 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Partially 
Covered 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 

353 

 
 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

A.1b.3.2  Protected 
sites and 
species 

Indicators 
of harvest, 
selective 
cutting, shelter 
wood 
regeneration, 
clear felling, 
transport of 
timber from 
felling sites and 
seasonal 
limitations etc. 

This includes 
the mis-use of 
salvaging 
permits or other 
specific 
ministerial 
permits, with the 
intention of 
circumventing 
harvest 
regulations 

A.1b.3.2.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
related to 
protected areas 
as well as 
protected, rare, 
or endangered 
species, 

Standard reference 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

Conclusion 

Findings and Justification 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

It is not clear if the definition of controversial sources “applicable 
local, national or international legislation on forest management, 
including but not limited to forest management practices” includes 
compliance with legal obligations for harvesting techniques and 
technology including the timing of harvest, selective cutting, shelter 
wood regeneration, clear felling, transport of timber from felling sites 
and seasonal limitations. 

Justification 

This indicator is concluded as partially covered for controlled 
sources.  Specific references to compliance with legal obligations for 
harvesting techniques and technology including the timing of 
harvest, selective cutting, shelter wood regeneration, clear felling, 
transport of timber from felling sites and seasonal limitations are not 
made within the PEFC normative requirements.  

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

Findings 

Covered 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 

354 

 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 
including their 
habitats and 
potential 
habitats. 

Standard reference 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

Findings and Justification 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

Conclusion 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

There are generic indicators (3.7. a) stating wood originated from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

It is considered that the definition of controversial sources 
“applicable local, national or international legislation on forest 
management, including but not limited to…nature and environmental 
protection, protected and endangered species” includes compliance 
with legislation related to protected areas as well as protected, rare, 
or endangered species, including their habitats and potential 
habitats. 

Justification 

This indicator is concluded as covered for controlled sources.  

A.1b.3.2.2 
Requirements 
that ensure 
compliance with 
legislation 
related to 
protected areas 
and habitats, 
shall include 
that the 
identification of 
protected areas 
is conducted 
according to the 
legal 
requirements. 

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 

Findings 

Partially 
Covered 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated from 
cases  when applicable legislation is not followed it is not allowed 

355 

 
 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

A.1b.3.3  Environmental 

requirements 

A.1b.3.3.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
related to 
environmental 
impact 
assessment  in 
connection with 
harvesting, 
acceptable 
levels of 
damage and 
disturbance of 
soil resources, 
establishment of 
buffer zones 
(e.g. along 
watercourses, 
open areas, 
breeding sites), 

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from : 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

6.1.4 The organisation shall only use PEFC certified materi al and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 

356 

Findings and Justification 
(Appendix 1, 6.1).  

Conclusion 

It is not clear if the definition of controversial sources “applicable 
local, national or international legislation on forest management, 
including but not limited to…forest management practices; nature 
and environmental protection; protected and endangered species” 
includes compliance with legislation related to protected areas and 
habitats including identification of protected areas. 

Justification 

This indicator is concluded as partially covered for controlled 
sources.  A specific reference to compliance with legislation related 
to protected areas and habitats including identification of protected 
areas is not made within the PEFC normative requirements.  

Findings 

Partially 
Covered 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

It is not clear if the definition of controversial sources “applicable 
local, national or international legislation on forest management, 
including but not limited to…forest management practices; nature 

 
 
Code 

Criterion 

A.1b.3.4  Health and 

safety 

Indicators 
maintenance of 
retained trees 
on felling sites, 
seasonal 
limitations on 
harvesting, and 
environmental 
requirements for 
forest 
machinery. 

A.1b.3.4.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
Health & Safety 
legislation. 

ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Standard reference 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 

357 

Conclusion 

Findings and Justification 
and environmental protection; protected and endangered species” 
includes compliance with legislation related to environmental impact 
assessment  in connection with harvesting, acceptable levels of 
damage and disturbance of soil resources, the establishment of 
buffer zones (e.g. along watercourses, open areas, breeding sites), 
maintenance of retained trees on felling sites, seasonal limitations 
on harvesting, and environmental requirements for forest machinery. 

Justification 

This indicator is concluded as partially covered for controlled 
sources.  Specific references are not made within the PEFC 
normative requirements to comply with legislation related to 
environmental impact assessment in connection with harvesting, 
acceptable levels of damage and disturbance of soil resources, the 
establishment of buffer zones (e.g. along watercourses, open areas, 
breeding sites), maintenance of retained trees on felling sites, 
seasonal limitations on harvesting, and environmental requirements 
for forest machinery. 

Findings 

Covered 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated from 
cases  when applicable legislation is not followed it is not allowed 

 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

A.1b.3.5  Legal 

employment 

A.1b.3.5.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation for 
employment of 
personnel 
involved in 
harvesting (and 
in-forest 
processing) 
activities 
including but not 
limited to 
requirements 
for: contracts 
and working 
permits, 
obligatory 
insurances, 
certificates of 
competence 
and other 
training 
requirements, 

Standard reference 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendi x 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

358 

Findings and Justification 
(Appendix 1, 6.1).  

Conclusion 

The definition of controversial sources “applicable local, national or 
international legislation on forest management, i ncluding but not 
limited to…health, labour and safety issues” includes compliance 
with Health & Safety legislation. 

Justification 

This indicator is concluded as covered for controlled sources.  

Findings 

Partially 
Covered 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

It is not clear if the definition of controversial sources “applicable 
local, national or international legislation on forest management, 
including but not limited to…health, labour and safety issues” 
includes compliance with legislation for contracts and working 
permits, obligatory insurances, certificates of competence and other 

 
 
Code 

Criterion 

Indicators 
and payment of 
social and 
income taxes.  

A.1b.3.5.2 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation for 
minimum 
working age and 
minimum age 
for personnel 
involved in 
hazardous work, 
legislation 
against forced 
and compulsory 
labour, and 
discrimination 
and legislation 
allowing for 
freedom of 
association. 

ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Standard reference 
PEFC ST 2002: 2020 Appendix 1 

Findings and Justification 
training requirements, and payment of social and income taxes. 

Conclusion 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

f) Activities where the spirit of the ILO Declaration on Fundamental 
Principles and Rights at Work (1998) is not met. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

Justification 

This indicator is concluded as partially covered for controlled 
sources.  A specific reference to compliance with legislation 
contracts and working permits, obligatory insurances, certificates of 
competence and other training requirements, and payment of social 
and income taxes, is not made within the PEFC normative 
requirements.   

Findings 

Covered 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

It is not clear if the definition of controversial sources part a) 
“applicable local, national or international legislation on forest 
management, including but not limited to…health, labour and safety 
issues” includes compliance with legislation for minimum working 
age and the minimum age for personnel involved in hazardous work, 
legislation against forced and compulsory labour, and discrimination 
and legislation allowing for freedom of association. However, part f) 

359 

 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

PEFC ST 2002: 2020 Appendix 1 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

Findings and Justification 
would cover this area. 

Justification 

This indicator is concluded as covered for controlled sources. 

Conclusion 

A.1b.4  Third  parties’  legal 
rights  concerning  use and 
tenure that are affecte d by 
timber harvesting 

A.1b.4.1  Customary 

rights 

A.1b.4.1.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
respect for 
customary 
tenure rights 
relevant to 
forest 
harvesting 
activities. 

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

360 

Findings 

Covered 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk i n 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated  from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

The definition of controversial sources “applicable local, national or 
international legislation on forest management, including but not 
limited to…property, tenure and land-use rights for indigenous 
peoples, local communities or other affected stakeholders” includes 
compliance with respect for customary tenure rights relevant to 

 
 
 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 
Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

Findings and Justification 
forest harvesting activities.  

Justification 

Conclusion 

A.1b.4.1.2 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legal obligations 
concerning 
benefit sharing 
they have 
negotiated with 
communities or 
customary 
users.  E.g. 
social 
agreements or 
social 
responsibility 
agreements or 
cahier de 
charges, 
dependent on 
the country. 

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

f) Activities where the spirit of the ILO Declaration on Fundamental 
Principles and Rights at Work (1998) is not met. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

361 

This indicator is concluded as covered for controlled sources.  

Findings 

Covered 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

According to PEFC ST 2002: 2020 – 3.7 f) forest practices and 
operations shall be conducted in recognition of the established 
framework of legal, customary and traditional rights such as outlined 
in ILO. ILO 169 (Articles 2, 15 and 35) address the sharing of 
benefits from the exploitation of resources to which they hol d rights.  

Justification 

This indicator is concluded as covered for controlled sources. 
Legislation regulation sharing of benefits is at least indirectly 
addressed (through ILO 169) in the normative requirement at the 
level of PEFC International. 

 
 
 
Criterion 
Code 
A.1b.4.2  Free, Prior 

and Informed 
Consent 

ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Indicators 
A.1b.4.2.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
the 
internationally 
adopted 
principles of 
'Free, Prior and 
Informed 
Consent' in 
connection with 
granting rights 
to forest 
management. 

Standard reference 

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

g) Activities where the spirit of the United Nations Declaration on the 
Rights of Indigenous Peoples (2007) is not met. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

Findings and Justification 

Findings 

Conclusion 
Covered 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

It is not clear if the definition of controversial sources part a) 
“applicable local, national or international legislation on forest 
management, including but not limited to…property, tenure and 
land-use rights for indigenous peoples” includes compliance with the 
internationally adopted principles of 'Free, Prior and Informed 
Consent' in connection with granting rights to forest management. 
However, in the case of part g), this covers the indicator. UNDRIP 
(Article 32) address the exploitation of resources to which 
Indigenous and Tribal Peoples hold rights, via processes that imbibe 
the principles of FPIC.  

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

Justification 

UNDRIP 
Article 32 
… 

2. States shall consult and cooperate in good faith with the indigenous 
peoples concerned through their own representative institutions in order 

362 

This indicator is concluded as covered for controlled sources.   

 
 
 
Code 

Criterion 

Indicators 

A.1b.4.3 

Indigenous 
and traditional 
peoples' rights 

A.1b.4.3.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
national 
legislation and 
international 
conventions 
ratified that 
respect the 
tenure rights of 
indigenous and 
tribal peoples to 
forest land as 
well as their 
right to FPIC. 

ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Standard reference 
to obtain their free and informed consent prior to the approval of any 
project affecting their lands or territories and other resources, particularly 
in connection with the development, utilization or exploitation of mineral, 
water or other resources. 

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

g) Activities where the spirit of the United Nations Declaration on the 
Rights of Indigenous Peoples (2007) is not met. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product group s. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

Findings and Justification 

Conclusion 

Findings 

Covered 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

The definition of controversial sources part a) “applicable local, 
national or international legislation on forest management, including 
but not limited to…property, tenure and land-use rights for 
indigenous peoples” includes compliance with legislation and 
international conventions ratified that respect the tenure rights of 
indigenous and tribal peoples. Furthermore, part g) strengthens 
coverage of the indicator. UNDRIP (Article 32) address the 
exploitation of resources to which Indigenous and Tribal Peoples 
hold rights, via processes that imbibe the principles of FPIC.  

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

Justification 

This indicator is concluded as covered for controlled sources.  

363 

 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1b.5 Trade and custom s,  
in  so  far  as  the  forest 
sector is concerned 

A.1b.5.1  Classification 

of species, 
quantities, 
qualities 

A.1b.5.1.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
regulating how 
harvested 
material is 
classified in 
terms of 
species, 
Quantities and 
qualities in 
connection with 
trade and 
transport.  

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

6.1.4 The organisation shal l only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

Findings 

Not Covered 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

The definition of controversial sources (3.7) includes forest and tree-
based material sourced from activities not complying with applicable 
local, national or international legislation on forest management, 
including forest management practices and other areas of law. This 
definition does not appear to include legisl ation regulating how 
harvested material is classified in terms of species, quantities and 
qualities in connection with trade and transport. 

Justification 

This indicator is concluded as not covered for controlled sources. 
Legislation regulating how harvested material is classified in terms 
of species, quantities and qualities in connection with trade and 
transport, does not appear to be included by PEFC International 

364 

 
 
 
 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

A.1b.5.2  Trade and 

transport 

A.1b.5.2.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legally required 
trading permits 
as well as 
legally required 
transport 
documents that 
accompany 
transport of 
wood from 
forest 
operations. 

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

Findings and Justification 
within the definition of controversial sources in the Chain of Custody 
standard. 

Conclusion 

Findings 

Not Covered 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

The definition of controversial sources (3.7) includes forest a nd tree-
based material sourced from activities not complying with applicable 
local, national or international legislation on forest management, 
including forest management practices and other areas of law. This 
definition does not appear to include compliance with legally 
required trading permits as well as legally required transport 
documents that accompany the transport of wood from forest 
operations. 

nal government sanctions restricting the export/import of such forest and  
tree based products 

Justification 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

This indicator is concluded as not covered for controlled sources. 
Legislation compliance with legally required trading permits as well 
as legally required transport documents that accompany the 
transport of wood from forest operations do not appear to be 
included by PEFC International within the definition of controversial 

365 

 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

A.1b.5.3  Offshore 

trading and 
transfer 
pricing 

A.1b.5.3.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
regulating 
offshore trading 
and transfer 
pricing.  

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there i s “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

Conclusion 

Not Covered 

Findings and Justification 
sources  in the Chain of Custody standard. 

Findings 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

The definition of controversial sources (3.7) includes forest an d tree-
based material sourced from activities not complying with applicable 
local, national or international legislation on forest management, 
including forest management practices and other areas of law. This 
definition does not appear to include compliance with legislation 
regulating offshore trading and transfer pricing. 

PEFC ST 2002: 2020 Appendix 1 

Justification 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

This indicator is concluded as not covered for controlled sources. 
Legislation regulating offshore trading and transfer pricing does not 
appear to be included by PEFC International within the definition of 
controversial sources in the Chain of Custody standard. 

366 

 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Criterion 
Code 
A.1b.5.4  Customs 

regulations 

Indicators 
A.1b.5.4.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
covering areas 
such as 
export/import 
licenses, and 
product 
classification 
related to 
customs (codes, 
quantities, 
qualities and 
species). 

Standard reference 

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

Findings and Justification 

Findings 

Conclusion 
Not Covered 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated  from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

The definition of controversial sources (3.7) includes forest and tree -
based material sourced from activities not complying with applicable 
local, national or international legislation on forest management, 
including forest management practices and other areas of law. This 
definition does not appear to include compliance with legislation 
covering areas such as  export/import licenses, and product 
classification related to customs (codes, quantities, qualities and 
species). 

Justification 

This indicator is concluded as partially covered for controlled 
sources.  A specific reference to compliance with legislation covering 
areas such as export/import licenses and product classification 
related to customs is not made within the PEFC normative 
requirements. In addition, some specific cases in relation to the risk 
assessment  tables in Appendix 1 mean that risks  may not always be 
captured.  

367 

 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

A.1b.5.5  CITES 

A.1b.5.5.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
related to 
CITES permits 
(the Convention 
on International 
Trade in 
Endangered 
Species of Wild 
Fauna and 
Flora, also 
known as the 
Washington 
Convention). 

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection ; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligen ce in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

368 

Findings and Justification 
This indicator is concluded as not covered for controlled sources. 
Legislation regulating export/import licenses, and product 
classification related to customs (codes, quantities, qualities and 
species), does not appear to be included by PEFC International 
within the definition of controversial sources in the Chain of Custody 
standard. 

Conclusion 

Findings 

Not Covered 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controlled sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

The definition of controversial sources (3.7) includes forest an d tree-
based material sourced from activities not complying with applicable 
local, national or international legislation on forest management, 
including forest management practices and other areas of law. This 
definition does not appear to include compliance with legislation 
related to CITES permits. 

Justification 

This indicator is concluded as not covered for controlled sources. 
Legislation related to CITES permits does not appear to be included 
by PEFC International within the definition of controversial sources 

 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

Code 

Criterion 

Indicators 

Standard reference 

A.1b.5.6  Legislation 

requiring due 
diligence / due 
care 
procedures 

A.1b.5.6.1 The 
scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
covering due 
diligence/due 
care 
procedures, 
including e.g. 
due 
diligence/due 
care systems, 
declaration 
obligations, and 
/or the keeping 
of trade related 
documents, 
legislation 
establishing 
procedures to 
prevent trade in 
illegally 
harvested 
timber and 
products 
derived from 
such timber, etc. 

PEFC ST 2002: 2020 

3.28 PEFC controlled sources 

Material category covering forest and tree based material for which an 
organisation has determined through its Due Diligence System that 
there is “negligible risk” that the material is from controversial sources. 

3.7 Controversial sources 

Forest and tree based material sourced from: 

a) Activities not complying with applicable local, national or international 
legislation on forest management, including but not limited to forest 
management practices; nature and environmental protection; protected 
and endangered species; property, tenure and land-use rights for 
indigenous peoples, local communities or other affected stakeholders; 
health, labour and safety issues; anticorruption and the payment of 
applicable royalties and taxes. 

6.1.4 The organisation shall only use PEFC certified material and PEFC 
controlled sources material as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, except 
recycled material, the organisation shall exercise due diligence in line 
with the PEFC Due Diligence System (DDS) for the avoidance of 
material from controversial sources laid down in Appendix 1 of this 
standard. Thereby the organisation shall establish that for material used 
as input for PEFC product groups there is “negligible risk” that it 
originates from controversial sources and that it meets the definition of 
PEFC controlled sources material. 

PEFC ST 2002: 2020 Appendix 1 

Appendix 1, 6.1 Forest and tree based material/products from unknown 
sources  or from controversial sources shall not be included in a PEFC 
product group. 

Findings and Justification 
in the Chain of Custody standard. 

Findings 

Conclusion 

Not Covered 

According to PEFC ST 2002: 2020 6.1.4, the certificate holder may 
choose to use controll ed sources in their products. Controlled 
sources  are defined by PEFC ST 2002: 2020 3.28, as inputs into a 
due diligence system which are concluded with negligible risk in 
relation to the definition in the standard of Controversial sources 
(PEFC ST 2002: 2020 3.7).  

Requirement 7.1.1 of PEFC ST 2002: 2020, describes that the 
certificate holder shall implement a Due Diligence System (DDS) 
when sourcing input material which is not PEFC-certified. The 
requirements for due diligence are contained within Appendix 1 of 
standard (PEFC ST 2002: 2020), the objective of which is to 
minimise the risk that non-certified materials or products which are 
sourced by the Certificate Holder derive from controversial sources.  

There are generic indicators (3.7. a) stating wood originated from 
cases  when applicable legislation is not followed it is not allowed 
(Appendix 1, 6.1).  

The definition of controversial sources (3.7) includes forest and tree -
based material sourced from activities not complying with applicable 
local, national or international legislation on forest management, 
including forest management practices and other areas of law. This 
definition does not appear to include requirements that ensure 
compliance with legislation covering due diligence/due care 
procedures. 

Justification 

This indicator is concluded as not covered for controlled sources. 
Requirements that ensure compliance with legislation covering due 
diligence/due care procedures do not appear to be included by 
PEFC International within the definition of controversial sources in 
the Chain of Custody standard. 

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C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

A.2a Legal requirements for supply chain entities - Certificate Holders 

Principle A.2a relates to  requirements for C ertificate holders to  meet trade, transport and customs laws (within  the country  of harvest), in so far as the forest sector is 
concerned. The standard assessed in this  section is PEFC  ST 2002:  2020  

Note: Section A2 is split into  two components: A.2a with findings  related to requirements for C ertificate holders and A.2b wi th findings  related to requirements for entities 
subject to C ontrolled Sources requirements. 

A.2a.1. Legal registration   

PEFC  ST 2003: 2020 
7.2.1 The ce rtification body shall obtain from the client 
organisation, as a minimum, the following 
inform ation and documentation as a part of the application for 
ce rtification: 
a) corporate e ntity, name, address and legal status 

A . 2a.1.1  Le gal 

R e gistration 

A . 2a.1.1.1 
The  scheme 
shall include 
re quirements 
that e nsure 
the  e x istence 
of le gal 
business 
re gistration, 
and other 
re le vant 
le gally 
re quire d 
lice nses. 

F i ndings 

Not 
C ove red 

According to 7.2.1 of PEFC ST 2003: 2020, the legal status 
of the  ce rtificate holder is checked during the audit. The 
C e rtification Body must gather information in re lation to 
le gal status, but there is no re quirement for ce rtificate 
holders that ensures the existence of legal business 
re gistration, and other re levant legally re quired lice nses.   

It is the  case that ISO 9000: 2015 re quires ce rtification 
bodies to document legal status as a part of the application 
for ce rtification. Howe ver, legal business registration or 
othe r re levant legally re quired licenses are not specifically 
re quire d to be ascertained or e valuated. At the same time, 
the  process of documenting the le gal status is carried out 
as a part of the application and is not subject to e valuation  
as part of annual audits. 

J ustification 

This indicator is concluded as Not Covered for certificate 
holders. The C ertification Body must gather information in 
re lation to legal status, but there  is no re quirement to ensure 
the  e x istence of legal business re gistration, or other re levant 

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I ndicators 

S t andard re ference 

F i ndings and Justification 

le gally re quire d licenses. 

A.2a.2 Taxes and fees 

A . 2a.2.1  Paym ent of 

tax e s, 
royalties and 
fe e s 

A . 2a.2.2  Value -added 

tax e s and 
othe r sales 
tax e s 

A 2a.2.1.1 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance 
with 
le gislation 
cove ring 
paym ent of all 
le gally 
re quire d 
tax e s, 
royaltie s and 
fe e s. 

A 2a.2.2.1 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance 
with 
le gislation 
cove ring 
diffe rent types 
of sales taxes 
that apply to 
the  m aterial 
be ing sold, 
including 
se lling 

C onclusion 

Not 
C ove red 

F i ndings 

The re  is no re quirement to ensure compliance with 
le gislation covering payment of all legally required taxes, 
royaltie s and fees, which is applicable to the C ertificate 
holder itself.  

J ustification 

This indicator is concluded as not covered for ce rtificate 
holders. PEFC International has no re quirement to e nsure  
com pliance with le gislation covering payment of all legally 
re quire d taxes, royalties and fees, applicable to the C ertificate 
holder itself. 

F i ndings 

Not 
C ove red 

The re  is no re quirement to ensure compliance with 
le gislation regulating differe nt types of sales taxes that 
apply to the m aterial being sold, including selling material 
as growing forest (standing stock sales), which is applicable 
to the  C ertificate holder itself.  

J ustification 

This indicator is concluded as not covered for ce rtificate 
holders. PEFC International has no re quirement to e nsure  
com pliance with le gislation re gulating different types of sales 
tax e s that apply to the material being sold, including selling 
m ate rial as growing forest (standing stock sales), applicable 

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C ode 

C riterion 

I ndicators 

S t andard re ference 

m ate rial as 
growing forest 
(standing 
stock  sales). 

A.2a.3 Trade and transport 

A . 2a.3.1  C lassification 

of species, 
quantities, 
qualities 

A . 2a.3.2  Trade  and 
transport 

A . 2a.3.1.1 
The  Scheme 
shall include 
re quirements 
that e nsure 
com pliance 
with 
le gislation 
re gulating 
how products 
are  classified 
in te rm s of 
spe cies, 
volum es and 
qualities in 
conne ction 
with trade  and 
transport.  

A . 2a.3.2.1 
The  Scheme 
shall include 
re quirements 
that e nsure 
com pliance 
with re quired 
trading 
pe rm its as 
we ll as le gally 
re quire d 
transport 

F i ndings and Justification 

to the  C ertificate holder itself. 

C onclusion 

Not 
C ove red 

F i ndings 

The re  is no re quirement to ensure compliance with 
le gislation regulating how products are classified in terms 
of species, volumes and qualities in connection with trade 
and transport, which is applicable to the Certificate holder 
itse lf.  

J ustification 

This indicator is concluded as not covered for ce rtificate 
holders. PEFC International has no re quirement to e nsure  
com pliance with le gislation re gulating how products are 
classified in te rms of species, volumes and qualities in 
conne ction with trade and transport, applicable to the 
C e rtificate holder itself. 

F i ndings 

Not 
C ove red 

The re  is no re quirement to ensure compliance with re quired 
trading permits as we ll as legally re quired transport 
docum ents that accompany the transport of wood , which is 
applicable to the C ertificate holder itself.  

J ustification 

This indicator is concluded as not covered for ce rtificate 
holders. PEFC International has no re quirement to e nsure  
com pliance with re quired trading permits as we ll as legally 

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S t andard re ference 

F i ndings and Justification 

C onclusion 

A . 2a.3.3  O ffshore 

trading and 
transfer 
pricing 

A . 2a.3.4  C ustoms 

re gulations 

docum ents 
that 
accom pany 
transport of 
wood. 
A . 2a.3.3.1 
The  Scheme 
shall include 
re quirements 
that e nsure 
com pliance 
with 
le gislation 
re gulating 
offshore 
trading.  

A . 2a.3.3.2 
The  Scheme 
shall include 
re quirements 
that e nsure 
com pliance 
with 
le gislation 
re gulating 
transfer 
pricing. 

A . 2a.3.4.1 
The  Scheme 
shall include 
re quirements 
that e nsure 
com pliance 
with 

re quire d transport documents that accompany the transport 
of wood, applicable to the C ertificate h older itself. 

F i ndings 

The re  is no re quirement to ensure compliance with 
le gislation regulating offshore trading , which is applicable 
to the  C ertificate holder itself.  

J ustification 

This indicator is concluded as not covered for ce rtificate 
holders. PEFC International has no re quirement to e nsure  
com pliance with le gislation re gulating offshore trading, 
applicable to the C ertificate holder itself. 

F i ndings 

The re  is no re quirement to ensure compliance with 
le gislation regulating transfer pricing, which is applicable to 
the  C e rtificate holder itself.  

J ustification 

This indicator is concluded as not covered for ce rtificate 
holders. PEFC International has no re quirement to e nsure  
com pliance with le gislation re gulating transfer pricing, 
applicable to the C ertificate holder itself. 

F i ndings 

The re  is no re quirement to ensure compliance with 
le gislation regulating covering areas such as export/import 
lice nses, and product classification re lated to customs 
(code s, quantities, qualities and species), which is 

Not 
C ove red 

Not 
C ove red 

Not 
C ove red 

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C ode 

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I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

A . 2a.3.5  C ITES 

le gislation 
cove ring areas 
such as 
e x port/import 
lice nses, and 
product 
classification 
re late d to 
customs 
(code s, 
quantities, 
qualities and 
spe cies). 

A . 2a.3.5.1 
The  Scheme 
shall include 
re quirements 
that e nsure 
com pliance 
with 
le gislation 
re late d to 
C ITES permits 
(the  
C onvention on 
Inte rnational 
Trade  in 
Endangere d 
Spe cie s of 
W ild Fauna 
and Flora, 
also known as 
the  
W ashington 
C onvention). 

PEFC  ST 2002: 2020 Appendix 1 
1. Ge ne ral requirements 
… 
1.4 The organisation procuring raw m aterial originating from 
spe cies listed in Appendix I to III of CITES 
shall comply with applicable legislation re lating to C ITES. 

374 

applicable to the C ertificate holder itself.  

J ustification 

This indicator is concluded as not covered for ce rtificate 
holders. PEFC International has no re quirement to e nsure  
com pliance with le gislation re gulating covering areas such as 
e x port/import licenses, and product classification re lated to 
customs (codes, quantities, qualities and species), applicable 
to the  C ertificate holder itself. 

F i ndings 

Partially 
C ove red 

As pe r 7.1.1 of PEFC ST 2002: 2020, the ce rtificate holder 
shall implement a Due Diligence System (DDS) laid down in 
Appe ndix 1, whe n sourcing input m aterial which is not 
PEFC -ce rtified. In such a case, the role of the DDS in 
Appe ndix 1 is to e nsure non-certified materials or products 
which a re  sourced by the Certificate Holder do not derive 
from  controversial sources. The DDS in Appendix 1 is not 
e x pected to be applied to the Certificate holder itself or to 
PEFC -ce rtified material.  

If not im plementing a DDS, there  is no re quirement to 
e nsure compliance with le gislation related to CITES 
pe rm its, which is applicable to the C ertificate holder itself. 
Howe ve r, if the Certificate Holder is implementing a DDS in 
conformance with Appendix 1 of PEFC ST 2002: 2020, then 
ge neral re quirement 1.4 applies, which re quires the 
organisation to comply with applicable legislation re lating to 
C ITES.  

J ustification 

This indicator is concluded as partially covere d for ce rtificate 
holders. If not implementing a DDS, there  is no re quirement 

 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

to e nsure  compliance with le gislation re lated to C ITES 
pe rm its, which is applicable to the C ertificate holder itself. 
Howe ve r, if the Certificate Holder is implementing a DDS in 
conformance with Appendix 1 of PEFC ST 2002: 2020, then 
ge neral re quirement 1.4 applies, which re quires  the 
organisation to comply with applicable legislation re lating to 
C ITES. 

A . 2a.3.6  Le gislation 

re quiring 
due  
dilige nce / 
due  care 
proce dure s 

A . 2a.3.6.1 
The  scheme 
shall include 
re quirements 
that e nsure 
com pliance 
with 
le gislation 
cove ring due 
dilige nce/due 
care  
proce dure s, 
including e.g. 
due  
dilige nce/due 
care  systems, 
de claration 
obligations, 
and /or the 
k e e ping of 
trade  re lated 
docum ents, 
le gislation 
e stablishing 
proce dure s to 
pre ve nt trade 
in ille gally 
harve sted 
tim be r and 

PEFC  ST 2002: 2020  

F i ndings 

Partially 
C ove red 

3.35 R ecycled m aterial 
Fore st and tre e based material that is: 
a) R e covered from waste during a manufacturing process. 
Ex clude d is re utilisation of materials such as re work , re grind or 
scrap ge nerated in a process and capable of being re claimed 
within the  same process that generated it. Ex cluded are by-
products re sulting from primary production processes, such as 
sawm illing by-products (sawdust, chips, bark, etc.) or fore stry 
re sidues (bark, chips from branches, roots, etc.) as they are  
not considered waste. 
b) Ge nerated by households or by commercial, industrial and 
institutional facilities in their role as end-users of the product 
that can no longer be used for its intended purpose. This 
include s returns of 
m ate rial from the distribution chain. 
Note  1: The term “capable of being re claimed within the same 
proce ss that generated it” means that the m aterial generated 
in one  process is continuously re turned to the same proce ss at 
the  same site. An e xample is re sidue generated by a pre ss line 
in a panel board production that continuously re -enters the 
sam e press line. This is not considered as re cycled material. 
Note  2: The definition is based on definitions of ISO 14021. 
Note  3: Different e xamples of recycled material are provided in 
PEFC  GD 2001. 

7.1.1 For all material used as input for a PEFC product group, 
e x ce pt re cycled material, the organisation shall exercise due 

As pe r 7.1.1 of PEFC ST 2002: 2020, the ce rtificate holder 
shall implement a Due Diligence System (DDS) laid down in 
Appe ndix 1, whe n sourcing input m aterial which is not 
PEFC -ce rtified (or re cycled material). In such a case, the 
role  of the DDS in Append ix 1 is to minimises the risk that 
non-certified materials or products which are sourced by 
the  C e rtificate Holder derive from controversial source s.  

Appe ndix 1 is intended to ensure that activities conducte d 
by the  organisation under the scope of this standard 
conform to all applicable timber le gality legislation, 
including trade and customs laws (appendix 1, 1.1). 
Inde ed, Appendix 1 m ay help in this way, howe ver there is 
no specific reference to ensuring compliance with le gislation 
cove ring due diligence/due care procedures, e ither in the 
case  of Appendix 1 or for C ertificate holders which are not 
im plementing a DDS but which m ay still be subje ct to some 
trade  and customs laws.  

J ustification 

This indicator is concluded as partially covere d for ce rtificate 
holders. There  is no specific re ference to ensuring compliance 
with le gislation covering due diligence/due care proce dures, 
e ithe r in the case of Appendix 1 or for C ertificate Holders 
which are  not implementing a DDS but which may still be 
subje ct to some trade and customs laws . 

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C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

products 
de rive d from 
such tim ber, 
e tc. 

dilige nce in line with the PEFC Due Diligence System (DDS) for 
the  avoidance of m aterial from controversial sources laid down 
in Appe ndix 1 of this standard. Thereby the organisation shall 
e stablish that for m aterial used as input for PEFC product 
groups there is “negligible risk” that it originates from 
controve rsial sources and that it m eets the definition of PEFC 
controlled sources m aterial. 

7.1.2 For PEFC  product groups whe re only input material used 
was de livere d with a PEFC claim by a supplier covered by a 
PEFC  re cognised certificate, an organisation may implement 
the  PEFC  DDS by meeting the following requirements:  
a) In order to e nable PEFC certified and uncertified entities 
furthe r down the  supply chain to implement a DDS, the 
organisation shall, upon request, provide the information 
spe cified in Appendix 1, 2.1 for material passed on with a PEFC 
claim . If the organisation does not 
possess the re quested information, the re quest shall be passed 
on to re levant supplier(s) of the organisation (Appendix 1, 
2.2). 
b) W here  internal or e xternal substantiated concerns on the 
origin of input material from controversial sources are raised, 
the  organisation shall follow up on these concerns following 
Appe ndix 1, 4. 
c) The  organisation shall define, document and implement a 
com m itment and a procedure, also covering forest and tre e 
based material/products not covered by the organisation’s 
PEFC   
chain of custody, ensuring that whe re  it is k nown to the 
organisation, or whe re  it has re ceived substantiated conce rns, 
that fore st and tree based material/products originates in 
ille gal source s (controversial sources, 3.7a), it shall not be 
place d on the market until the concern has been resolved in 
accordance with Appendix 1, 4. 

PEFC  ST 2002: 2020 - Appendix 1 

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F i ndings and Justification 

C onclusion 

1.1 In order to help ensure  that activities conducted by the 
organisation under the scope of this standard conform to all 
applicable timber le gality le gislation, including trade and 
customs laws, and to minimise the risk that the procured 
m ate rial originates in controversial source s, the organisation 
shall operate a Due Diligence System (DDS), in accordance 
with the  following e lements of this standard. 

1.3 The organisation shall implement the PEFC  DDS in three 
ste ps relating to:  
a) gathering information 
b) risk  assessment 
c) m anagement of significant risk supplies 

3.1 The organisation shall carry out a risk assessment, 
assessing the risk of procuring raw m aterial from controversial 
source s for all input forest and tre e based material covered by 
the  organisation’s PEFC chain of custody, with the  exception of 
m ate rial/products delivere d with a PEFC claim by a supplier 
with a PEFC  re cognised ce rtificate, as this material can be 
considered as having “negligible risk” of originating in 
controve rsial sources. 

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F i ndings and Justification 

C onclusion 

A.2b Legal requirements for supply chain entities - Non-PEFC certified supply chains 

Principle A.2b relates to requirements of the Scheme that  applies to C ertificate Holders applying the  normative requirements of the Scheme relating to its  due diligence 
system. It asks if the requirements for entities subject to C ontrolled So urces, cover trade, transport and customs laws (within  the country of harvest), in so far as the 
forest sector is concerned. The standard assessed in this  section is PEFC  ST 2002:  2020 Indicator 3.7 and Appendix 1  

Note: Section A2 is split into  two components: A.2a with findings  related to requirements for C ertificate holders and A.2b with findings  related to requirements for en tities 

subject to C ontrolled Sources requirements. 

A.2b.1. Legal registration 

A . 2b.1.1  Le gal 

R e gistration 

A . 2b.1.1.1 The 
sche me shall 
include  
re quirements that 
e nsure the 
e x istence of le gal 
business 
re gistration, and 
othe r re levant 
le gally re quire d 
lice nses. 

PEFC  ST 2002: 2020 

3.28 PEFC controlled sources 

Mate rial category covering forest and tre e based material for which an 
organisation has determined through its Due Diligence System that there  is 
“ne gligible risk” that the material is from controversial sources. 

3.7 C ontroversial source s 

Fore st and tre e based material source d from: 

a) Activitie s not complying with a pplicable local, national or international 
le gislation on forest management, including but not limited to forest 
m anagement practices; nature and e nvironmental protection; protected and 
e ndangered species; property, te nure and land-use rights for indigenous 
pe oples, local communities or other affected stakeholders; health, labour 
and safety issues; anticorruption and the payment of applicable royalties 
and taxes. 

6.1.4 The organisation shall only use PEFC  certified material and PEFC 
controlled sources m aterial as input for PEFC product groups. 

PEFC  ST 2002: 2020 - Appendix 1 

1.1 In order to help ensure  that activities conducted by the organisation 
unde r the scope of this standard conform to all applicable timber legality 
le gislation, including trade and customs laws, and to minimise the risk that 

378 

F i ndings 

Not 
C ove red 

R e quirement 7.1.1 of PEFC ST 2002: 
2020, describes that the ce rtificate holder 
shall implement a Due Diligence System 
(DDS) whe n sourcing input material which 
is not PEFC-certified. The re quirements 
for due  diligence  are contained within 
Appe ndix 1 of standard (PEFC ST 2002: 
2020): “Appendix 1: PEFC Due Diligence 
System (DDS) for the avoidance of 
material from controversial sources”. In 
such a case, the role of the DDS in 
Appe ndix 1 is to m inimise the risk that 
non-certified materials or products which 
are  source d by the C ertificate Holder 
de rive  from controversial sources. 

PEFC  ST 2002: 2020, Appendix 1, 
indicator 1.1 describes that to e nsure 
com pliance with applicable timber legality 
le gislation and trade and customs laws, 

 
 
 
 
 
 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

the  procured m aterial originates in controversial source s, the organisation 
shall operate a Due Diligence System (DDS), in accordance with the  
following elements of this standard. 
6.1 Fore st and tre e based material/p roducts from unknown source s or from 
controve rsial sources shall not be included in a PEFC product group. 

the  ce rtificate holder shall operate a due 
dilige nce system to minimise the risk that 
the  procured m aterial originates in 
controve rsial sources, in accordance with 
Appe ndix 1. 

The  definition of controversial sources 
(3.7) includes forest and tre e-based 
m ate rial sourced from activities not 
com plying with applicable local, national 
or inte rnational legislation on forest 
m anagement, including fore st 
m anagement practices and other a reas of 
law. This definition is specific to forest 
m anagement only. It does not appear to 
include  compliance re levant to supply 
chain le gality, covering le gislation 
re le vant to business re gistration, and 
othe r re levant legally re quired licenses, 
that applies to supply chain entities. 

J ustification 

This indicator is concluded as not covered 
for controlled sources. Legislation 
re gulating the existence of le gal business 
re gistration, and other re levant legally 
re quire d licenses, does not appear to be 
include d by PEFC International within the 
de finition of controversial source s in the 
C hain of C ustody standard. 

A.2b.2 Taxes and fees 

A . 2b.2.1  Paym ent of 

tax e s, 

A 2b.2.1.1 The 
Sche m e shall 

PEFC  ST 2002: 2020 

F i ndings 

Not 
C ove red 

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C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

royalties and 
fe e s 

include  
re quirements that 
e nsure compliance 
with le gislation 
cove ring payment 
of all le gally 
re quire d taxes, 
royaltie s and fees. 

3.28 PEFC controlled sources 

Mate rial category covering forest and tre e based material for which an 
organisation has determined through its Due Diligence System that there  is 
“ne gligible risk” that the material is from controversial sources. 

3.7 C ontroversial source s 

Fore st and tre e based material source d from: 

a) Activitie s not complying with applicable local, national or international 
le gislation on forest management, including but not limited to forest 
m anagement practices; nature and e nvironmental protection; protected and 
e ndangered species; property, te nure and land-use rights for indigenous 
pe oples, local communities or other affected stakeholders; health, labour 
and safety issues; anticorruption and the payment of applicable royalties 
and taxes. 

6.1.4 The organisation shall only use PEFC  certified material and PEFC 
controlled sources m aterial as input for PEFC product groups. 

PEFC  ST 2002: 2020 - Appendix 1 

1.1 In order to help ensure  that activities conducted by the organisation 
unde r the scope of this standard conform to all applicable timber legality 
le gislation, including trade and customs laws, and to minimise the risk that 
the  procured m aterial originates in controversial source s, the organisation 
shall operate a Due Diligence System (DDS), in accordance with the  
following elements of this standard. 
6.1 Fore st and tre e based material/products from unknown source s or from 
controve rsial sources shall not be included in a PEFC product group. 

R e quirement 7.1.1 of PEFC ST 2002: 
2020, describes that the ce rtificate holder 
shall implement a Due Diligence System 
(DDS) whe n sourcing input material which 
is not PEFC-certified. The re quirements 
for due  diligence  are contained within 
Appe ndix 1 of standard (PEFC ST 2002: 
2020): “Appendix 1: PEFC Due Diligence 
System (DDS) for the avoidance of 
material from controversial sources”. In 
such a case, the role of the DDS in 
Appe ndix 1 is to m inimise the risk that 
non-certified materials or products which 
are  source d by the C ertificate Holder 
de rive  from controversial sources. 

PEFC  ST 2002: 2020, Appendix 1, 
indicator 1.1 describes that to e nsure 
com pliance with applicable timber legality 
le gislation, including trade and customs 
laws, the  ce rtificate holder shall operate a 
due  diligence system to minimise the risk 
that the  procured material originates in 
controve rsial sources, in accordance with 
Appe ndix 1. 

The  definition of controversial sources 
(3.7) includes forest and tre e-based 
m ate rial sourced from activities not 
com plying with applicable local, national 
or inte rnational legislation on forest 
m anagement, the payment of applicable 
royaltie s and taxes. This definition is 
spe cific to fore st management only. It 
doe s not appear to include compliance 
re le vant to the supply chain legality, 
cove ring legislation re levant to legally 

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S t andard re ference 

F i ndings and Justification 

C onclusion 

re quire d taxes, royalties and fees that 
apply to products being traded along the 
supply chain. 

J ustification 

This indicator is concluded as not covered 
for controlled sources.  
Le gislation covering payment of all legally 
re quire d taxes, royalties and fees, does 
not appear to be included by PEFC 
Inte rnational within the definition of 
controve rsial sources in the Chain of 
C ustody standard. 

A . 2b.2.2  Value -added 

tax e s and 
othe r sales 
tax e s 

A 2b.2.2.1 The 
Sche m e shall 
include  
re quirements that 
e nsure compliance 
with le gislation 
cove ring different 
type s of sales 
tax e s that apply to 
the  m aterial being 
sold, including 
se lling material as 
growing forest 
(standing stock 
sale s). 

PEFC  ST 2002: 2020 

3.28 PEFC controlled sources 

Mate rial category covering forest and tre e based material for which an 
organisation has determined through its Due Diligence System that there  is 
“ne gligible risk” that the material is from controversial sources. 

3.7 C ontroversial source s 

Fore st and tre e based material source d from: 

a) Activitie s not complying with applicable local, national or international 
le gislation on forest management, including but not limited to forest 
m anagement practices; nature and e nvironmental protection; protected and 
e ndangered species; property, te nure and land-use rights for indigenous 
pe oples, local communities or other affected stakeholders; health, labour 
and safety issues; anticorruption and the payment of applicable royalties 
and taxes. 

6.1.4 The o rganisation shall only use PEFC  certified material and PEFC 
controlled sources m aterial as input for PEFC product groups. 

PEFC  ST 2002: 2020 - Appendix 1 

1.1 In order to help ensure  that activities conducted by the organisation 
unde r the scope of this standard conform to all applicable timber legality 

F i ndings 

Not 
C ove red 

R e quirement 7.1.1 of PEFC ST 2002: 
2020, describes that the ce rtificate holder 
shall implement a Due Diligence System 
(DDS) whe n sourcing input material which 
is not PEFC-certified. The re quirements 
for due  diligence  are contained within 
Appe ndix 1 of standard (PEFC ST 2002: 
2020): “Appendix 1: PEFC Due Diligence 
System (DDS) for the avoidance of 
material from controversial sources”. In 
such a case, the role of the DDS in 
Appe ndix 1 is to m inimise the risk that 
non-certified materials or products which 
are  source d by the C ertificate Holder 
de rive  from controversial sources. 

PEFC  ST 2002: 2020, Appendix 1, 
indicator 1.1 describes that to e nsure 
com pliance with applicable timber legality 

381 

 
 
 
 
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S t andard re ference 

F i ndings and Justification 

C onclusion 

le gislation, including trade and customs laws, and to minimise the risk that 
the  procured m aterial originates in controversial source s, the organisation 
shall operate a Due Diligence System (DDS), in accordance with the  
following elements of this standard. 
6.1 Fore st and tre e based material/products from unknown source s or from 
controve rsial sources shall not be included in a PEFC product group. 

le gislation, including trade and customs 
laws, the  ce rtificate holder shall operate a 
due  diligence system to minimise the risk 
that the  procured material originates in 
controve rsial sources, in accordance with 
Appe ndix 1. 

The  definition of controversial sources 
(3.7) includes forest and tre e-based 
m ate rial sourced from activities not 
com plying with applicable local, national 
or inte rnational legislation on forest 
m anagement, including the payment of 
applicable royalties and taxes. This 
de finition is specific to forest management 
only. It does not appear to include 
com pliance re levant to the supply chain 
le gality, covering legislation re levant to 
VAT and other sales taxes that apply to 
products being traded along the supply 
chain. 

J ustification 

This indicator is concluded as not covered 
for controlled sources.  
Le gislation covering VAT and other sales 
tax e s that apply to the material being 
sold, including selling material as growing 
fore st (standing stock sales), does not 
appear to be included by PEFC 
Inte rnational within the definition of 
controve rsial sources in the Chain of 
C ustody standard. 

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C onclusion 

A.2b.3 Trade and transport 

A . 2b.3.1  C lassification 

of species, 
quantities, 
qualities 

A . 2b.3.1.1 The 
Sche m e shall 
include  
re quirements that 
e nsure compliance 
with le gislation 
re gulating how 
products are 
classified in te rms 
of species, 
volum es and 
qualities in 
conne ction with 
trade  and 
transport.  

PEFC  ST 2002: 2020 

3.28 PEFC controlled sources 

Mate rial category covering forest and tre e based material for which an 
organisation has determined through its Due Diligence System that there  is 
“ne gligible risk” that the material is from controversial sources. 

3.7 C ontroversial source s 

Fore st and tre e based material source d from: 

a) Activitie s not complying with applicable local, national or international 
le gislation on forest management, including but not limited to forest 
m anagement practices; nature and e nvironmental protection; protected and 
e ndangered species; property, te nure and land-use rights for indigenous 
pe oples, local communities or other affected stakeholders; health, labour 
and safety issues; anticorruption and the payment of applicable royalties 
and taxes. 

6.1.4 The organisation shall only use PEFC  certified material and PEFC 
controlled sources m aterial as input for PEFC product groups. 

PEFC  ST 2002: 2020 - Appendix 1 

1.1 In order to help ensure  that activities conducted by the organisation 
unde r the scope of this standard conform to all ap plicable timber legality 
le gislation, including trade and customs laws, and to minimise the risk that 
the  procured m aterial originates in controversial source s, the organisation 
shall operate a Due Diligence System (DDS), in accordance with the  
following elements of this standard. 

6.1 Fore st and tre e based material/products from unknown source s or from 
controve rsial sources shall not be included in a PEFC product group. 

F i ndings 

Not 
C ove red 

R e quirement 7.1.1 of PEFC ST 2002: 
2020, describes that the ce rtificate holder 
shall implement a Due Diligence System 
(DDS) whe n sourcing input material which 
is not PEFC-certified. The re quirements 
for due  diligence  are contained within 
Appe ndix 1 of standard (PEFC ST 2002: 
2020): “Appendix 1: PEFC Due Diligence 
System (DDS) for the avoidance of 
material from controversial sources”. In 
such a case, the role of the DDS in 
Appe ndix 1 is to m inimise the risk that 
non-certified materials or products which 
are  source d by the C ertificate Holder 
de rive  from controversial sources. 

The  definition of controversial sources 
(3.7) includes forest and tre e-based 
m ate rial sourced from activities not 
com plying with applicable local, national 
or inte rnational legislation on forest 
m anagement, including fore st 
m anagement practices and other areas of 
la w. This definition is specific to forest 
m anagement only. It does not appear to 
include  compliance re levant to the supply 
chain le gality, covering le gislation 
re le vant to how products are classified in 
te rm s of species, volumes and qualities 
that apply to products being traded along 
the  supply chain.  

383 

 
 
 
 
 
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F i ndings and Justification 

C onclusion 

A . 2b.3.2  Trade  and 
transport 

A . 2b.3.2.1 The 
Sche m e shall 
include  
re quirements that 
e nsure compliance 
with re quired 
trading permits as 
we ll as le gally 
re quire d transport 
docum ents that 
accom pany 
transport of wood. 

PEFC  ST 2002: 2020 

3.28 PEFC controlled sources 

Mate rial category covering forest and tre e based material for which an 
organisation has determined through its Due Diligence System that there  is 
“ne gligible risk” that the material is from controversial sources. 

3.7 C ontroversial source s 

Fore st and tre e based material source d from: 

a) Activitie s not complying with applicable local, national or international 
le gislation on forest management, including but not limited to forest 
m anagement practices; nature and e nvironmental protection; protected and 
e ndangered species; property, te nure and land-use rights for indigenous 
pe oples, local communities or other affected stakeholders; health, labour 
and safety issues; anticorruption and the payment of applicable royalties 
and taxes. 

6.1.4 The organisation shall only use PEFC  certified material and PEFC 
controlled sources m aterial as input for PEFC product groups. 

PEFC  ST 2002: 2020 - Appendix 1 

1.1 In order to help ensure  that activities conducted by the organisation 
unde r the scope of this standard conform to all applicable timber legality 
le gislation, including trade and customs laws, and to minimise the risk that 
the  procured m aterial originates in controversial source s, the organisation 
shall operate a Due Diligence System (DDS), in accordance with the  

384 

Not 
C ove red 

J ustification 

This indicator is concluded as not covered 
for controlled sources.  
Le gislation regulating how products are  
classified in te rms of species, volumes 
and qualities in connection with trade and 
transport, does not appear to be included 
by PEFC  International within the definition 
of controversial sources in the Chain of 
C ustody standard. 
F i ndings 

R e quirement 7.1.1 of PEFC ST 2002: 
2020, describes that the ce rtificate holder 
shall implement a Due Diligence System 
(DDS) whe n sourcing input material which 
is not PEFC-certified. The re quirements 
for due  diligence  are contained within 
Appe ndix 1 of standard (PEFC ST 2002: 
2020): “Appendix 1: PEFC Due Diligence 
System (DDS) for the avoidance of 
material from controversial sources”. In 
such a case, the role of the DDS in 
Appe ndix 1 is to m inimise the risk that 
non-certified materials or products which 
are  source d by the C ertificate Holder 
de rive  from controversial sources. 

The  definition of controversial sources 
(3.7) includes forest and tre e-based 
m ate rial sourced from activities not 
com plying with applicable local, national 
or inte rnational legislation on forest 
m anagement, including fore st 

 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

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I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

following elements of this standard. 
6.1 Fore st and tre e based material/products from unknown source s or from 
controve rsial sources shall not be included in a PEFC product group. 

A . 2b.3.3  O ffshore 

trading and 
transfer 
pricing 

A . 2b.3.3.1 The 
Sche m e shall 
include  
re quirements that 
e nsure compliance 
with le gislation 
re gulating offshore 
trading.  

PEFC  ST 2002: 2020 

3.28 PEFC controlled sources 

Mate rial category covering forest and tre e based material for which an 
organisation has determined through its Due Diligence System that there  is 
“ne gligible risk” that the material is from controversial sources. 

3.7 C ontroversial source s 

Fore st and tre e based material source d from: 

a) Activitie s not complying with applicable local, national or international 
le gislation on forest management, including but not limited to forest 
m anagement practices; nature and e nvironmental protection; protected and 
e ndangered species; property, te nure and land-use rights for indigenous 
pe oples, local communities or other affected stakeholders; health, labour 
and safety issues; anticorruption and the payment of applicable royalties 
and taxes. 

6.1.4 The organisation shall only use PEFC  certified material and PEFC 

385 

m anagement practices and other areas of 
law. This definition is specific to forest 
m anagement only. It does not appear to 
include  compliance re levant to the supply 
chain le gality, covering le gislation 
re le vant to trade and transport that apply 
to products being traded along the supply 
chain. 

J ustification 

This indicator is concluded as not covered 
for controlled sources.  
C om pliance with re quired trading permits 
as we ll as legally re quired transport 
docum ents that accompany the transport 
of wood does not appear to be included 
by PEFC  International within the definition 
of controversial sources in the Chain of 
C ustody standard. 
F i ndings 

R e quirement 7.1.1 of PEFC ST 2002: 
2020, describes that the ce rtificate holder 
shall implement a Due Diligence System 
(DDS) whe n sourcing input material which 
is not PEFC-certified. The re quirements 
for due  diligence  are contained within 
Appe ndix 1 of standard (PEFC ST 2002: 
2020): “Appendix 1: PEFC Due Diligence 
System (DDS) for the avoidance of 
material from controversial sources”. In 
such a case, the role of the DDS in 
Appe ndix 1 is to m inimise the risk that 
non-certified materials or products which 
are  source d by the C ertificate Holder 

Not 
C ove red 

 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

C ode 

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I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

controlled sources m aterial as input for PEFC product groups. 

de rive  from controversial sources. 

PEFC  ST 2002: 2020 - Appendix 1 

1.1 In order to help ensure  that activities conducted by the organisation 
unde r the scope of this standard conform to all applicable timber legality 
le gislation, including trade and customs laws, and to minimise the risk that 
the  procured m aterial originates in controversial source s, the organisation 
shall operate a Due Diligence System (DDS), in accordance with the  
following elements of this standard. 
6.1 Fore st and tre e based material/products from unknown source s or from 
controve rsial sources shall not be included in a PEFC product group. 

A . 2.3.3.2 The 
Sche m e shall 
include  
re quirements that 
e nsure compliance 
with le gislation 
re gulating transfer 
pricing. 

PEFC  ST 2002: 2020 

3.28 PEFC controlled sources 

Mate rial category covering forest and tre e based material for which an 
organisation has determined through its Due Diligence System that there  is 
“ne gligible risk” that the material is from controversial sources. 

3.7 C ontroversial source s 

Fore st and tre e based material source d from: 

a) Activitie s not complying with applicable local, national or international 

386 

The  definition of controversial sources 
(3.7) includes forest and tre e-based 
m ate rial sourced from activities not 
com plying with applicable local, national 
or inte rnational legislation on forest 
m anagement, including fore st 
m anagement practices and other a reas of 
law. This definition is specific to forest 
m anagement only. It does not appear to 
include  compliance re levant to the supply 
chain le gality, covering le gislation 
re le vant to offshore trading that apply to 
products being traded along the supply 
chain. 

J ustification 

This indicator is concluded as not covered 
for controlled sources.  
Le gislation regulating offshore trading  
doe s not appear to be included by PEFC 
Inte rnational within the definition of 
controve rsial sources in the Chain of 
C ustody standard. 
F i ndings 

R e quirement 7.1.1 of PEFC ST 2002: 
2020, describes that the ce rtificate holder 
shall implement a Due Diligence System 
(DDS) whe n sourcing input material which 
is not PEFC-certified. The re quirements 
for due  diligence  are contained within 
Appe ndix 1 of standard (PEFC ST 2002: 
2020): “Appendix 1: PEFC Due Diligence 

Not 
C ove red 

 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

le gislation on forest management, including but not limited to forest 
m anagement practices; nature and e nvironmental protection; protected and 
e ndangered species; property, te nure and land-use rights for indigenous 
pe oples, local communities or other affected stakeholders; health, labour 
and safety issues; anticorruption and the payment of applicable royalties 
and taxes. 

6.1.4 The organisation shall only use PEFC  certified material and PEFC 
controlled sources m aterial as input for PEFC product groups. 

PEFC  ST 2002: 2020 - Appendix 1 

1.1 In order to help ensure  that activities conducted by the organisation 
unde r the scope of this standard conform to all applicable timber legality 
le gislation, including trade and customs laws, and to minimise the risk th at 
the  procured m aterial originates in controversial source s, the organisation 
shall operate a Due Diligence System (DDS), in accordance with the  
following elements of this standard. 
6.1 Fore st and tre e based material/products from unknown source s or from 
controve rsial sources shall not be included in a PEFC product group. 

A . 2b.3.4  C ustoms 

re gulations 

A . 2b.3.4.1 The 
Sche m e shall 
include  
re quirements that 

PEFC  ST 2002: 2020 

3.28 PEFC controlled sources 

Mate rial category covering forest and tre e based material for which an 

387 

System (DDS) for the avoidance of 
material from controversial sources”. In 
such a case, the role of the DDS in 
Appe ndix 1 is to m inimise the risk that 
non-certified materials or products which 
are  source d by the C ertificate Holder 
de rive  from controversial sources. 

The  definition of controversial sources 
(3.7) includes forest and tre e-based 
m ate rial sourced from activities not 
com plying with applicable local, national 
or inte rnational legislation on forest 
m anagement, including fore st 
m anagement practices and other areas of 
law. This definition is specific to forest 
m anagement only. It does not appear to 
include  compliance re levant to the supply 
chain le gality, covering le gislation 
re le vant to transfer pricing that apply to 
products being traded along the supply 
chain. 

J ustification 

This indicator is concluded as not covered 
for controlled sources.  
Le gislation regulating transfer pricing 
doe s not appear to be included by PEFC 
Inte rnational within the definition of 
controve rsial sources in the Chain of 
C ustody standard. 
F i ndings 

R e quirement 7.1.1 of PEFC ST 2002: 
2020, describes that the ce rtificate holder 

Not 
C ove red 

 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

C ode 

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I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

e nsure compliance 
with le gislation 
cove ring areas 
such as 
e x port/import 
lice nses, and 
product 
classification 
re late d to customs 
(code s, quantities, 
qualities and 
spe cies). 

organisation has determined through its Due Diligence System that there  is 
“ne gligible risk” that the material is from controversial sources. 

3.7 C ontroversial source s 

Fore st and tre e based material source d from: 

a) Activitie s not complying with applicable local, national or international 
le gislation on forest management, including but not limited to forest 
m anagement practices; nature and e nvironmental protection; protected and 
e ndangered species; property, te nure and land-use rights for indigenous 
pe oples, local communities or other affected stakeholders; health, labour 
and safety issues; anticorruption and the payment of applicable royalties 
and taxes. 

6.1.4 The organisation shall only use PEFC  certified material and PEFC 
controlled sources m aterial as input for PEFC product groups. 

PEFC  ST 2002: 2020 - Appendix 1 

1.1 In order to help ensure  that activities conducted by the organisation 
unde r the scope of this standard conform to all applicable timber legality 
le gislation, including trade and customs laws, and to minimise the risk that 
the  procured m aterial originates in controversial source s, the organisation 
shall operate a Due Diligence System (DDS), in accordance with the  
following elements of this standard. 

Appe ndix 1, Table 1: List of indicators for ne gligible risk 

Appe ndix 1, Table 2: List of indicators for significant risk at origin level 

Appe ndix 1, Table 3: List of indicators for significant risk at supply chain 
le ve l 

6.1 Fore st and tre e based material/products from unknown source s or from 
controve rsial sources shall not be included in a PEFC product group. 

shall implement a Due Diligence System 
(DDS) whe n sourcing input material which 
is not PEFC-certified. The re quirements 
for due  diligence  are contained within 
Appe ndix 1 of standard (PEFC ST 2002: 
2020): “Appendix 1: PEFC Due Diligence 
System (DDS) for the avoidance of 
material from controversial sources”. In 
such a case, the role of the DDS in 
Appe ndix 1 is to m inimise the risk that 
non-certified materials or products which 
are  source d by the C ertificate Holder 
de rive  from controversial sources. 

The  definition of controversial sources 
(3.7) includes forest and tre e-based 
m ate rial sourced from activities not 
com plying with applicable local, national 
or inte rnational legislation on forest 
m anagement, including fore st 
m anagement practices and other areas of 
law. This definition is specific to forest 
m anagement only. It does not appear to 
include  compliance re levant to the supply 
chain le gality, covering le gislation 
re le vant to export/import licenses, and 
product classification re lated to customs 
that apply to products being traded along 
the  supply chain. 

J ustification 

This indicator is concluded as not covered 
for controlled sources.  
Le gislation covering are as such as 
e x port/import licenses, and product 
classification related to customs (codes, 

388 

 
 
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C onclusion 

A . 2b.3.5  C ITES 

A . 2b.3.5.1 The 
Sche m e shall 
include  
re quirements that 
e nsure compliance 
with le gislation 
re late d to CITES 
pe rm its (the 
C onvention on 
Inte rnational 
Trade  in 
Endangere d 
Spe cie s of W ild 
Fauna and Flora, 
also known as the 
W ashington 
C onvention). 

PEFC  ST 2002: 2020 

3.28 PEFC controlled sources 

Mate rial category covering forest and tre e based material for which an 
organisation has determined through its Due Diligence System that there  is 
“ne gligible risk” that the material is from controversial sources. 

3.7 C ontroversial source s 

Fore st and tre e based material source d from: 

a) Activitie s not complying with applicable local, national or international 
le gislation on forest management, including but not limited to forest 
m anagement practices; nature and e nvironmental protection ; protected and 
e ndangered species; property, te nure and land-use rights for indigenous 
pe oples, local communities or other affected stakeholders; health, labour 
and safety issues; anticorruption and the payment of applicable royalties 
and taxes. 

6.1.4 The organisation shall only use PEFC  certified material and PEFC 
controlled sources m aterial as input for PEFC product groups. 

PEFC  ST 2002: 2020 - Appendix 1 

1.1 In order to help ensure  that activities conducted by the organisation 
unde r the scope of this s tandard conform to all applicable timber legality 
le gislation, including trade and customs laws, and to minimise the risk that 
the  procured m aterial originates in controversial source s, the organisation 
shall operate a Due Diligence System (DDS), in accord ance with the  
following elements of this standard. 
1.4 The organisation procuring raw m aterial originating from species listed 
in Appe ndix I to III of CITES shall comply with applicable legislation re lating 
to C ITES. 
6.1 Fore st and tre e based material/products from unknown source s or from 
controve rsial sources shall not be included in a PEFC product group. 

389 

Not 
C ove red 

quantities, qualities and species), does 
not appear to be included by PEFC 
Inte rnational within the definition of 
controve rsial sources in the Chain of 
C ustody standard. 
F i ndings 

R e quirement 7.1.1 of PEFC ST 2002: 
2020, describes that the ce rtificate holder 
shall implement a Due Diligence System 
(DDS) whe n sourcing input material which 
is not PEFC-certified. The re quirements 
for due  diligence  are contained within 
Appe ndix 1 of standard (PEFC ST 2002: 
2020): “Appendix 1: PEFC Due Diligence 
System (DDS) for the avoidance of 
material from controversial sources”. In 
such a case, the role of the DDS in 
Appe ndix 1 is to m inimise the risk that 
non-certified materials or products which 
are  source d by the C ertificate Holder 
de rive  from controversial sources. 

The  definition of controversial sources 
(3.7) includes forest and tre e-based 
m ate rial sourced from activities not 
com plying with applicable local, national 
or inte rnational legislation on forest 
m anagement, including fore st 
m anagement practices and other areas of 
law. This definition is specific to forest 
m anagement only. It does not appear to 
include  compliance re levant to the supply 
chain le gality, covering le gislation 
re le vant to CITES permits that apply to 
products being traded along the supply 
chain. 

 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

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F i ndings and Justification 

C onclusion 

Appe ndix 1, indicator 1.4 re quires the 
ce rtificate holder to comply with C ITES 
re quirement, howe ver this is requested 
just for the  ce rtification holder and is not 
se e n as applicable to supply chain 
e ntitie s. 

J ustification 

This indicator is concluded as not covered 
for controlled sources.  
Le gislation related to CITES permits does 
not appear to be included by PEFC 
Inte rnational within the definition of 
controve rsial sources in the Chain of 
C ustody standard. 
F i ndings 

PEFC  ST 2002: 2020, Appendix 1, 
indicator 1.1 describes that to e nsure 
com pliance with applicable timber legality 
le gislation, including trade and customs 
laws, the  ce rtificate holder shall operate a 
due  diligence system to minimise the risk 
that the  procured material originates in 
controve rsial sources, in accordance with 
Appe ndix 1. 

The  definition of controversial sources 
(3.7) includes forest and tre e-based 
m ate rial sourced from activities not 
com plying with applicable local, national 
or inte rnational legislation on forest 
m anagement, including fore st 
m anagement practices and other a reas of 
law. This definition is specific to forest 

Not 
C ove red 

A . 2b.3.6  Le gislation 

re quiring 
due  
dilige nce / 
due  care 
proce dure s 

A . 2b.3.6.1 The 
sche me shall 
include  
re quirements that 
e nsure compliance 
with le gislation 
cove ring due 
dilige nce/due care 
proce dure s, 
including e.g. due 
dilige nce/due care 
syste ms, 
de claration 
obligations, and 
/or the  k eeping of 
trade  re lated 
docum ents, 
le gislation 
e stablishing 
proce dure s to 

PEFC  ST 2002: 2020 

3.28 PEFC controlled sources 

Mate rial category covering forest and tre e based material for which an 
organisation has determined through its Due Diligence System that there  is 
“ne gligible risk” that the material is from controversial sources. 

3.7 C ontroversial source s 

Fore st and tre e based material source d from: 

a) Activitie s not complying with applicable local, national or international 
le gislation on forest management, including but not limited to forest 
m anagement practices; nature and e nvironmental protection; protected and 
e ndangered species; property, te nure and land-use rights for indigenous 
pe oples, local communities or other affected stakeholders; health, labour 
and safety issues; anticorruption and the payment of applicable royalties 
and taxes. 

6.1.4 The organisation shall only use PEFC  certified material and PEFC 
controlled sources m aterial as input for PEFC product groups. 

PEFC  ST 2002: 2020 - Appendix 1 

1.1 In order to help ensure  that activities conducted by the organisation 

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pre ve nt trade in 
ille gally harvested 
tim be r and 
products derived 
from  such timber, 
e tc. 

unde r the scope of this standard conform to all applicable timber legality 
le gislation, including trade and customs laws, and to minimise the risk that 
the  procured m aterial originates in controversial source s, the organisation 
shall operate a Due Diligence System (DDS), in accordance with the  
following elements of this standard. 
6.1 Fore st and tre e based material/products from unknown source s or from 
controve rsial sources shall not be included in a PEFC product group. 

m anagement only. It does not appear to 
include  compliance re levant to the supply 
chain le gality, covering le gislation 
re le vant to legislation re quiring due 
dilige nce / due care procedures that apply 
to products being traded along the supply 
chain. 

J ustification 

This indicator is concluded as not covered 
for controlled sources.  
Le gislation covering due diligence/due 
care  proce dures does not appear to be 
include d by PEFC International within the 
de finition of controversial source s in the 
C hain of C ustody standard. 

A.3 Requirements for material control 

A.3.1 Material control  

A . 3.1.1  Mate rial 

origin and 
ide ntification 

A . 3.1.1.1 The 
Sche m e shall 
re quire  systematic 
proce sses to 
e nable the 
ide ntification of 
the  country of 
harve st of the 
m ate rial, and 
whe re  applicable 
to a higher level of 
de tail, such as the 
sub-national 

PEFC  ST 2002: 2020  
5.1.1 For each delivery of m aterial used as input for a PEFC product group 
the  organisation shall obtain documentation with the  following information 
from  the supplier: 
a) supplier identification 
b) product identification 
c) quantity of products 
d) de livery identification based on date of delivery, delivery period, or 
accounting period 
For inputs with a PEFC claim the document shall also include:  
e ) the  organisation’s name as the PEFC customer of the delivery 
f) the  applicable PEFC claim specifically for e ach claimed product covered 
by the  documentation  

F i ndings 

Partially 
C ove red 

PEFC -ce rtified products 
According to PEFC ST 2002: 2020, 5.1.1 
the  ce rtificate holder shall identify the 
supplier re levant to inputs into PEFC-
ce rtifie d products. The identification of the 
country of the harvest is not specifically 
m e ntioned. Howe ver, the certificate 
holder has the option to implement a Due 
Dilige nce  System based on re quirement 
7.1.2 of the main standard PEFC ST 2002: 
2020. This is a re duced DDS focussing on 

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re gion or 
conce ssion le vel.  

g) the  ce rtificate number of the supplier’s PEFC re cognised ce rtificate 
Note  1: The ce rtificate number is a numerical or alpha-numerical 
com bination, which is a unique identifier of the certifica te. 
Note  2: An e xample of delivery documentation is an invoice or delivery 
note  providing the information required. 

7.1.1 For all material used as input for a PEFC product group, e xcept 
re cycle d m aterial, the organisation shall exercise due diligence in line with 
the  PEFC  Due Diligence System (DDS) for the avoidance  of material from 
controve rsial sources laid down in Appendix 1 of this standard. Thereby the 
organisation shall e stablish that for m aterial used as input for PEFC product 
groups there is “negligible risk” that it originates from controversial sources 
and that it m eets the definition of PEFC controlled sources material 

7.1.2 For PEFC  product groups whe re only input material used was 
de live red with a PEFC claim by a supplier covered by a PEFC re cognised 
ce rtificate, an organisation m ay implement the PEFC DDS by meeting the 
following requirements: 
a) In order to e nable PEFC certified and uncertified entities further down 
the  supply chain to implement a DDS, the organisation shall, upon request, 
provide the information specified in Appendix 1, 2.1 for material passed on 
with a PEFC  claim. If the organisation does not possess the requested 
inform ation, the re quest shall be passed on to relevant supplier(s) of the 
organisation (Appendix 1, 2.2). 
b) W here  internal or e xternal substantiated concerns on the origin of input 
m ate rial from controversial sources are raised, the organisation shall follow 
up on these concerns following Appendix 1, 4. 
c) The  organisation shall define, document and implement a commitment 
and a procedure, also covering forest and tre e based material/products not 
cove re d by the organisation’s PEFC  
chain of custody, ensuring that whe re  it is k nown to the organisation, or 
whe re  it has re ceived substantiated conce rns, that forest and tre e based 
m ate rial/products originates in illegal sources (controversial source s, 3.7a), 
it shall not be placed on the m arket until the concern has been re solved in 
accordance with Appendix 1, 4. 

Appe ndix 1, 2.1 In order to enable the organisation to implement the PEFC 

392 

obtaining from suppliers – and passing 
downstre am buyers - information relating 
to spe cies and origin, as we ll as 
addre ssing internal or external 
substantiated concerns that may be 
raise d in re lation to the products sourced. 

PEFC  C ontrolled Sources 
As pe r 7.1.1 of PEFC ST 2002: 2020, the 
ce rtificate holder shall implement a Due 
Dilige nce  System (DDS) whe n input 
m ate rial is not PEFC-certified. The role of 
the  DDS in Appendix 1 is to e nsure input 
de rive d from non-certified suppliers does 
not contain controversial sources. 
According to PEFC ST 2002: 2020,  

W ithin the same standard, Appendix 1, 
2.1 re quire s that certificate holder acce ss 
inform ation from its supplier(s) in re lation 
to the  country of harvest of the m aterial 
and whe re  the applicable sub-national 
re gion and/or concession of harvest. As 
pe r appendix 1, 2.2 suppliers should 
provide information related to the sources 
use d in products in case customers are 
re que sting this information.   

J ustification 

This indicator is concluded as partially 
cove re d. The identification of the country of 
the  harvest is not directly re quired for PEFC-
ce rtifie d products – only on a voluntary basis 
if the  ce rtificate holder implements a Due 
Dilige nce  System based on re quirement 
7.1.2. Howe ver, origin information is 

 
 
 
 
 
 
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DDS, the  organisation shall have access to the following information from 
its supplier(s): 
a) Identification of tre e species included, or list of tree species potentially 
include d, in the material/ product by their common name and/or their 
scie ntific name whe re applicable. 
b) C ountry of harvest of the material and whe re applicable sub-national 
re gion and/or concession of harvest. 
Note  1: Acce ss to the scientific name of species is required in cases whe re 
the  usage of a common name could pose a risk of wrong identification of 
the  species. 
Note  2: Usage of a trade name of species is considered as e quivalent to the 
com m on name in cases whe re  all species covere d by the trade name have 
an e quivalent risk of originating in controversial sources. 
Note  3: Acce ss to the sub -national level of the material origin is re quired in 
case s whe re sub-national re gions within one country do not re present an 
e quivalent risk re lating to the controversial source s. 
Note  4: The term “concession of harvest” refers to  a contract for harvest in 
a ge ographically defined forest area. 
Note  5: The term “country/region” is further used throughout this clause to 
ide ntify a country, a sub-national region or a concession of harvest of the 
m ate rial/product origin. 

Appe ndix 1, 2.2 In order to enable PEFC ce rtified and unce rtified entities 
furthe r down the  supply chain to implement a DDS, the organisation shall, 
upon re quest, provide the information specified in 2.1 of this appendix for 
m ate rial passed on with a PEFC claim. If the organisation does not possess 
the  re quested information, the re quest shall be passed on to re levant 
supplier(s) of the organisation. 

PEFC  ST 2002: 2020  
3.30 PEFC product group 
Product or set of products with e quivalent input material, defined by 
product name/type and category, type(s) of species, chain of custody 
m e thod, material category, PEFC claim(s), for which an organisation applies 
its chain of custody. 

4.1.2 The organisation shall define the scope of its PEFC chain of custody 
by spe cifying the PEFC product groups for which the re quirements of the 

393 

A . 3.1.1.2 The 
Sche m e shall 
re quire  systematic 
proce sses to 
e nable the 
ide ntification of 
the  species 
include d in 
m ate rials or 

re quire d in the case of C ontrolled Sources 
m ate rial. 

Partially 
C ove red 

F i ndings 

PEFC -ce rtified products 
According to PEFC ST 2002: 2020, 4.1.2, 
the  ce rtificate holder shall define the 
product groups. According to PEFC  ST 
2002: 2020, 3.30 product groups are 
de fined by ‘type of species’, among other 
things. O therwise, the identification of 

 
 
 
 
 
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products included 
in the  scope of 
ce rtification. 

PEFC  chain of custody are implemented. 

5.1.1 For each delivery of m aterial used as input for a PEFC product group 
the  organisation shall obtain documentation with the  following information 
from  the supplier: 
a) supplier identification 
b) product identification 
c) quantity of products  
d) de livery identification based on date of delivery, delivery period, or 
accounting period 
For inputs with a PEFC claim the document shall also include: 
e ) the  organisation’s name as the PEFC customer of the delivery 
f) the  applicable PEFC claim specifically for e ach claimed product covered 
by the  documentation  
g) the  ce rtificate number of the supplier’s PEFC re cognised ce rtificate 
Note  1: The ce rtificate number is a numerical or alpha-numerical 
com bination, which is a unique identifier of the certificate. 
Note  2: An e xample of delivery documentation is an invoice or delivery 
note  providing the information required. 

6. C hain of custody m ethods 
6.1 Ge neral 
… 
6.1.3 PEFC product groups shall be established for products with e quivalent 
input m aterial, with the  
sam e measurement unit or units that can be converted into a single 
m e asurement unit. 
6.1.4 The organisation shall only use PEFC  certified material and PEFC 
controlled sources m aterial 
as input for PEFC product groups. 
7.1.1 For all material used as input for a PEFC product group, e xcept 
re cycle d m aterial, the organisation shall exercise due diligence in line with 
the  PEFC  Due Diligence System (DDS) for the avoidance  of material from 
controve rsial sources laid down in Appendix 1 of this standard. Thereby the 
organisation shall e stablish that for m aterial used as input for PEFC product 
groups there is “negligible risk” that it originates from controversial sources 
and that it m eets the definition of PEFC controlled sources material.  

spe cies is not specifically mentioned in 
the  chain of custody re quirements. 
Howe ve r, the ce rtificate holder has the 
option to implement a Due Diligence 
Syste m  based on requirement 7.1.2 of 
the  m ain standard PEFC ST 2002: 2020. 
This is a re duced DDS focussing on 
obtaining from suppliers – and passing 
downstre am buyers - information relating 
to spe cies and origin, as we ll as 
addre ssing internal or external 
substantiated concerns that may be 
raise d in re lation to the products sourced.  

PEFC  C ontrolled Sources 
As pe r 7.1.1 of PEFC ST 2002: 2020, the 
ce rtificate holder shall implement a Due 
Dilige nce  System (DDS) whe n input 
m ate rial is not PEFC-certified. The role of 
the  DDS in Appendix 1 is to e nsure input 
de rive d from non-certified suppliers does 
not contain controversial sources.  

W ithin the same standard, Appendix 1, 
2.1 re quire s that certificate holder acce ss 
inform ation from its supplier(s) in re lation 
to spe cies of the material – ore whe re  
applicable a list of tre e species potentially 
include d. As per appendix 1, 2.2 suppliers 
should provide information re lated to the 
source s used in products in case 
customers are  requesting this 
inform ation.   

J ustification 

This indicator is concluded as partially 

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cove re d. The identification of species is not 
dire ctly re quired for PEFC-certified products 
– only on a voluntary basis if the ce rtificate 
holder im plements a Due Diligence System 
based on requirement 7.1.2. Howe ver, 
Spe cie s information is re quired in the case 
of C ontrolled Source s material. 

7.1.2 For PEFC  product groups whe re only input material used was 
de live red with a PEFC claim by a supplier covered by a PEFC re cognised 
ce rtificate, an organisation m ay implement the PEFC DDS by meeting the 
following requirements: 
a) In order to e nable PEFC certified and uncertified entities further down 
the  supply chain to implement a DDS, the organisation shall, upon request, 
provide the information specified in Ap pendix 1, 2.1 for material passed on 
with a PEFC  claim. If the organisation does not possess the requested 
inform ation, the re quest shall be passed on to relevant supplier(s) of the 
organisation (Appendix 1, 2.2). 
b) W here  internal or e xternal substantiated concerns on the origin of input 
m ate rial from controversial sources are raised, the organisation shall follow 
up on these concerns following Appendix 1, 4. 
c) The  organisation shall define, document and implement a commitment 
and a procedure, also covering forest and tre e based material/products not 
cove re d by the organisation’s PEFC  
chain of custody, ensuring that whe re  it is k nown to the organisation, or 
whe re  it has re ceived substantiated conce rns, that forest and tre e based 
m ate rial/products originates in illegal sources (controversial source s, 3.7a), 
it shall not be placed on the m arket until the concern has been re solved in 
accordance with Appendix 1, 4. 

2.1 In order to e nable the organisation to implement the PEFC DDS, the 
organisation shall have access to the following information from its 
supplier(s): 
a) Identification of tre e species included, or list of tree species potentially 
include d, in the material/ product by their common name and/or their 
scie ntific name whe re applicable. 
b) C ountry of harvest of the material and whe re applicable sub-national 
re gion and/or concession of harvest. 
Note  1: Acce ss to the scientific name of species is required in cases whe re 
the  usage of a common name could pose a risk of wrong identification of 
the  species. 
Note  2: Usage of a trade name of species is considered as e quivalent to the 
com m on name in cases whe re  all species covere d by the trade name have 
an e quivalent risk of originating in controversial sources. 

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Note  3: Acce ss to the sub -national level of the material origin is re quired in 
case s whe re sub-national re gions within one country do not re present an 
e quivalent risk re lating to the controversial source s. 
Note  4: The term “concession of harvest” refers to a contract for harvest in 
a ge ographically defined forest area. 
Note  5: The term “country/region” is further used throughout this clause to 
ide ntify a country, a sub-national  
re gion or a concession of harvest of the material/product origin. 

2.2 In order to e nable PEFC certified and uncertified e ntities further down 
the  supply chain to implement a DDS, the organisation shall, upon request, 
provide the information specified in 2.1 of this appendix for m aterial passed 
on with a PEFC  claim. If the organisation does not possess the re quested 
inform ation, the re quest shall be passed on to relevant supplier(s) of the 
organisation. 

PEFC  ST 2002: 2020 

3.28 PEFC controlled sources 

Mate rial category covering forest and tre e based material for which an 
organisation has determined through its Due Diligence System that there  is 
“ne gligible risk” that the material is from controversial sources. 

6.1.1 There  are three methods to implement the PEFC chain of custody, 
nam ely the physical 
se paration method, the percentage method and the cre dit method. 
De pe nding on the nature  of material flows and processes, the organisation 
shall choose the appropriate method. 

6.1.4 The organisation shall only use PEFC  certified material and PEFC 
controlled sources m aterial  
as input for PEFC product groups. 

6.2.1 The organisation applying the physical separation method shall 
e nsure that material with different m aterial categories and different 
ce rtifie d content are  kept separate or cle arly identifiable at all stages of the 
production or trading process. 

396 

A . 3.1.1.3 The 
Sche m e shall 
include  clear and 
e ffe ctive measures 
to pre ve nt 
m ate rial from non-
ne gligible risk, 
unve rified or 
pote ntially illegal 
source s from 
e nte ring the 
supply chain and 
m ix ed with 
conforming 
m ate rial. 

F i ndings 

C ove red 

According to PEFC ST 2002: 2020 6.1.4, 
the  ce rtificate holder m ay choose to use 
controlled sources in their products. 
C ontrolled source s are defined by PEFC ST 
2002: 2020 3.28, as inputs into a due 
dilige nce system which are  concluded with 
ne gligible risk in re lation to the definition 
in the  standard of Controversial sources 
(PEFC  ST 2002: 2020 3.7).  

PEFC -ce rtified products 
According to PEFC ST 2002: 2020 6.1.1 
are  thre e methods to implement 
se gre gation betwe en PEFC products, 
com paring with non-certified.  

For the  physical separation method, the 
standard re quires (PEFC ST 2002: 2020 
6.2.1) to separate betwe en different 

 
 
 
 
 
 
 
 
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7.1.1 For all material used as input for a PEFC product group, e xcept 
re cycle d m aterial, the organisation shall exercise due diligence in line with 
the  PEFC  Due Diligence System (DDS) for the avoidance  of material from 
controve rsial sources laid down in Appendix 1 of this standard. Thereby the 
organisation shall e stablish that for m aterial used as input for PEFC product 
groups there is “negligible risk” that it originates from controversial sources 
and that it m eets the definition of PEFC controlled sources material.  

6. No placement on the m arket 
6.1 Fore st and tre e based material/products from unknown source s or from 
controve rsial sources 
shall not be included in a PEFC product group. 
6.2 W here it is known to the organisation that forest and tre e based 
m ate rials/products not 
cove re d by the organisation’s PEFC chain of custody originate in illegal 
source s (controversial 
source s, 3.7a), it shall not be placed on the market. 
6.3 W here the organisation has received substantiated concerns that forest 
and tre e based 
m ate rials/products not covered by the organisation’s PEFC chain of custody 
originate in illegal 
source s (controversial source s, 3.7a), it shall not be placed on the m arket 
until the  concern has 
be e n re solved in accordance with clause 4 of this appendix. 

m ate rial categories and certified content. 
For the  other two m ethods (percent and 
cre dit) PEFC 100% and PEFC  Controlled 
Source s can be mixed.  

PEFC  C ontrolled Sources 
As pe r 7.1.1 of PEFC ST 2002: 2020, the 
ce rtificate holder shall implement a Due 
Dilige nce  System (DDS) whe n input 
m ate rial is not PEFC-certified. The role of 
the  DDS in Appendix 1 is to e nsure input 
de rive d from non-certified suppliers does 
not contain controversial sources.  

As pe r 7.1.1 of PEFC ST 2002: 2020, the 
ce rtificate holder shall implement a Due 
Dilige nce  System (DDS) whe n input 
m ate rial is not PEFC-certified. The role of 
the  DDS in Appendix 1 is to e nsure input 
de rive d from non-certified suppliers does 
not contain controversial sources. PEFC 
ST 2002: 2020, Appendix 1, 6.1 re quire s 
that m aterial/products from unknown 
source s or from controversial sources 
shall not be included in a PEFC product 
group. 6.2 and 6.3 include additional 
provisions barring controversial material 
or m aterial which is subje ct to a 
substantiated concern, from being placed 
on the  mark et.  

J ustification 

This indicator is concluded as covered. PEFC-
ce rtifie d and Controlled Source s material is 
ide ntified as necessary. O nly 
products/materials which are  PEFC-certified 

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A . 3.1.1.4 Where 
applicable, the 
Sche m e shall 
re quire  the 
se gre gation and 
track ing of 
ce rtifie d 
(according to e ach 
individual claim 
type ) or ve rified 
le gal wood along 
the  supply chain, 
using appropriate 
inve ntory m ethods 
and documented 
controls whe re 
ne ce ssary to 
e nsure that risks 
of m ixing are  
ide ntified, 
m anaged and 
m itigated. 

PEFC  ST 2002: 2020  

4.2 Documented proce dures  
4.2.1 The organisation shall e stablish writte n documented procedure s for 
its PEFC  chain of custody. 
The  documented procedures shall include at least the following elements: 
a) re sponsibilities and authorities relating to the PEFC chain of custody 
b) de scription of the raw m aterial flow within the production/trading 
proce ss(es), including definition 
of product groups 
c) proce dures for PEFC chain o f custody process(es) covering all 
re quirements of this standard, 
including: 
i. ide ntification of material categories  
ii. physical separation of PEFC ce rtified material, PEFC controlled source s 
m ate rial 
and other m aterial 
iii. de finition of product groups, calculation of ce rtified content, 
m anagement of cre dit 
accounts, transfer to outputs (for organisations applying perce ntage or 
cre dit m e thod) 
iv. sale /transfer of products and PEFC  claims, including documentation in 
which 
PEFC  claims are made, and other o n- and off-product trademark use 
… 

4.4.1 To provide e vidence of conformity with the  requirements of this 
standard, the organisation shall establish and maintain at le ast the 
following records re lating to the product groups covered by its PEFC chain 
of custody: 
a) R e cords of all suppliers of input material delivered with a PEFC claim, 

398 

Partially 
C ove red 

or which are  not considered to be a 
controve rsial source (it has achieved the 
status of a C ontrolled Source), m ay be 
include d as input for PEFC product groups. 

F i ndings 

Standard PEFC ST 2002: 2020 m aintains 
a full se t of requirements for documented 
proce dure s for the segregation and 
track ing of certified material or other 
de signations (material with significant 
risk s, and controlled source s). 

According to PEFC ST 2002: 2020 6.1.1 
the re  are three methods to implement 
se gre gation betwe en PEFC products, 
com paring with non-certified. For the 
physical separation method, the standard 
re quire s (PEFC ST 2002: 2020 6.2.1) to 
se parate betwe en different material 
cate gories and certified content. For the 
othe r two m ethods (perce nt and cre dit) 
PEFC  100% and PEFC C ontrolled Sources 
could be m ixed.  

Howe ve r, the C oC system does not 
include  any validation of volumes 
transferre d from seller to purchaser 
(ve rification of volumes vertically up and 
down the  supply chain), which is 
considered as a m ajor gap in the system. 

J ustification 

This indicator is concluded as partially 
cove re d. Se gregation and tracking of 

 
 
 
 
 
 
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ce rtifie d material are directly addressed 
within the  normative re quirements, via a 
C O C  system re quire d of ce rtificate holders. 
Howe ve r, the C oC system does not include 
any validation of volumes transferred from 
se lle rs to purchasers (verification of 
volum es) ve rtically up and down supply 
chains, which is considered as a major gap 
in the  system. 

including evidence of the suppliers’ PEFC ce rtified status. 
Note : Evide nce can be a print-out from the PEFC we bsite. 
b) R e cords of all input m aterial, including PEFC claims and documents 
associated to the delivery of 
the  input m aterial, and for re cycled input m aterial, information 
de m onstrating that the definition of recycled material is met.  
c) R e cords of calculation of the ce rtified content, transfer of the percentage 
to output products and m anagement of the cre dit account, as applicable. 
d) R e cords of all products sold/transferred, including PEFC claims and 
docum ents associated to the delivery of the output products. 
e ) R e cords of the Due Diligence System, including records of risk 
assessments and significant risk supplies m anagement, as applicable.  
f) R e cords of internal audits, periodic chain of custody review, non-
conformities and corrective actions. g) Records on complaints and their 
re solution. 

4.9 O utsourcing 
4.9.1 The organisation may outsource  activities covere d by its PEFC chain 
of custody to another entity. 
4.9.2 Through all stages of outsourcing the organisation shall be 
re sponsible for e nsuring that all 
outsourced activities meet the re quirements of this standard,  including 
m anagement system 
re quirements. The organisation shall have a writte n agre ement with all 
e ntitie s to whom activities 
have  been outsourced, ensuring that: 
a) The  material/products covered by the organisation’s PEFC chain of 
custody are  physically 
se parated from other material or products. 

5. Ide ntification of inputs and declaration of outputs  
5.1 Identification of input material 
5.1.1 For each delivery of m aterial used as input for a PEFC product group 
the  organisation shall 
obtain documentation with the following information from the supplier: 
a) supplier identification 
b) product identification 

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c) quantity of products  
d) de livery identification based on date of delivery, delivery period, or 
accounting period 
For inputs with a PEFC claim the document shall also include: 
e ) the  organisation’s name as the PEFC customer of the delivery 
f) the  applicable PEFC claim specifically for e ach claimed product covered 
by the  documentation 
g) the  ce rtificate number of the supplier’s PEFC re cognised ce rtificate 

5.1.2 Identification at supplier le vel 
5.1.2.1 For all inputs delivere d with a PEFC claim the organisation shall 
ve rify that the supplier is 
cove re d by a PEFC re cognised ce rtificate on the PEFC we bsite. 
5.1.2.2 For each delivery of m aterial used as input for a PEFC product 
group the organisation shall 
classify the m aterial category of the procured material. 
5.2 De claration of outputs  
5.2.1 For outputs from a PEFC product group for which the  organisation 
m ak es a PEFC claim to 
a PEFC  customer, it shall provide the customer with documentation 
providing the following  
inform ation for e ach delivery: 
a) PEFC  customer identification 
b) the  organisation’s name as the supplier of the material 
c) product identification 
d) quantity of product(s) 
e ) date of delivery / delivery period / accounting period 
f) the  applicable PEFC claim specifically for e ach claimed product covered 
by the  documentation 
g) the  ce rtificate number of the organisation’s PEFC recognised ce rtificate 

6.1.1 There  are three methods to implement the PEFC chain of custody, 
nam ely the physical separation method, the perce ntage m ethod and the 
cre dit m e thod. Depending on the nature of material flows and proce sses, 
the  organisation shall choose the appropriate method. 
from  unknown sources or from controversial sources shall not be included 
in a PEFC  product group. 

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6.2 Physical separation m ethod 
… 
6.3 Pe rcentage method  
… 
6.4 C re dit method 

A.3.2 Recycled material  

A . 3.2.1  W aste 

m ate rial 

A . 3.2.1.1 The 
Sche m e shall have 
a de finition of 
waste  m aterial 
which at le ast 
cove rs the 
de finition of waste 
m ate rial as 
de scribed by the 
EUTR  Guidance 
docum ent.  

PEFC  ST 2002: 2020 3.35 R ecycled material 
Fore st and tre e based material that is: 
a) R e covered from waste during a manufacturing process. Ex cluded is 
re utilisation of materials such as rework , re grind or scrap generated in a 
proce ss and capable of being re claimed within the same process that 
ge nerated it. Excluded are by-products resulting from primary production 
proce sses, such as sawm illing by-products (sawdust, chips, bark, e tc.) or 
fore stry re sidues (bark, chips from branches, roots, e tc.) as they are not 
considered waste. 
b) Ge nerated by households or by commercial, industrial and institutional 
facilitie s in their role as e nd users of the product that can no longer be used for 
its inte nded purpose. This includes re turns of material from the distribution 
chain. 
Note  1: The term “capable of being re claimed within the same process that 
ge nerated it” means that the 
m ate rial generated in one process is continuously re turned to the same 
proce ss at the same site. An e xample is re sidue generated by a press line in a 
pane l board production that continuously re -enters the same press line. This is 
not considered as re cycled material. 
Note  2: The definition is based on definitions of ISO 14021. 
Note  3: Different e xamples of recycled material are provided in PEFC GD 2001. 

F i ndings 

Partially 
C ove red 

The  following resources are available from 
the  European C ommission in re lation to 
re claim ed material: 

 
 

EU Tim ber R egulation (995/2010) 
EUTR  Guidance document on 
R e cycle d timber and timber 
products 

The  EUTR exempts material which has 
com pleted its lifecycle and would otherwise 
be  disposed of as waste, fitting a definition 
close  to post-consumer waste. This is 
de m onstrated in the EUTR definition of 
tim be r and timber products, which e xcludes 
“timber products or components of such 
products manufactured from timber or 
timber products that have completed their 
lifecycle and would otherwise be disposed of 
as waste”[1].  

[1] Directive 2008/98/EC Article 3(1) defines 'waste ' as “any substance or object which the holder discards or intends or is required to discard ” 

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The  EUTR Guidance document on Recycled 
tim be r and timber products re inforces the 
EUTR ’s exemption for m aterial generated by 
e nd users of the product that can no longer 
be  used for its intended purpose, by 
de scribing that this exemption: 

 

 

a pplies to timber products of a kind 
cove re d by the Annex, produced 
from  m aterial that has completed 
i t s lifecycle and would otherwise 
h ave been disposed of as waste 
(e .g. re cycled paper, timber 
re trie ve d from dismantled 
buildings, or products m ade from 
waste  woo d).  
d oes not apply to by-products of a 
m anufacturing process that 
involve s material which has not 
com pleted its lifecycle and would 
o therwise have been discarded[2]. 

Mate rial deemed a by-product of a 
m anufacturing process (PEFC ST 2002: 2020 
3.35 a) is not exempt from the EUTR. 

The  EUTR Guidance document on Recycled 
tim be r and timber products describes that: 
“By-products” from another production are 
not waste  but are to be re garded as a raw 
m ate rial in the production. Material in a 
re gulated timber product is not re cycled 

[2] EUTR Guidance document on Recycled timber and timber products: “By-products” from another production are not waste but are to be regarded as a raw material in the production. Material in a reg ulated 
timber product is not recycled material if the material is the by-product of a manufacturing process. Example: Sawdust or off-cuts from sawn timber used to make particle board or medium density fibreboard.  

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m ate rial if the material is the by-product of 
a m anufacturing process. Ex ample: Sawdust 
or off-cuts from sawn timber used to make 
particle  board or medium density 
fibre board 2. 

The  standard contains a definition of waste 
m ate rial under its re cycled m aterial 
de finition: 

 

 

According to PEFC ST 2002: 2020, 3.35 
a) de scribes material re covered from 
waste  during a m anufacturing process, 
e x cluding certain types of material that 
would not be considere d as waste 
according to the definition of the EUTR. 
Ex am ples of e xcluded m aterial from the 
de finition include material capable of 
be ing re claimed within the same 
proce ss that generated it, and by-
products re sulting from primary 
production processes.  

3.35 b) describes material that can no 
longer be used for its intended purpose 
would be  considered as waste according 
to the  definition of the EUTR. This 
include s material generated by 
households or by commercial, industrial 
and institutional facilities in their role as 
e nd users of the product that can no 
longer be used for its intended purpose. 

J ustification 

This indicator is concluded as partially 
cove re d only. Definition of waste m aterial 

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from  PEFC ST 2002: 2020, 3.35 a) may 
not e ntirely align with the  definition of 
waste  m aterial as described by the EUTR 
and associated guidance document. 

A . 3.2.1.2 The 
Sche m e shall 
re quire  systematic 
proce sses to 
e nable the 
ide ntification of 
waste  m aterial 
that has 
com pleted its life 
cycle  and to 
diffe rentiate this 
m ate rial from 
virgin or m aterial 
that are  by-
products of a 
m anufacturing 
proce ss which has 
not com pleted its 
life cycle  as defined 
by the  EUTR. 

PEFC  ST 2002: 2020  

F i ndings 

Partially 
C ove red 

3.35 Forest and tre e based m aterial that is: 
a) R e covered from waste during a manufacturing process. Ex cluded is 
re utilisation of materials such as rework , re grind or scrap generated in a 
proce ss and capable of being re claimed within the same process that 
ge nerated it. Excluded are by-products resulting from primary production 
proce sses, such as sawm illing by-products (sawdust, chips, bark, e tc.) or 
fore stry re sidues (bark, chips from branches, roots, e tc.) as they are not 
considered waste. 
b) Ge nerated by households or by commercial, industrial and institutional 
facilitie s in their role as e nd-users of the product that can no longer be used for 
its inte nded purpose. This includes re turns of material from the distribution 
chain. 
Note  1: The term “capable of being re claimed within the same process that 
ge nerated it” means that the 
m ate rial generated in one process is continuously re turned to the same 
proce ss at the same site. An e xample is re sidue generated by a press line in a 
pane l board production that continuously re -enters the same press line. This is 
not considered as re cycled material. 
Note  2: The definition is based on definitions of ISO 14021. 
Note  3: Different e xamples of recycled material are provided in PEFC GD 
2001. 

4.4 R e cord keeping 
4.4.1 To provide e vidence of conformity with the  requirements of this 
standard, the organisation shall 
e stablish and m aintain at least the following records re lating to the product 
groups covered by its 
PEFC  chain of custody: 
… 
b) R e cords of all input m aterial, including PEFC claims and documents 

The  standard contains a definition of 
waste  m aterial under its re cycled material 
de finition, as in PEFC ST 2002: 2020, 
3.35.b), as e xplained in A3.2.1.1.  

According to this definition, PEFC ST 
2002: 2020 4.41, re quires that the 
ce rtificate holder shall e stablish and 
m aintain re cords relating to the product 
groups covered by its PEFC chain of 
custody. This includes maintaining re cords 
of all input material, including PEFC claims 
and documents associated to  the delivery 
of the  input m aterial, and for re cycled 
input m aterial, information demonstrating 
that the  definition of re cycled material is 
m e t. 

Howe ve r, m aterial that would not be 
considered as waste according to the 
de finition of the EUTR (3.35 a) could be 
m ix ed with m aterial that considered the 
de finition of the EUTR (3.35 b). 

J ustification 

This indicator is concluded as partially 
cove re d. PEFC standard allows mixing of 
m ate rial that would not be considered as 
waste  according to the definition of the EUTR 

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A . 3.2.1.3 The 
Sche m e shall include 
cle ar and e ffective 
m e asures to prevent 
“tim ber products of a 
k ind covered by the 
Anne x of the EUTR”, 
produced from i) 
re claim ed material 
that has NO T 
com pleted its 
life cycle  and would 
othe rwise  have been 
discarded as waste”,  
ii) unve rified or  
iii) virgin m aterial (as 
de fined by the EUTR) 
from , e ntering the 
supply chain.  

associated to the delivery of 
the  input m aterial, and for re cycled input m aterial, information 
de m onstrating that the definition of 
re cycle d m aterial is met. 

5.4 C ontent of recycled material 
5.4.1 For products covered by the organisation’s PEFC chain of custody that 
include  recycled material, 
the  organisation shall calculate the content of re cycled material based on 
ISO  14021 and inform 
about it upon re quest. 
PEFC  ST 2002: 2020  

(3.35 a) with m aterial that considered the 
de finition of the EUTR (3.35 b). 

F i ndings 

Partially 
C ove red 

3.35 Forest and tre e based m aterial that is: 
a) R e covered from waste during a manufacturing process. Ex cluded is 
re utilisation of materials such as rework , re grind or scrap generated in a 
proce ss and capable of being re claimed within the same process that 
ge nerated it. Excluded are by-products resulting from primary production 
proce sses, such as sawm illing by-products (sawdust, chips, bark, e tc.) or 
fore stry re sidues (bark, chips from branches, roots, e tc.) as they are not 
considered waste. 
b) Ge nerated by households or by commercial, industrial and institutional 
facilitie s in their role as e nd-users of the product that can no longer be used for 
its inte nded purpose. This includes re turns of material from the distribution 
chain. 
Note  1: The term “capable of being re claimed within the same process that 
ge nerated it” means that the 
m ate rial generated in one process is continuously re turn ed to the same 
proce ss at the same site. An e xample is re sidue generated by a press line in a 
pane l board production that continuously re -enters the same press line. This is 
not considered as re cycled material. 
Note  2: The definition is based on definition s of ISO 14021. 
Note  3: Different e xamples of recycled material are provided in PEFC GD 
2001. 

4.4 R e cord keeping 
4.4.1 To provide e vidence of conformity with the  requirements of this 

The  standard contains a definition of 
waste  m aterial under its re cycled material 
de finition, as in PEFC ST 2002: 2020, 
3.35. 

According to this definition, PEFC ST 
2002: 2020 4.41, re quires that the 
ce rtificate holder shall e stablish and 
m aintain re cords relating to the product 
groups covered by its PEFC chain of 
custody. This includes maintaining re cords 
of all input material, including PEFC claims 
and documents associated to  the delivery 
of the  input m aterial, and for re cycled 
input m aterial, information demonstrating 
that the  definition of re cycled material is 
m e t. 

Howe ve r, m aterial that would not be 
considered as waste according to the 
de finition of the EUTR (3.35 a) could be 
m ix ed with m aterial that considered the 
de finition of the EUTR (3.35 b). 

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standard, the organisation shall 
e stablish and m aintain at least the following records re lating to the product 
groups covered by its 
PEFC  chain of custody: 
… 
b) R e cords of all input m aterial, including PEFC claims and documents 
associated to the delivery of 
the  input m aterial, and for re cycled input m aterial, information 
de m onstrating that the definition of 
re cycle d m aterial is met. 

5.4 C ontent of recycled material 
5.4.1 For products covered by the organisation’s PEFC chain of custody that 
include  recycled material, 
the  organisation shall calculate the content of re cycled material based on 
ISO  14021 and inform 
about it upon re quest. 

J ustification 

This indicator is concluded as partially 
cove re d. PEFC standard allows mixing of 
m ate rial that would not be considered as 
waste  according to the definition of the 
EUTR  (3.35 a) with m aterial that 
considered the definition of the EUTR 
(3.35 b). 

A.4 General requirements for Certificate Holders 

A . 4.1 

C onflict 
re solution 

A . 4.1.1 The 
Sche m e shall 
include  
re quirements that 
e nsure that 
disputes are  
ide ntified, 
re corde d and 
m anaged, in a way 
that: 

i) e nsures there is 
a transparent 
ongoing process to 
addre ss the issue 
ii) re quires for the 
e x clusion from the 

PEFC  ST 1003: 2018  

6.3.2 Legal, customary and traditional rights re lated to the forest land  
… 
6.3.2.2 The standard re quires that fore st practices and operations shall be 
conducted in re cognition of 
the  e stablished framework  of legal, customary and traditional rights such as 
outlined in ILO 169 
and the UN De claration on the Rights of Indigenous Peoples, which s hall not 
be  infringed upon 
without the  free, prior and informed consent of the holders of the rights, 
including the provision of compensation whe re applicable. Where  the e xtent 
of rights is not ye t re solved, or is in dispute, 
the re  are processes for just and fair re solution. In such cases forest 
m anagers shall, in the interim, 
provide m eaningful opportunities for parties to be engaged in forest 
m anagement decisions whilst 

Fore st 
Manageme
nt: 
Partially 
cove re d. 

C hain of 
custody: 
C ove red. 

F i ndings 

Fore st Management 

According to PEFC ST 1003: 2018 7.4.1 
fore st management standards require the 
ce rtificate holders should implement a 
m e chanism for re solving complaints and 
disputes re lating to forest management 
ope rations, land use rights and work  
conditions. Related to transparency, 
indicator 7.3.1. re quires certificate 
holders to communicate and consult with 
stak eholders re lating to sustainable forest 
m anagement, which could be assimilated 
as transparent process to addre ss issues.  

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scope  of the 
ce rtificate 
situations or areas 
or fore st whe re 
the  le gality of 
te nure  or 
m anagement/harv
e sting is not 
de fined or is 
uncle ar and 
disputed. 
iii e nsures re spect 
for le gally-
e nshrined 
customary te nure 
rights of local 
com m unities. 

re spe cting the processes and roles and responsibilities laid out in the policies 
and laws whe re the 
ce rtification takes place. 

7.3.1 The standard re quires that e ffective communication and consultation 
with local communities, 
indigenous peoples and other stakeholders relating to sustainable forest 
m anagement shall be provided. 

7.4 C omplaints  
7.4.1 The standard re quires that appropriate mechanisms are in place for 
re solving complaints and disputes relating to forest m anagement operations, 
land use rights and work  conditions. 

PEFC  ST 2002: 2020  

3.7 C ontroversial source s 

Fore st and tre e based material source d from: 

a) Activitie s not complying with applicable local, national or international 
le gislation on forest management, including but not limited to forest 
m anagement practices; nature and e nvironmental protection; protected and 
e ndangered species; property, te nure and land-use rights for indigenous 
pe oples, local communities or other affected stakeholders; health, labour 
and safety issues; anticorruption and the payment of applicable royalties 
and taxes. 

3.37 Substantiated concern 
Information supported by proof or e vidence, indicating that forest and tre e 
based material originates in controversial sources. 
Note : Substantiated concerns can be concerns by third parties, as we ll as 
conce rns of the organisation itself. 

4.4.1 To provide e vidence of conformity with the  requirements of this 
standard, the organisation shall establish and maintain at le ast the following 
re cords re lating to the product groups covered by its PEFC chain of custody:  
… 
g) R e cords on complaints and their re solution. 

PEFC  ST 1003: 2018 6.3.2.2 re quires that 
whe re  the  e xtent of rights is not yet 
re solved or is in dispute, there are 
proce sses for a just and fair re solution. In 
such cases, forest m anagers are re quire d 
to, in the  interim, provide meaningful 
opportunities for parties to be engaged in 
fore st management decisions whilst 
re spe cting the processes and roles and 
re sponsibilities laid out in the policies and 
laws whe re  the  ce rtification takes place. 

I re lation to point ii) of the indicator, 
standard re quirements do not e xtend to 
re quiring the exclusion from the scope of 
the  ce rtificate situations or areas or forest 
whe re  the  le gality of te nure  or 
m anagement/harvesting is not defined or 
is uncle ar and disputed.  

In summary, re quirements 7.4.1 and 
6.3.2.2 re quire  a process but do not 
spe cifically re quire  exclusion. So it is true 
that “if the fore st managers cannot 
de m onstrate compliance with 7.4.1 and 
6.3.2.2, they cannot be certified”, but it is 
not true  that the are a requires exclusion. 

C hain of C ustody 

According to PEFC ST 2002: 2020 4.4.1 g) 
re cords on complaints and their re solution 
should be kept by the certificate holder. 
PEFC  ST 2002: 2020 4.7 explain the 
com plaint procedure. PEFC ST 2002: 2020  

C e rtificate holders sourcing PEFC-certified 

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4.7 C omplaints 
4.7.1 The organisation shall e stablish procedures for dealing with complaints 
from  suppliers, customers and other parties re lating to its chain of custody, 
re fle cting the requirements of 4.7.2. 
4.7.2 Upon re ceipt of a complaint in writing, the organisation shall: 
a) form ally acknowle dge the complaint to the complainant within ten 
work days 
b) gather and verify all necessary information to e valuate and validate the 
com plaint and make a  decision on the complaint 
c) form ally communicate the decision on the complaint and of the complaint 
handling process to the complainant 
d) e nsure that appropriate corre ctive and pre ventive actions are taken, if 
ne ce ssary 

7.1.2 For PEFC  product groups whe re only input material used was delivered 
with a P EFC  claim by a supplier covere d by a PEFC recognised ce rtificate, an 
organisation may implement the PEFC DDS by meeting the following 
re quirements: 
a) In order to e nable PEFC certified and uncertified entities further down the 
supply chain to implement a DDS, the organisation shall, upon re quest, 
provide the information specified in Appendix 1, 2.1 for material passed on 
with a PEFC  claim. If the organisation does not possess the requested 
inform ation, the re quest shall be passed on to relevant supplier(s) of the 
organisation (Appendix 1, 2.2). 
b) W here  internal or e xternal substantiated concerns on the origin of input 
m ate rial from controversial sources are raised, the organisation shall follow 
up on these concerns following Appendix 1, 4. 
c) The  organisation shall define, document and implement a commitment 
and a procedure, also covering forest and tre e based material/products not 
cove re d by the organisation’s PEFC chain of custody, e nsuring that whe re it 
is k nown to the organisation, or whe re  it has re ceived substantiated 
conce rns, that forest and tree based m aterial/products originates in illegal 
source s (controversial source s, 3.7a), it shall not be placed on the m arket 
until the  concern has been re solved in accordance with Appendix 1, 4.  

Appe ndix 1, 4.1 The organisation shall ensure that substantiated concerns 
about the potential origin of material covere d by the organisation’s DDS in 

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products have the option (i.e. it is 
voluntary) to implement a Due Diligence  
Syste m  based on requirement 7.1.2 of 
the  m ain standard PEFC ST 2002: 2020. 
This is a re duced DDS focussing on 
obtaining from suppliers – and passing 
downstre am buyers - information relating 
to spe cies and origin, as we ll as 
addre ssing internal or external 
substantiated concerns that may be 
raise d in re lation to the products sourced. 
7.1.2 b) requires that material with 
substantiated concerns, shall not be 
place d on the market until the concern is 
inve stigated and has been re solved. 

As pe r 7.1.1 of PEFC ST 2002: 2020, the 
ce rtificate holder shall implement a Due 
Dilige nce  System (DDS) whe n input 
m ate rial is not PEFC-certified. The role of 
the  DDS in Appendix 1 is to e nsure input 
de rive d from non-certified suppliers does 
not contain controversial sources. For 
e ntitie s applying this Due Diligence 
Syste m , PEFC ST 2002: 2020 Appendix 1, 
re quirements 4.1 and 4.2 apply in case of 
substantiated concerns, the certificate 
holder shall not place  products on the 
m ark et. 

R e lated to the transparency, PEFC 
re quirements do include limited m easures 
that the  dispute or complaint is handled in 
a transparent way with the  complainant, 
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controve rsial sources are promptly investigated, starting no later than ten 
work days as of identification of the substantiated concern. 

J ustification 

Appe ndix 1, 4.2 If the concern cannot be re solved by the organisation’s 
inve stigation, the risk of the re levant material being from controversial 
source s shall be determined as “significant” and managed in accordance 
with cla use 5 of this appendix. 

6. No placement on the m arket 
6.3 W here the organisation has received substantiated concerns that forest 
and tre e based 
m ate rials/products not covered by the organisation’s PEFC chain of custody 
originate in illegal 
source s (controversial source s, 3.7a), it shall not be placed on the m arket 
until the  concern has 
be e n re solved in accordance with clause 4 of this appendix. 

This indicator is concluded as partially 
cove re d for forest m anagement 
ce rtification and chain of custody 
ce rtification. For forest m anagement 
ce rtification, standard re quirements do 
not e x tend to requiring the exclusion from 
the  scope of the ce rtificate situations or 
are as or fore st whe re the legality of 
te nure  or m anagement/harvesting is not 
de fined or is unclear and disputed.  

In the  case of chain of custody, standard 
re quirements re quire e xclusion from the 
scope  of the certificate, material for which 
the re  are unre solved substantiated 
conce rns. Basic requirements e xist in 
re lation to the transparency of 
dispute/complaint re solutions processes. 

C orruption  

A . 4.1.2 The scheme 
shall include 
re quirements to 
e nsure that 
ce rtificate holders do 
not e ngage in corrupt 
practice s re lated to 
ille gal harvesting. 

PEFC  ST 1003: 2018  
6.3.1.2 The standard re quires that the organisation shall comply with 
applicable local, national and  
inte rnational le gislation on forest management, including but not limited to 
fore st management 
practice s; nature  and environmental protection; protected and endangere d 
spe cies; property, te nure and land-use rights for indigenous peoples, local 
com m unities or other affecte d stakeholders; health, labour a nd safety 
issues; anti-corruption and the payment of applicable royalties and taxes. 

6.3.1.3 The standard re quires that whe re no anti-corruption legislation 
e x ists, the organisation must take alternative anti-corruption measure s 
appropriate to the risk of corruption. 

Fore st 
Manageme
nt: 
cove re d. 

C hain of 
custody: 
Not 
C ove red. 

F i ndings 

Fore st Management 

According to PEFC ST 1003: 2018 - 
6.3.1.3, anti-corruption measures should 
be  tak en if there  is no legislation in the 
country. In countries whe re  anti-
corruption le gislation is in place, this 
should be followe d by the ce rtificate 
holder (6.3.1.2).  

C hain o f custody 

According to PEFC ST 2002: 2020 3.9, 

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PEFC  ST 2002: 2020  
3.7 C ontroversial source s 
Fore st and tre e based material source d from: 
a) Activitie s not complying with applicable local, national or international 
le gislation on forest  
m anagement, including but not limited to fore st management practice s; 
nature  and environmental 
prote ction; protected and endangered species; property, te nure  and land -
use  rights for indigenous peoples, local communities or other affected 
stak eholders; health, labour and safety issues; anti- 
corruption and the payment of applicable royalties and taxes. 

3.9 Due  Diligence System (DDS) 
A fram e work of proce dures and measure s, namely information gathering, 
risk  assessment and risk  
m itigation, implemented by an organisation to reduce the risk that fore st 
and tre e based m aterial originates from controversial sources. 

7.1.1 For all material used as input for a PEFC product group, e xcept 
re cycle d m aterial, the organisation shall exercise due diligence in line with 
the  PEFC  Due Diligence System (DDS) for the avoidance  of material from 
controve rsial sources laid down in Appendix 1 of this standard. Thereby the 
organisation shall e stablish that for m aterial used as input for PEFC product 
groups there is “negligible risk” that it originates from controversial source s 
and that it m eets the definition of PEFC controlled sources material. 

and 7.1.1 ce rtificate holder should 
im plement a mechanism to e nsure  that 
products are not originated from 
controve rsial sources (PEFC ST 2002: 
2020 3.7). Howe ver, these indicators do 
not re quire  the ce rtificate holder itself to 
avoid engaging in corrupt practices. 

J ustification 

At the  le ve l of PEFC International, this 
indicator is concluded as covered for 
fore st management and not covere d for 
chain of custody. For fore st management, 
corrupt practices related to illegal 
harve sting is directly addressed in the 
norm ative re quirement at the le vel of 
PEFC  International. For chain of custody, 
the re  is no re quirement that certificate 
holders do not e ngage in corrupt practices 
re late d to illegal harvesting. 

A.5 Quality and procedural requirements for Certificate Holders 

A . 5.1 

Inte rnal 
proce dure s 
for 
C e rtificate 
Holde rs 

A . 5.1.1 The 
Sche m e shall 
include  
re quirements for 
the  C e rtificate 
Holde rs to have in 
place  - and 
im plement - 
syste ms and 

PEFC  ST 1003: 2018 
7.5 Documented Information 
7.5.1 The standard re quires that the organisation’s m anagement system 
shall include documented  
inform ation required by the standard and determined by the organisation as 
be ing necessary for the e ffectiveness of the sustainable fore st management 
syste m. 
7.5.2 The standard re quires that the documented information is re levant, 
and updated as appropriate, to the activities of the organisation. 

F i ndings 

C ove red 

Fore st management 

According to PEFC ST 1003: 2018 7.5.1, 
fore st management standards require 
that the  ce rtificate holder shall have a 
docum ented management system, which 
is re le vant, and updated as appropriate, 

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to the  activities of the organisation.  

C hain of custody 

According to PEFC ST 2002: 2020 the 
ce rtificate holder shall have documented 
proce dure s for its PEFC chain of custody, 
including the definition of re sponsibilities 
and the m aintenance of re cords.  

J ustification 

This indicator is concluded as covered for 
fore st management and chain of custody. 
Docum ented systems and procedures 
cove ring all requirements of the re levant 
standards are re quired both for Fore st 
Management and Chain of Custody 
ce rtification. 

proce dure s 
cove ring all 
re quirements of 
the  Sche me. 

PEFC  ST 2002: 2020  
4.2 Documented proce dures  
4.2.1 The organisation shall e stablish writte n documented procedure s for its 
PEFC  chain of custody. 
The  documented procedures shall include at least the following elements: 
a) re sponsibilities and authorities relating to the PEFC chain of custody 
b) de scription of the raw m aterial flow within the production/trading 
proce ss(es), including definition 
of product groups 
c) proce dures for PEFC chain of custody process(es) covering all 
re quirements of this standard, including: 
i. ide ntification of material categories  
ii. physical separation of PEFC ce rtified material, PEFC controlled source s 
m ate rial and other m aterial 
iii. de finition of product groups, calculation of ce rtified content, management 
of cre dit accounts, transfer to outputs (for organisations applying 
pe rce ntage or cre dit method) 
iv. sale /transfer of products and PEFC  claims, including documentation in 
which PEFC  claims are m ade, and other on- and off-product trademark use 
v. re cord k eeping 
vi. inte rnal audits and non-conformity control 
vii. the  Due Diligence System 
viii. com plaints resolution 
ix . outsourcing  

4.3.1.1 The organisation’s management shall define and document its 
com m itment to implement and maintain the chain of custody requirements 
in accordance with this standard. The organisation’s commitment shall be 
m ade available to the organisation’s personnel, suppliers, customers, and 
othe r interested parties. 
4.3.1.2 The organisation’s management shall appoint a member of the 
m anagement who, irre spective of other re sponsibilities, shall have overall 
re sponsibility and authority for the organisation’s PEFC  chain of custody.  

4.4.1 To provide e vidence of conformity with the  requirements of this 
standard, the organisation shall establish and maintain at le ast the following 

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re cords re lating to the product groups covered by its PEFC chain of custody:  
a) R e cords of all suppliers of input material delivered with a PEFC claim, 
including evidence of the suppliers’ PEFC ce rtified status. 
Note : Evide nce can be a print-out from the PEFC we bsite. 
b) R e cords of all input m aterial, including PEFC claims and documents 
associated to the delivery of the input material, and for re cycled input 
m ate rial, information demonstrating that the definition of re cycled m aterial 
is m e t. 
c) R e cords of calculation of the ce rtified content, transfer of the percentage 
to output products and m anagement of the cre dit account, as applicable. 
d) R e cords of all products sold/transferred, including PEFC claims and 
docum ents associated to the delivery of the output products. 
e ) R e cords of the Due Diligence System, including records of risk 
assessments and significant risk supplies m anagement, as applicable. 
f) R e cords of internal audits, periodic chain of custody review, non-
conformities and corrective actions. g) Records on complaints and their 
re solution. 
PEFC  ST 1003: 2018 
1. Scope  
This document constitutes PEFC International’s Sustainability Be nchmark for 
PEFC  e ndorsed re gional, national or sub-national standards for the 
sustainable management of forests and Trees outside Forests, covering all 
the ir products and services. Through PEFC endorsed standards, which are 
de ve loped in a balanced multi-stakeholder process following PEFC 
Inte rnational’s Sustainability Benchmark for standard setting, the 
re quirements outlined in this document apply to owne rs and managers, as 
we ll as contractors and other operators operating in PEFC-certified areas. 
The y cover all necessary processes of a m anagement system that aims at 
sustainable forest management. 

7.5.2 The standard re quires that the documented information is re levant, 
and updated as appropriate, to the activities of the organisation. 

9.2 Internal audit 
9.2.1 O bjectives 
The  standard re quires that an internal audit programme at planned intervals 
shall provide information on whe ther the m anagement system 

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A . 5.1.2 The 
Sche m e shall 
include  
re quirements for 
the  C e rtificate 
Holde rs to 
re gularly re view 
the  proper 
functioning of their 
own proce dure s. 

F i ndings 

C ove red 

Fore st management 

PEFC  ST 1003: 2018 7.5.2 re quires 
docum ented information to be updated by 
the  ce rtificate holder and contractors 
(PEFC  ST 1003: 2018, 1). Se ction 9 of the 
sam e standard outlines the re quirements 
for a re gular internal audit programme 
that shall provide information on whe ther 
the  m anagement system is effectively 
im plemented and maintained, and 
conforms to the requirements of the 
national sustainable fore st management 
standard. 

C hain of custody 

According to PEFC ST 2002: 2020 4.2.1 

 
 
 
 
 
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and 4.4.1 f) the certificate holder should 
conduct internal audits and periodic 
re vie w the  chains of custody, non-
conformities, and corre ctive actions. PEFC 
ST 2002: 2020 4.6 gives additional 
instruction re lated to the internal audits. 
At the  same time, PEFC ST 2002: 2020 
4.9 de fines the procedure s for the proper 
functioning of outsourcing activities. 

J ustification 

At the  le ve l of PEFC International, this 
indicator is concluded as covered for forest 
m anagement and chain of custody. 
R e gularly re view the proper functioning of 
own syste ms and proce dures is directly 
addre ssed in the normative re quirements. 

a) conforms to  
• the  organisation’s requirements for its management system; 
• the  re quirements of the national sustainable fore st management standard 
b) is e ffectively implemented and m aintained. 
9.2.2 O rganisation 
The  standard re quires that the organisation shall: 
a) plan, establish, implement and m aintain an audit programme(s) including 
the  fre quency, methods, responsibilities, planning requirements and 
re porting, which shall take into consideration the importance of the 
proce sses conce rned and the re sults of previous audits; 
b) de fine the audit criteria and scope for each audit; 
c) se le ct the auditors and conduct audits to ensure obje ctivity and the 
im partiality of the audit process; 
d) e nsure that the re sults of the audits are  reported to relevant 
m anagement; 
e ) re tain documented information as evidence  of the implementation of the 
audit programme and the 
audit re sults. 
9.3 Management re view 
9.3.1 The standard re quires that an annual m anagement re view shall at 
le ast include 
a) the  status of actions from pre vious management reviews;  
b) changes in e xternal and internal issues that are re levant to the 
m anagement system; 
c) inform ation on the organisation’s performance, including tre nds in: 
• nonconformities and corre ctive actions; 
• m onitoring and m easurement re sults; 
• audit re sults; 
d) opportunities for continual improvement. 
9.3.2 The standard re quires that the outputs of the m anagement re view 
shall include decisions re lated to continual improvement opportunities and 
any ne ed for changes to the management system. 
9.3.3 The standard re quires that documented information as evidence  of the 
re sults of management 
re vie ws shall be re tained. 

PEFC  ST 2002: 2020  

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4.2.1 The organisation shall e stablish writte n documented procedure s for its 
PEFC  chain of custody. The documented procedures shall include at least the 
following elements: 
a) re sponsibilities and authorities relating to the PEFC chain of custody 
b) de scription of the raw m aterial flow within the production/trading 
proce ss(es), including definition of product groups 
c) proce dures for PEFC chain of custody process(es) covering all 
re quirements of this standard, including: 
… 
vi. inte rnal audits and non-conformity control  

4.4.1 To provide e vidence of conformity with the  requirements of this 
standard, the organisation shall establish and maintain at le ast the following 
re cords re lating to the product groups covered by its PEFC chain of  custody: 
… 
f) R e cords of internal audits, periodic chain of custody review, non-
conformities and corrective actions. 

4.6 Inspection and control 
4.6.1 The organisation shall conduct internal audits at le ast annually, and 
prior to the  initial certification  
audit, covering its compliance with all re quirements of this standard 
applicable to the organisation, 
including activities covere d by outsourcing, and establish corre ctive and 
pre ve ntive measures 
if re quire d. 
Note : Informative guidance for performing internal audits is given in ISO 
19011. 
4.6.2 The organisation’s management shall re view the  re sult of the internal 
audit and the organisation’s 
PEFC  chain of custody at least annually. 

4.9 O utsourcing 
4.9.1 The organisation may outsource  activities covere d by its PEFC chain of 
custody to another entity. 
4.9.2 Through all stages of outsourcing the organisation shall be re sponsible 
for e nsuring that all 

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outsourced activities meet the re quirements of this standard, including 
m anagement system 
re quirements. The organisation shall have a writte n agre ement with all 
e ntitie s to whom activities 
have  been outsourced, ensuring that: 
a) The  material/products covered by the organisation’s PEFC chain of 
custody are  physically 
se parated from other material or products. 
b) The  organisation has access to the entity’s site(s) for internal and 
e x te rnal auditing of outsourced 
activitie s for conformity with the  requirements of this standard. 
Note  1: A te mplate for an outsourcing agre ement can be obtained from the 
PEFC  C ouncil and P EFC 
authorised bodies. 
Note  2: Internal audits of outsourced activities should be conducted at least 
annually and before the 
outsourced activity starts. 
PEFC  ST 1003: 2018 
7.2.1 The standard re quires that fore st managers, contractors, employees 
and forest owners shall be 
provided with sufficient information and kept up-to-date through continuous 
training in re lation to sustainable forest management, as a pre condition for 
all m anagement planning and practices described in this benchmark.  

8.2.10 The standard re quire s that the use of pesticides shall follow the  
instructions given by the pesticide producer and be implemented with proper 
e quipment by trained personnel. 

PEFC  ST 2002: 2020  
4.5.1 Human re source s/personnel 
The  organisation shall e nsure and demonstrate that all personnel performing 
activitie s affecting the  
im plementation and maintenance  of its PEFC chain of custody are competent 
on the  basis of appropriate training, e ducation, skills and e xperience .  

Appe ndix 1, 5.3.2 The organisation shall demonstrate that personnel 
carrying out inspections has sufficient k nowle dge and competence in the 

415 

A . 5.2 

Q ualification 
and 
com petence  

A . 5.2.1 The 
Sche m e shall 
include  
re quirements that 
e nsure that 
ce rtifie d 
organisations have 
pe rsonnel with 
sufficient 
qualifications and 
com petencies to 
consistently and 
e ffe ctively 
im plement 
Sche m e 
re quirements. 

F i ndings 

C ove red 

Fore st management 

According to PEFC ST 1003: 2018 7.2.1 
staff shall be provided with sufficient 
inform ation and kept up-to-date through 
continuous training in re lation to 
sustainable forest management, as a 
pre condition for all m anagement planning 
and practice s described in this 
be nchmark. It is not explicit that this 
m ust be in re lation to the m anagement 
syste m and procedures, and to ensure 
the ir e ffective implementation. According 
to PEFC  ST 1003: 2018 8.2.10 application 
of pe sticides shall follow instructions 
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local business, cultural and social customs, and applicable 
tre atie s, conventions legislation, governance and law e nforcement, re levant 
to the  origin of 
“significant risk” supplies and to the risk(s) identified. 

C hain of custody 

According to PEFC ST 2002: 2020 4.5.1 
organisation shall e nsure that staff 
work ing in implementation and 
m aintenance  is qualified (training, 
e ducation, skills, e xperience). It is not 
cle ar if PEFC  International consistently 
include s training of staff on Scheme 
re quirements. 

For e ntities that is applying Due Diligence 
Syste m , define in Appendix 1: According 
to PEFC  ST 2002: 5.3.2 organisation shall 
e nsure that staff conducting the 
inspections has sufficient knowle dge and 
com petence . It is not cle ar if PEFC 
Inte rnational consistently includes training 
of staff on Scheme requirements. 

J ustification 

This indicator is concluded as covered for 
fore st management and chain of custody. 
R e quirements are included that ce rtified 
organisations have personnel with sufficient 
com petencies to implement Scheme 
re quirements. 

A . 5.3 

R isk  based 
approaches 
to sourcing, 
trade  or 
production 

A . 5.3.1 If the 
Sche m e includes an 
option to implement 
a risk  based 
approach to sourcing 
non-certified material 
(Due  Diligence 
Syste m ), it shall: i) 

PEFC  ST 2002: 2020 

3.28 PEFC controlled sources 

Mate rial category covering forest and tre e based material for which an 
organisation has determined through its Due Diligence System th at there  is 
“ne gligible risk” that the material is from controversial sources. 

3.7 C ontroversial source s 

F i ndings 

C ove red 

Fore st management  

Fore st management re quirements do not 
include  a risk based approach to sourcing 
non-certified material. 

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contain clear 
re quirements and ii) 
e nsure consistent 
im plementation of 
the  Due  Diligence 
Syste m , for all 
activitie s, materials 
and suppliers 
include d within the 
scope  of the 
ce rtification. 

Fore st and tre e based material source d from: 

C hain of custody 

a) Activitie s not complying with applicable local, national or international 
le gislation on forest management, including but not limited to forest 
m anagement practices; nature and e nvironmental protection; protected and 
e ndangered species; property, te nure and land-use rights for indigenous 
pe oples, local communities or other affected stakeholders; health, labour 
and safety issues; anticorruption and the payment of applicable royalties 
and taxes. 

6.1.4 The organisation shall only use PEFC  certified material and PEFC 
controlled sources m aterial  
as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, e xcept 
re cycle d m aterial, the organisation shall exercise due diligence in line with 
the  PEFC  Due Diligence System (DDS) for the avoidance  of material from 
controve rsial sources laid down in Appendix 1 of this standard. Thereby the 
organisation shall e stablish that for m aterial used as input for PEFC product 
groups there is “negligible risk” that it originates from controversial source s 
and that it m eets the  
de finition of PEFC controlled sources material. 

7.1.2 For PEFC  product groups whe re only input material used was delivered 
with a PEFC  claim by a supplier covere d by a PEFC recognised ce rtificate, an 
organisation may implement the PEFC DDS by meeting the following 
re quirements: 
a) In order to e nable PEFC certified and uncertified entities further down the 
supply chain to implement a DDS, the organisation shall, upon re quest, 
provide the information specified in Appendix 1, 2.1 for material passed on 
with a PEFC  claim. If the organisation does not possess the requested 
inform ation, the re quest shall be passed on to relevant supplier(s) of the 
organisation (Appendix 1, 2.2). 
b) W here  internal or e xternal substantiated concerns on the origin of input 
m ate rial from controversial sources are raised, the organisation shall follow 
up on these concerns following Appendix 1, 4. 
c) The  organisation shall define, document and implement a commitment 
and a procedure, also covering forest and tre e based material/products not 
cove re d by the organisation’s PEFC chain of custody, e nsuring that whe re it 

According to PEFC ST 2002: 2020 6.1.4, 
the  ce rtificate holder m ay choose to use 
controlled sources in their products. 
C ontrolled source s are defined by PEFC ST 
2002: 2020 3.28, as inputs into a due 
dilige nce system which are  concluded with 
ne gligible risk in re lation to the definition 
in the  standard of Controversial sources 
(PEFC  ST 2002: 2020 3.7). 

R e quirement 7.1.1 of PEFC ST 2002: 
2020, describes that the ce rtificate holder 
shall implement a Due Diligence System 
(DDS) whe n sourcing input material which 
is not PEFC-certified. The re quirements 
for due  diligence  are contained within 
Appe ndix 1 of standard (PEFC ST 2002: 
2020), the obje ctive of which is to ensure 
non-certified materials or products which 
are  source d by the C ertificate Holder do 
not de rive from controversial sources. The 
DDS in Appe ndix 1 is not expected to be 
applied to the C ertificate holder itself or to 
PEFC -ce rtified material.  

In the  case that materials or products 
which are  sourced by the Certificate 
Holde r are  PEFC ce rtified, the certificate 
holder has the option to implement a Due 
Dilige nce  System based on re quirement 
7.1.2 of the main standard PEFC ST 2002: 
2020. This is a  re duced DDS focussing on 
obtaining information in re lation to 
spe cies and origin, as we ll as addressing 
inte rnal or e xternal substantiated 

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is k nown to the organisation, or whe re  it has re ceived substantiated 
conce rns, that forest and tree based m aterial/products originates in illegal 
source s (controversial source s, 3.7a), it shall not be placed on the m arket 
until the  concern has been re solved in accordance with Appendix 1, 4  

conce rns that m ay be raised in relation to 
the  products source d. 

J ustification 

Not applicable to forest management. 

This indicator is concluded as covered for 
the  chain of custody. Normative 
re quirements are  described for the 
consistent implementation of a DDS for 
sourcing non-certified material. 

PEFC  ST 2002: 2020 - Appendix 1: PEFC Due Diligence System (DDS) for 
the  avoidance of m aterial from controversial sources 
1.1 In order to help ensure  that activities conducted by the organisation 
unde r the scope of this standard conform to all applicable timber legality 
le gislation, including trade and customs laws, and to minimise the risk that 
the  procured m aterial originates in controversial source s, the organisation 
shall operate a Due Diligence System (DDS), in accordance with the  
following elements o f this standard. 

Appe ndix 1, Table 1: List of indicators for ne gligible risk 

a) Supplies declared as ce rtified against a forest ce rtification system (other 
than PEFC e ndorsed),  addressing the activities covered by the term 
controve rsial sources, supported by a fore st management, chain of custody 
or fibre  sourcing ce rtificate issued by a third party certification body.  

b) Supplies verified by governmental or non-governmental ve rification or 
lice nsing m echanisms other than forest ce rtification systems, addressing the 
activitie s covered by the term controversial sources.  

c) Supplies supported by ve rifiable documentation that clearly identifies:  

i. country of harvest and/or sub-national re gion whe re the timber was 
harve sted, whe re  the latest  

Transparency International (TI) C orruption Perce ption Index (CPI) score is 
highe r than 50, or whe re  the latest World Justice Project (W JP) Rule of Law 
Inde x is higher than 0,5, and 

ii. trade  name and type of product as we ll as the common name of tree 
spe cies and, whe re applicable, its full scientific name, and 

iii. all suppliers within the supply chain, and 

iv. the  forest area of the supply origin, and 

v. docum ents, including contractual agre ements and self -declarations, or 
othe r re liable information indicating that products do not originate from 
controve rsial sources.  

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Appe ndix 1, Table 2: List of indicators for significant risk at origin level 

a) Activitie s not complying with applicable local, national or international 
le gislation on forest management, including but not limited to forest 
m anagement practices; nature and e nvironmental protection; protected and 
e ndangered species; property, te nure and land-use rights for indigenous 
pe oples, local communities or other affected stakeholders; health, labour 
and safety issues; anti-corruption and the payment of applicable royalties 
and taxes. 

i. The  latest Transpare ncy International (TI) C orruption Perception Index 
(C PI) score  of the country is lowe r than 50 or the latest W orld Justice  
Proje ct (W JP) Rule of Law Index of the country is lowe r than 0,5. 

ii. The  country/region is k nown as a country with low le ve l of forest 
gove rnance and law e nforcement. 

iii. Tre e  species included in the m aterial/product is known as species with 
pre valence  of activities covere d by the te rm controversial sources (a) or (b) 
in the  country/region. 

iv. The  country is covered by UN, EU or national government sanctions 
re stricting the export/import of such forest and tre e based products 

Appe ndix 1, Table 3: List of indicators for significant risk at supply ch ain 
le ve l 

a) C ountries/re gions whe re the products have been traded are unknown.  

b) Spe cies in the product are unknown. 

c) Evide nce  of illegal practices concerning controversial sources by any 
com pany in the supply chain. 

A . 5.3.2 The 
Sche m e shall 
include  
re quirements that 
e nsure that 
whe ne ve r there is 
a change in the 
risk  re lated to 
ille gal harvest, 
trade  or transport 

PEFC  ST 2002: 2020 

3.7 C ontroversial source s 

Fore st and tre e based material source d from: 

a) Activitie s not complying with applicable local, national or international 
le gislation on forest management, including but not limited to forest 
m anagement practices; nature and e nvironmental protection; protected and 
e ndangered species; property, te nure and land-use rights for indigenous 
pe oples, local communities or other affected stakeholders; health, labour 
and safety issues; anticorruption and the payment of applicable royalties 

F i ndings 

C ove red 

Fore st management  

Fore st management re quirements do not 
include  a risk based approach to sourcing 
non-certified material. 

C hain of custody 

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in a supply chain – 
or a supply chain 
cove re d by a DDS 
– the  risk  shall be 
assessed and 
m itigated prior to 
shipping and sale. 

and taxes. 

6.1.4 The organisation shall only use PEFC  certified material and PEFC 
controlled sources m aterial  
as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, e xcept 
re cycle d m aterial, the organisation shall exercise due diligence in line with 
the  PEFC  Due Diligence System (DDS) for the avoidance  of material from 
controve rsial sources laid down in Appendix 1 of this standard. Thereby the 
organisation shall e stablish that for m aterial used as input for PEFC product 
groups there is “negligible risk” that it originates from controversial source s 
and that it m eets the  
de finition of PEFC controlled sources material. 

PEFC  ST 2002: 2020 - Appendix 1: PEFC Due Diligence System (DDS) for 
the  avoidance of m aterial from controversial sources 

3. R isk assessment 
3.1 The organisation shall carry out a risk assessment, assessing the risk of 
procuring raw m aterial 
from  controversial sources for all input forest and tree based m aterial 
cove re d by the 
organisation’s PEFC chain of custody, with the e xception of 
m ate rial/products delivere d with a  
PEFC  claim by a supplier with a PEFC re cognised ce rtificate, as this material 
can be  considered 
as having “negligible risk” of originating in controversial sources.  
3.2 The organisation’s risk assessment shall re sult in the classification of 
m ate rial into “negligible” or 
“significant” risk category. 
3.3 The organisation’s risk assessment shall be based on the indicators for 
risk  at origin and supply 
chain le vel listed in tables 1- 3 below. 
… 
3.7 The risk assessment shall be carried out for the first delivery of e very 

According to PEFC ST 2002: 2020 6.1.4, 
the  ce rtificate holder m ay choose to use 
controlled sources in their products. 
C ontrolled source s are defined by PEFC ST 
2002: 2020 3.28, as inputs into a due 
dilige nce system which are  concluded with 
ne gligible risk in re lation to the definition 
in the  standard of Controversial sources 
(PEFC  ST 2002: 2020 3.7). 

R e quirement 7.1.1 of PEFC ST 2002: 
2020, describes that the ce rtificate holder 
shall implement a Due Diligence System 
(DDS) whe n sourcing input material which 
is not PEFC-certified. The re quirements 
for due  diligence  are contained within 
Appe ndix 1 of standard (PEFC ST 2002: 
2020), the obje ctive of which is to ensure 
non-certified materials or products which 
are  source d by the C ertificate Holder do 
not de rive from controversial sources. The 
DDS in Appe ndix 1 is not expected to be 
applied to the C ertificate holder itself or to 
PEFC -ce rtified material.  

According to PEFC ST 2002: 2020, 
Appe ndix 1, 3.9, the risk assessment shall 
be  re vie we d at le ast annually, and whe n 
changes of characteristics (of the supply 
chain) are made. 

J ustification 

Not applicable to forest management. 

This indicator is concluded as covered for 
the  chain of custody. Whenever there  is a 

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A . 5.3.3 In cases 
whe re  othe r 3rd 
party schemes 
pe rm itted to be 
use d by the due 
dilige nce system 
as m eeting specific 
due  diligence 
re quirements, the 
sche me shall 
include  
re quirements that 
e nsure that it is 
cle ar: 
i) on what basis 
re cognition is 
m ade and;  
ii) how it is 
ve rifie d that other 
Sche m es e nsure 
conformance with 
the  specific due 
dilige nce 
re quirements. 

individual supplier, or for 
se ve ral suppliers, with the  same characteristics listed in 2.1 of this 
appendix, and the same 
applicability of indicators according to tables 1 -3 above. 
… 
3.9 The risk assessment shall be re viewe d and if necessary re vised at least 
annually, and whe n changes re garding the characteristics listed in 2.1 of this 
appendix occur. 

PEFC  ST 2002: 2020 

3.7 C ontroversial source s 

Fore st and tre e based material source d from: 

a) Activitie s not complying with applicable local, national or international 
le gislation on forest management, including but not limited to forest 
m anagement practices; nature and e nvironmental protection; protected and 
e ndangered species; property, te nure and land-use rights for indigenous 
pe oples, local communities or other affected stakeholders; health, labour 
and safety issues; anticorruption and the payment of applicable royalties 
and taxes. 

6.1.4 The organisation shall only use PEFC  certified material and PEFC 
controlled sources m aterial  
as input for PEFC product groups. 

7.1.1 For all material used as input for a PEFC product group, e xcept 
re cycle d m aterial, the organisation shall exercise due diligence in line with 
the  PEFC  Due Diligence System (DDS) for the avoidance  of material from 
controve rsial sources laid down in Appendix 1 of this standard. Thereby the 
organisation shall e stablish that for m aterial used as input for PEFC product 
groups there is “negligible risk” that it originates from controversial source s 
and that it m eets the  
de finition of PEFC controlled sources material. 

PEFC  ST 2002: 2020 - Appendix 1: PEFC Due Diligence System (DDS) for 
the  avoidance of m aterial from controversial sources 

3. R isk assessment 

421 

change in the risk re lated to illegal harvest, 
trade  or transport in a supply chain – or a 
supply chain covere d by a DDS – the risk 
shall be assessed and m itigated prior to 
shipping and sale. 

F i ndings 

Partially 
C ove red 

Fore st management re quirements do not 
include  a risk based approach to sourcing 
non-certified material. 

C hain of custody 

R e quirement 7.1.1 of PEFC ST 2002: 
2020, describes that the ce rtificate holder 
shall implement a Due Diligence System 
(DDS) whe n sourcing input material which 
is not PEFC-certified. The re quirements 
for due  diligence  are contained within 
Appe ndix 1 of standard (PEFC ST 2002: 
2020), the obje ctive of which is to ensure 
non-certified materials or products which 
are  source d by the C ertificate Holder do 
not de rive from controversial source s.  

The  risk assessment proce dures described 
in PEFC  ST 2002: 2020, Appendix 1, 
include  the use of indicators in tables. 
Table 1 re cognizes that supplies certified 
to othe r forest certification schemes can 
re sult in a negligible risk conclusion. It is 
not cle ar (no re quirements or guidance 
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… 

3.3 The organisation’s risk assessment shall be based on the indicators for 
risk  at origin and supply chain level listed in tables 1 - 3 below.  

3.4 W here the organisation’s risk assessment identifies indicators specified in 
table  1, the organisation may co nsider the material as having “negligible risk” 
to originate in controversial sources, and conclude the risk assessment without 
having to consider the indicators outlined in tables 2 and 3. 

Table 1: List of indicators for negligible risk 
Indicators 
a) Supplies declared as ce rtified against a forest ce rtification system (other 
than PEFC e ndorsed), addressing the activities covere d by the te rm 
controve rsial sources, supported by a fore st management, chain of custody or 
fibre  sourcing certificate issued by a third party ce rtification body. 
b) Supplies verified by governmental or non-governmental ve rification or 
lice nsing m echanisms other than forest ce rtification systems, addressing the 
activitie s covered by the term controversial sources. 

sche mes shall be evaluated by the 
ce rtificate holder other than that they 
cove r the  activities included in the term 
controve rsial sources and are covered by 
a supported by third-party ce rtification. It 
is e x pected that this is covere d in the 
audit process. 

Furthe rm ore, Table 1 (b) determines that 
supplies verified by governmental or non-
gove rnmental ve rification or licensing 
m e chanisms (other than fore st 
ce rtification systems) can be considered 
as low risk , as long as they address the 
activitie s covered by the term 
controve rsial sources. Howe ver, the 
de finition of “governmental or non-
gove rnmental ve rification or licensing 
m e chanisms” is not cle ar. Again, it is not 
cle ar (no requirements or guidance was 
found) on what basis – or how – the  
lice nsing m echanisms are to be 
e valuated.  

J ustification 

Not applicable to forest management. 

This indicator is concluded as partially 
cove re d for the chain of custody. The DDS 
de te rmines that supplies ve rified by 
gove rnmental or non-governmental 
ve rification or licensing m echanisms (other 
than forest ce rtification systems) can be 
considered as low risk , as long as they 
addre ss the activities covere d by the te rm 
controve rsial sources. Howe ver, there are no 

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A . 5.3.4 The 
Sche m e shall 
include  
re quirements to 
e nsure that the 
DDS com prises, at 
a m inimum, the 
following 
e le ments:  
i) a quality 
m anagement 
syste m,  
ii) proce dures for 
obtaining acce ss 
to information 
pe rtinent to the 
ide ntification of 
risk ; iii) risk 
assessments, and 
iv) the  
im plementation of 
m itigations 
m e asures whe n 
risk s are 
ide ntified. 

PEFC  ST 2002: 2020 
3.28 PEFC controlled sources 
Mate rial category covering forest and tre e based material for which an 
organisation has determined through its Due Diligence System that there  is 
“ne gligible risk” that the material is from controversial sources. 
3.7 C ontroversial source s 
Fore st and tre e based material source d from: 
a) Activitie s not complying with applicable local, national or international 
le gislation on forest management, including but not limited to forest 
m anagement practices; nature and e nvironmental protection; protected and 
e ndangered species; property, te nure and land-use rights for indigenous 
pe oples, local communities or other affected stakeholders; health, labour 
and safety issues; anticorruption and the p ayment of applicable royalties 
and taxes. 
b) Activitie s whe re the capability of forests to produce a range of wood and 
non-wood forest products and services on a sustainable basis is not 
m aintained or harvesting le vels e xceed a rate that can be sustained in the 
long te rm. 
c) Activitie s whe re  forest management does not contribute to the 
m aintenance , conservation or e nhancement of biodiversity on landscape, 
e cosystem, species or genetic le vels. 
d) Activitie s whe re ecologically important forest areas are not identified, 
prote cte d, conserved or set aside. 
e ) Activitie s whe re forest conversions occur, in other than justified 
circum stances whe re  the conversion: 
i. is in com pliance with national and regional policy and legislation applicable 
for land use and forest management, and 
ii. doe s not have negative impacts on ecologically important forest areas, 

423 

re quirements or guidance on what basis – or 
how - the  schemes shall be evaluated by the 
ce rtificate holder other than that they cover 
the  activities included in the term 
controve rsial sources and are covered by a 
supported by third-party ce rtification. It is 
e x pected that this is covered in the audit 
proce ss. 

F i ndings 

C hain of custody 

Partially 
C ove red 

According to PEFC ST 2002: 2020 6.1.4, 
the  chain of custody ce rtificate holder 
m ay choose to use controlled sources in 
the ir products. Controlled sources are 
de fined by PEFC ST 2002: 2020 3.28, as 
inputs into a due diligence  system which 
are  concluded with ne gligible risk in 
re lation to the definition in the standard 
of C ontroversial sources (PEFC  ST 2002: 
2020 3.7). 

W he re products which are sourced by the 
C e rtificate Holder are PEFC ce rtified, the 
ce rtificate holder has the option to 
im plement a Due Diligence  System based 
on re quirement 7.1.2 of the m ain 
standard PEFC ST 2002: 2020. 
R e quirement 7.1.2 is not mandatory and 
Anne x 1 of the standard is not applicable 
in such cases. O n this point it is important 
to note  that the assessed standard is not 
use d yet and during the discussion with 
PEFC , they e xplain that 7.1.2 should be 
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culturally and  
socially significant areas, or other protected areas, and  
iii. doe s not destroy are as of significantly high carbon stock, and 
iv. m akes a contribution to long-term conservation, economic, and/or social 
be nefits. 
f) Activitie s whe re the spirit of the ILO De claration on Fundamental 
Principles and Rights at Work  (1998) is not met. 
g) Activitie s whe re the spirit of the United Nations Declaration on the R i ghts 
of Indigenous Peoples (2007) is not met. 
h) C onflict timber. 
i) Ge ne tically modified trees. 
6.1.4 The organisation shall only use PEFC  certified material and PEFC 
controlled sources m aterial as input for PEFC product groups. 
7.1.1 For all material used as input for a PEFC product group, e xcept 
re cycle d m aterial, the organisation shall exercise due diligence in line with 
the  PEFC  Due Diligence System (DDS) for the avoidance  of material from 
controve rsial sources laid down in Appendix 1 of this standard. Thereby the 
organisation shall e stablish that for m aterial used as input for PEFC product 
groups there is “negligible risk” that it originates from controversial source s 
and that it m eets the definition of PEFC controlled sources material.  
7.1.2 For PEFC  product groups whe re only input material used was delivered 
with a PEFC  claim by a supplier covere d by a PEFC recognised ce rtificate, an 
organisation may implement the PEFC DDS by meeting the following 
re quirements: 
a) In order to e nable PEFC certified and uncertified entities further down the 
supply chain to implement a DDS, the organisation shall, upon re quest, 
provide the information specified in Appendix 1, 2.1 for material passed on 
with a PEFC  claim. If the organisation does not possess the requested 
inform ation, the re quest shall be passed on to relevant supplier(s) of the 
organisation (Appendix 1, 2.2). 
b) W here  internal or e xternal substantiated concerns on the origin of input 
m ate rial from controversial sources are raised, the organisation shall follow 
up on these concerns following Appendix 1, 4. 
c) The  organisation shall define, document and implement a commitment 
and a procedure, also covering forest and tre e based material/products not 
cove re d by the organisation’s PEFC  
chain of custody, ensuring that whe re  it is k nown to the organisation, or 

doe s not specific this.  At the  same time, 
PEFC  e xplained that PEFC C oC Working 
Group is observing the use of the chain of 
custody standards and continuously 
e valuating the feedback re ceived from 
ce rtificate holders, ce rtification bodies and 
accre ditation bodies. If necessary, a 
guidance document for the PEFC ST 
2002:2020 ve rsion will be  developed. This 
guidance would not add additional 
re quirements but adds e xplanation, 
clarification, and interpretation whe re  
ne ce ssary. 

C ontrolled Source s for non-PEFC-certified 
m ate rial  

R e quirement 7.1.1 of PEFC ST 2002: 
2020, describes that the ce rtificate holder 
shall implement a Due Diligence System 
(DDS) whe n sourcing input material which 
is not PEFC-certified. The re quirements 
for due  diligence  are contained within 
Appe ndix 1 of standard (PEFC ST 2002: 
2020), the obje ctive of which is to ensure 
non-certified materials or products which 
are  source d by the C ertificate Holder do 
not de rive from controversial source s. For 
e ntitie s applying this Due Diligence 
Syste m , PEFC ST 2002: 2020 Appendix 1, 
re quirements 4.1, 4.2 and section 6 apply 
in case  of substantiated concerns. The 
ce rtificate holder shall not place products 
on the  mark et for which substantiated 
conce rns have not been re solved. 

R e quirement 6.2 also re quires that wood 

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whe re  it has re ceived substantiated conce rns, that forest and tre e based 
m ate rial/products originates in illegal sources (controversial source s, 3.7a), 
it shall not be placed on the m arket until the concern has been re solved in 
accordance with Appendix 1, 4. 

PEFC  ST 2002: 2020 - Appendix 1 
1.1 In order to help ensure  that activities conducted by the organisation 
unde r the scope of this standard conform to all applicable timber legality 
le gislation, including trade and customs laws, and to minimise the risk that 
the  procured m aterial originates in controversial source s, the organisation 
shall operate a Due Diligence System (DDS), in accordance with the  
following elements of this standard. 
3.4 W here the organisation’s risk assessment identifies indicators specified 
in table 1, the organisation may consider the material as having “negligible 
risk ” to originate in controversial sources, and conclude the risk assessment 
without having to consider the indicators  outlined in tables 2 and 3. 
3.5 W here the organisation’s risk assessment does not identify indicators 
spe cified in table 1, the risk assessment shall be continued ag  

3.6 W here none of the indicators outlined in tables 2 and 3 are identified, 
the  organisation may consider the supplies as having “negligible risk” to 
originate in controversial source s, and conclude the risk assessment.  
Appe ndix 1, Table 1: List of indicators for ne gligible risk 
a) Supplies declared as ce rtified against a forest ce rtification system (other 
than PEFC e ndorsed),  
addre ssing the activities covered by the term controversial source s, 
supported by a forest management, 
chain of custody or fibre sourcing ce rtificate issued by a third party 
ce rtification body. 
b) Supplies verified by g overnmental or non-governmental ve rification or 
lice nsing m echanisms other than forest ce rtification systems, addressing the 
activitie s covered by the term controversial sources.  
c) Supplies supported by ve rifiable documentation that clearly identifies:  
i. country of harvest and/or sub-national re gion whe re the timber was 
harve sted, whe re  the latest  
Transparency International (TI) C orruption Perce ption Index (CPI) score is 
highe r than 50, or whe re  

originated from illegal source s should not 
be  placed on the market. 

C ontrolled Source s due diligence 
m e chanism 

The  due diligence re quirements outlined 
in Appe ndix 1 of PEFC ST 2002: 2020 are 
inte nded to e nsure non-certified materials 
or products which are sourced by the 
C e rtificate Holder do not derive from 
controve rsial sources  

According to Appendix 1 (3.4) sources can 
be  considere d having “negligible risk” 
whe re  the  organisation can meet the 
re quirements of Table 1. In such cases, it 
is not re quired to proceed to Tables 2 and 
3 in the  risk assessment. According to 
Appe ndix 1, 3.6, sources can be 
considered having “negligible risk” whe re 
none  of the indicators outlined in tables 2 
and 3 is identified.   

It is not cle ar that the DDS would be able 
to de te ct all risks within supply chains in 
line  with the  definition of negligible and 
non-negligible risk as outlined in the EUTR 
and prohibition of illegal material or 
m ate rial with a non-negligible risk 
cate gory. As examples, the following 
issues are observe d:  

1.  The re  is no clear definition of the 

te rm  ‘significant risk’. 

2.  Table 1, point c) of the table 

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the  latest World Justice Project (WJP) R ule of Law Index is higher than 0,5, 
and 
ii. trade  name and type of product as we ll as the common name of tree 
spe cies and, whe re applicable, 
its full scientific name, and 
iii. all suppliers within the supply chain, and 
iv. the  forest area of the supply origin, and 
v. docum ents, including contractual agre ements and self-declarations, or 
othe r re liable information 
indicating that products do not originate from controversial source s. 

Appe ndix 1, Table 2: List of indicators for significant risk at origin level 
a) Activitie s not complying with applicable local, national or international 
le gislation on forest management, including but not limited to forest 
m anagement practices; nature and e nvironmental protection; protected and 
e ndangered species; property, te nure and land-use rights for indigenous 
pe oples, local communities or other affected stakeholders; health, labour 
and safety issues; anti-corruption and the payment of applicable royalties 
and taxes. 
i. The  latest Transpare ncy International (TI) C orruption Perception Index 
(C PI) score  of the country is lowe r than 50 or the latest W orld Justice  
Proje ct (W JP) Rule of Law Index of the country is lowe r than 0,5. 
ii. The  country/region is k nown as a country with low le ve l of forest 
gove rnance and law e nforcement. 
iii. Tre e  species included in the m aterial/product is known as species with 
pre valence  of activities covere d by the te rm controversial sources (a) or (b) 
in the  country/region. 
iv. The  country is covered by UN, EU or national government sanctions 
re stricting the export/import of such forest and tre e based products 

6.1 Fore st and tre e based material/products from unknown source s or from 
controve rsial sources shall not be included in a PEFC product group. 

considers as negligible risk wood 
com ing from sources with 
“documents, including contractual 
agreements and self-declarations, or 
other reliable information indicating 
that products do not originate from 
controversial sources”. Scenarios 
m ay e xist that allow for wood 
source s to be considered as 
ne gligible risk even though risks 
e x ist. E.g. in re lation to te nure rights. 
It is not always possible to ascertain 
a risk  conclusion from such 
docum ents, or e ven from documents 
alone. 

3.  A low risk  conclusion may be possible 
in som e cases whe re this may not be 
warrante d. For e xample: 

 

Table 2 a) I-IV, could help 
conclude as negligible risk 
wood supply coming from 
countrie s whe re the C PI is 
highe r than 50. Other 
tim be r legality databases 
and indices have observed 
cle ar ille gality risks arising 
in countries with a CPI 
above 50. An alternative 
database that is cited 
include s the W orld Justice  
Proje ct (W JP) Rule of Law 
Inde x. Again, countries with 
a score  lowe r than 0,5 may 
also contain illegality risks. 
Ex am ples include India and 

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 

Thailand, both with a score 
of 0.51. PEFC includes a 
note  that “These indices 
m ight not always be 
appropriate for fore stry. 
W he re m ore appropriate 
indicators exist, these can 
be  used with a prior 
agre ement with the  PEFC 
C ouncil. These alternative 
indicators will be listed in 
the  chain of custody 
guidance document”. 

Table 3 (List of indicators for 
significant risk at supply 
chain le vel) includes in c) as 
a significant risk indicator, 
e vide nce of illegal practices 
conce rning controversial 
source s by any company in 
the  supply chain. Howe ver, 
again, the definition of 
controve rsial sources only 
applies to applicable local, 
national or international 
le gislation on forest 
m anagement and does not 
m ak e reference  to the trade 
and transport laws. So there 
is no re quirement to 
consider a supply-chain 
e ntity that had been 
sanctioned for illegal trading 
of wood-products, for 
e x ample. 

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J ustification 

This indicator is concluded as partially 
cove re d. C ases in relation to the risk 
assessment tables in Appendix 1 mean 
that risk s may not always be captured. 

B. Requirements for Certification Bodies 

Sche m e re quirements for Certification Bodies shall be clear and unambiguous and allow the  Scheme  owne r to ve rify the level o f conformance of e ach C ertification Body to these 
re quirements. 

B.1 General Certification Body requirements 

B.1.1 

C om petenc
e  and 
qualificatio
ns 

B . 1.1.1 The 
Sche m e shall have 
m e chanisms to 
e nsure that 
auditors, and 
othe r re levant 
pe rsonnel of the 
C e rtification Body, 
are  qualified and 
com petent to 
e valuate 
organisations’ 
com pliance with 
spe cific Scheme 
re quirements. 

C e rtification and Accre ditation procedure s, 2007 – Annex 6  
C hapter 4 C ERTIFICATION PROCEDURES 
The  ce rtification body shall have established internal procedures for fore st 
m anagement ce rtification against a national forest ce rtification scheme and 
for chain of custody certification against Annex 4 (Chain of Custody of Forest 
Base d Products – Requirements) or against a scheme specific chain of 
custody standard. 
The  applied ce rtification proce dures for forest m anagement ce rtification or 
chain of custody ce rtification against a scheme specific chain of custody 
standard shall fulfil or be compatible with the re quirements defined in any of 
the  following documents: 
a) ISO  17021(1) if the ce rtification is carried out as management system 
ce rtification, 
b) ISO  Guide 65 (EN 45 011)(2) if the ce rtification is carried out as product 
ce rtification (the term “product” is used in its wide st sense and includes also 
proce sses and services )(2), 
The  applied ce rtification proce dures for chain of custody certification against 
Anne x 4 (Chain of Custody of Fore st Based Products – R equirements) shall 
fulfill re quirements defined in ISO Guide 65 (EN 45 011)(2). The applied 
auditing procedure s shall fulfill or be compatible with the  requirements of 
ISO  19011(3). 
In addition to above requirements the certification body: 

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F i ndings 

C ove red 

Fore st management 
According to Certification and 
Accre ditation procedure s, Annex 6 2007 – 
C hapter 3.2, auditors should fulfil ISO 
19011 (defines qualification and 
com petence  for auditors). In addition, 
according to Annex 6 – C ertification and 
Accre ditation procedure s, 2007 – C hapter 
4, ISO  17021 is re quested to be 
im plemented by the Certified Body. 

C hain of C ustody 
For C e rtification Bodies operating chain of 
custody (PEFC ST 2003:2020, 6.1.1.2), 
auditors should have specific e ducation 
(PEFC  ST 2003:2020, 6.1.1.2.1), 
com petence  (PEFC ST 2003:2020, 
6.1.1.2.6) and work  experience (PEFC ST 
2003:2020, 6.1.1.2.2) for conducting 
audits. Indicator 6.1.1.2.4 re quests 

 
 
 
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a) informs the relevant PEFC National Governing Bodies about all issued 
fore st management and chain of custody ce rtificates and changes 
conce rning validity and scope of these certificates, 
… 
C om pliance of the ce rtification body’s procedures with the  above 
re quirements shall be ve rified by accre ditation according to chapter 5.  

– C hapter 3.2 C ertification bodies have the re sponsibility to use competent 
auditors that have adequate te chnical k now-how on the ce rtification proce ss 
and issues related to forest m anagement or chain of custody certification, 
re spe ctively. 
The  auditors shall fulfil general crite ria for quality and environmental 
m anagement systems auditors as defined in ISO 19011(3). 
Additional qualification re quirements for auditors carrying out forest 
m anagement or chain of custody audits against a scheme specific standard 
should be defined by the re spective national forest certification scheme. 
The  ce rtification body can fulfil the technical competence  defined for 
auditors by the presence of a te chnica l e xpert(s) in a group of auditors 
carrying out forest m anagement or chain of custody audits. 
The  compliance of auditors with the above requirements is verified by an 
accre ditation as described in chapter 5. 

auditors to have successfully completed 
training in audit techniques based on ISO 
19011.  

J ustification 

This indicator is concluded as covered for 
fore st management and chain of custody. 
For fore st management, auditors and other 
re le vant personnel of the Certification Body, 
are  qualified and competent to evaluate 
organisations’ compliance  with specific 
Sche m e re quirements is indire ctly (through 
ISO  standards) addre ssed in the normative 
re quirement. For Chain of custody, auditors 
and other re levant personnel of the 
C e rtification Body, are qualified and 
com petent to evaluate organisations’ 
com pliance with specific Scheme 
re quirements is directly addressed in the 
norm ative re quirement. 

PEFC  ST 2003: 2020 

6.1.1.1 Personnel involved in the certification activities  
6.1.1.1.1 The ce rtification body shall ensure  that all personnel carrying out 
the  k e y activities, such as contract re view, auditing, granting of ce rtification, 
m onitoring of auditors, e tc. have the re levant and appropriate k nowle dge 
and competencies corre sponding to these activities. 

6.1.1.2 Auditors 
The  ce rtification body shall have a documented process to e nsure  that 
auditors have personal attributes, knowle dge and skills in accordance with 
clauses 7.1, 7.2.1, 7.2.2, 7.2.3.1, 7.2.3.2 and 7.2.3.4 of ISO 19011:2018. 

6.1.1.2.1 Education 
6.1.1.2.1.1 The ce rtification body shall ensure  that auditors have the 

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k nowle dge corre sponding to at least a secondary education that includes or 
is supplemented with courses re lated to forest and/or tre e based and re lated 
industries whe re the auditor(s) conducts chain of custody audits. 
Note : Se condary e ducation is the part of the national e ducation system that 
com e s after the primary or e lementary stage, but that is completed prior to 
e ntrance to tertiary e ducation, e .g. university or similar e ducational 
institution. 
6.1.1.2.1.2 The specific e ducation re lating to fore st and/or tre e based and 
re late d industries can be substituted by work ing experience in these sectors 
if the  ce rtification body can demonstrate it is e quivalent to the re quired 
e ducation. 
Note : Fore st and/or tre e based and related industries include, for e xample, 
activitie s re lating to manufacturing, re search, e ducation, standards 
de ve lopment, forest industry/product associations, fore st law and 
re gulation, transport, distribution and re cycling or transport and storage of 
fore st and/or tre e based products. 

6.1.1.2.2 W orking e xperience 
6.1.1.2.2.1 For a first qualification of an auditor, the ce rtification body shall 
e nsure that the auditor has a minimum of three years of full-time re lated 
work ing e xperience in the forest and/or tre e based and re lated industries. 
Note : Fore st and/or tre e based and related industries include, for e xample, 
activitie s re lating to manufacturing, re search, e ducation, standards 
de ve lopment, forest industry/product associations, fore st law and 
re gulation, transport, distribution and re cycling or transport and storage of 
fore st and tre e based products. 
6.1.1.2.2.2 The number of years of total work  experience may be re duced 
by one  year, if the auditor has completed a te rtiary e ducation appropriate 
and re levant to forest and/or tre e based and re lated industries. 
Note : Te rtiary education, also re ferre d to as third stage, third level, and 
post-secondary e ducation, is the e ducational le vel following the completion 
of a school providing a secondary education. 
6.1.1.2.2.3 The number of years of total work  experience may be re duced 
by one  year if the auditor has performed, as auditor-in-training, four chain 
of custody a udits under the le adership of a qualified auditor, in addition to 
the  chain of custody audits re quired as audit experience under 6.1.1.2.5.1.  
6.1.1.2.3 PEFC chain of custody training  

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The  ce rtification body shall e nsure  that new auditors have re ceived initial 
training on the PEFC system and the C hain of C ustody standard, that is 
re cognised by the PEFC C ouncil. 
Note : The PEFC  we bsite www.pe fc.org provides further information on 
training options. 
6.1.1.2.4 Audit training 
The  ce rtification body shall e nsure  tha t auditors have successfully completed 
training in audit techniques based on ISO 19011. 
6.1.1.2.5 Audit experience 
6.1.1.2.5.1 For a first qualification of an auditor, the ce rtification body shall 
e nsure that the auditor within the last thre e years has performed, as 
auditor-in-training, chain of custody audits for at le ast four organisations 
unde r the leadership of a qualified auditor, including at le ast two PEFC chain 
of custody audits. The number of chain of custody audits -in-training can be 
re duce d to two PEFC chain of custody audits for auditors that are qualified 
for chain of custody standards, ISO 9001 or ISO 14001 in forest and/or tre e 
re late d sectors. 

6.1.1.2.6 C ompetencies 
6.1.1.2.6.1 The ce rtification body shall ensure  that auditors demonstrate 
ability to apply k nowle dge and skills in the following areas:  
a) The  obje ctives and core processes of the PEFC system including the 
re quirements from the PEFC Sustainable Forest Management standard (PEFC 
ST 1003) covered in the PEFC  chain of custody definition of controversial 
source s, (PEFC ST 2002, clause 3.6 paragraphs b, c, d and e). 
b) Audit principles, procedures and techniques (see 7.2.3.2.a of ISO 
19011:2018): to e nable the auditor to apply those appropriate to different 
audits and ensure that audits are  conducted in a consistent and systematic 
m anner. 
c) O rganisation situations (see 7.2.3.2.c of ISO 19011:2018), including 
organisational size, structure, functions and re lationships, general business 
proce sses and re lated terminology, and cultural and social customs such as 
k nowle dge of the clie nt organisation work ing language, or language that the 
ce rtification body and client can agree on: to e nable the auditor to 
com prehend the organisation’s operational context. 
d) Applicable international legislation and country specific fore st governance  
and law e nforce ment system re levant to forest and tre e based raw m aterial 

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procure ment and avoidance of raw m aterial from controversial sources: to 
e nable the auditor to compre hend the client organisation’s contractual 
re lationships with suppliers and evaluate the client organisation’s procedures 
for avoidance of raw m aterial from controversial source s. Knowle dge and 
unde rstanding of this are a shall cover: 
i. contracts and agreements, including labour contracts and or collective 
bargaining agreements 
ii. fore st governance and law e nforcement system of countries of the 
unce rtified raw m aterial origin, including those covering social, health and 
safe ty issues of work ers 
iii. inte rnational conventions re lating to work er rights (ILO core conventions) 
iv. inte rnational tre aties and conventions re lating to the trade of forest and 
tre e  based products PEFC  

6.1.1.2.6.2 The ce rtification body shall ensure  that auditors demonstrate 
ability to apply te rminology, knowle dge, understanding and skills in the 
following areas of the PEFC chain of custody: 
a) principles and re quirements of the C hain of C ustody standard (PEFC ST 
2002) 
b) products (including non-wood forest products and products from recycled 
m ate rial), processes and practice s in the specific sector, applied raw 
m ate rial flow, m easurements and control m easures  
c) the  application of m anagement systems to fore st and tree based and 
re late d industries and interaction betwe en their components 
d) information systems and technology for authorisation, security, 
distribution and control of documents, data and re cords 
e ) application of PEFC trademarks and other product labels and claims  
f) application of the measure s to avoid procurement of raw m aterial from 
controve rsial sources, including the re levant risk assessment methodology 
and indicators 
g) social, health and safety re quirements 
6.1.1.2.6.3 The ce rtification body shall maintain e vidence of annual 
m onitoring of chain of custody auditors, applying methods such as re viewing 
audit re ports or clie nt organisations’ feedback, etc. based on the frequency 
of the ir usage and the le vel of risk linked to their activities, and periodic 
witne ss audits. In particular, the ce rtification body shall review the  
com petence  of its personnel in the light of their performance in order to 

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B . 1.1.2 If the 
Sche m e includes 
an option for the 
C e rtificate Holder 
to im plement a 
Due  Diligence 
Syste m , the 
sche me shall 
e nsure that the 
auditors and other 
re le vant personnel 
of the  C ertification 
Body are  qualified 
and competent to 
e valuate 
organisations’ 
com pliance with 
re late d Scheme 
re quirements. 

ide ntify training needs. 

PEFC  ST 2003: 2020 

F i ndings 

C ove red 

C hapter 4 C ERTIFICATION PROCEDURES 
The  ce rtification body shall have established internal procedures for fore st 
m anagement ce rtification against a national forest ce rtification scheme and 
for chain of custody certification against Annex 4 (Chain of Custody of Forest 
Base d Products – Requirements) or against a scheme specific chain of 
custody standard. 
The  applied ce rtification proce dures for forest m anagement ce rtification or 
chain of custody ce rtification against a scheme specific chain of custody 
standard shall fulfil or be compatible with the re quirements defined in any of 
the  following documents: 
a) ISO  17021(1) if the ce rtification is carried out as management system 
ce rtification, 
b) ISO  Guide 65 (EN 45 011)(2) if the ce rtification is carried out as product 
ce rtification (the term “product” is used in its wide st sense and includes also 
proce sses and services )(2), 
The  applied ce rtification proce dures for chain of custody certification against 
Anne x 4 (Chain of Custody of Fore st Based Products – R equirements) shall 
fulfill re quirements defined in ISO Guide 65 (EN 45 011)(2). The applied 
auditing procedure s shall fulfill or be compatible with the  requirements of 
ISO  19011(3). 

PEFC  ST 2003: 2020  
6.1.1.2.4 Audit training 
The  ce rtification body shall e nsure  that auditors have successfully completed 
training in audit techniques based on ISO 19011. 

6.1.1.2.6 C ompetencies 
6.1.1.2.6.1 The ce rtification body shall ensure  that auditors demonstrate 
ability to apply k nowle dge and skills in the following areas: 
a) The  obje ctives and core processes of the PEFC system including the 
re quirements from the PEFC Sustainable Forest Management standard (PEFC 
ST 1003) covered in the PEFC  chain of custody definition of controversial 

Fore st management 
PEFC  Fore st management requirements 
do not include a risk based approach to 
sourcing non-certified material. 

C hain of custody 
According to PEFC ST 2003: 2020, 
6.1.1.2.6.1 d) auditors shall demonstrate 
k nowle dge related to international 
le gislation and country specific forest 
gove rnance and law e nforcement. At the 
sam e time, indicator 6.1.1.2.4 re quests 
auditors to have successfully completed 
training in audit techniques based on ISO 
19011. Although a ‘due diligence ’ 
qualification is not specifically described, 
it is considere d this would be covered 
be cause auditors are re quired to evaluate 
the  clie nt organisation’s procedures for 
avoidance of raw m aterial from 
controve rsial sources, including  risk 
assessment, fore st governance  and law 
e nforcement systems. 

J ustification 

This indicator is concluded as covered. 
Auditors qualifications re lated to the Due 
dilige nce are addressed directly and 
indire ctly in the normative re quirement. 

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source s, (PEFC ST 2002, clause 3.6 paragraphs b, c, d and e). 
… 
d) Applicable international legislation and country specific fore st governance  
and law e nforce ment system re levant to forest and tre e based raw m aterial 
procure ment and avoidance of raw m aterial from controversial sources: to 
e nable the auditor to compre hend the client organisation’s contractual 
re lationships with suppliers and evaluate the client organisation’s procedures 
for avoidance of raw m aterial from controversial source s. Knowle dge and 
unde rstanding of this are a shall cover: 
i. contracts and agreements, including labour contracts and or collective 
bargaining agreements 
ii. fore st governance and law e nforcement system of countries of the 
unce rtified raw m aterial origin, including those covering social, health and 
safe ty issues of work ers 
iii. inte rnational conventions re lating to work er rights (ILO core conventions) 
iv. inte rnational tre aties and conventions re lating to the trade of forest and 
tre e  based products PEFC  

6.1.1.2.6.2 The ce rtification body shall ensure  that auditors demonstrate 
ability to apply te rminology, knowle dge, understanding and skills in the 
following areas of the PEFC chain of custody: 
… 
f) application of the measure s to avoid procurement of raw m aterial from 
controve rsial sources, including the re levant risk assessment methodology 
and indicators 
g) social, health and safety re quirements 

C e rtification and Accre ditation procedure s, 2007 – Annex 6, 
C hapter 3.2 Certification bodies have the re sponsibility to use competent 
auditors that have adequate te chnical k now-how on the ce rtification proce ss 
and issues related to forest m anagement or chain of custody certification, 
re spe ctively. 
The  auditors shall fulfil general crite ria for quality and environmental 
m anagement systems auditors as defined in ISO 19 011(3). 
Additional qualification re quirements for auditors carrying out forest 
m anagement or chain of custody audits against a scheme specific standard 
should be defined by the re spective national forest certification scheme. 
The  ce rtification body can fulfil the technical competence  defined for 

434 

B.1.2 

Im partialit
y 

B . 1.2.1 The 
sche me shall 
include  
re quirements to 
e nsure that 
auditors, and 
othe r personnel 
re le vant to the 
conformance 
e valuation of an 
organisation shall 

F i ndings 

C ove red 

Fore st management 
According to Certification and 
Accre ditation procedure s, Annex 6 2007 – 
C hapter 3.2 auditors should fulfil ISO 
19011 (defines qualification and 
com petence  for auditors). In addition, 
according to Annex 6 – C ertification and 
Accre ditation procedure s, 2007 – C hapter 
4, ISO  17021 is re quested to be 

 
 
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be  im partial to the 
e ntity(-ies) under 
e valuation. 

auditors by the presence of a te chnical e xpert(s) in a group of auditors 
carrying out forest m anagement or chain of custod y audits. 
The  compliance of auditors with the above requirements is verified by an 
accre ditation as described in chapter 5. 

C hapter 4 C ERTIFICATION PROCEDURES 
The  ce rtification body shall have established internal procedures for fore st 
m anagement ce rtification against a national forest ce rtification scheme and 
for chain of custody certification against Annex 4 (Chain of Custody of Forest 
Base d Products – Requirements) or against a scheme specific chain of 
custody standard. 
The  applied ce rtification proce dures for forest m anagement ce rtification or 
chain of custody ce rtification against a scheme specific chain of custody 
standard shall fulfil or be compatible with the re quirements defined in any of 
the  following documents: 
a) ISO  17021(1) if the ce rtification is carried out as management system 
ce rtification, 
b) ISO  Guide 65 (EN 45 011)(2) if the ce rtification is carried out as product 
ce rtification (the term “product” is used in its wide st sense and includes also 
proce sses and services )(2), 
The  applied ce rtification proce dures for chain of custody certification against 
Anne x 4 (Chain of Custody of Fore st Based Products – R equirements) shall 
fulfill re quirements defined in ISO Guide 65 (EN 45 011)(2). The applied 
auditing procedure s shall fulfill or be compatible with the  requirements of 
ISO  19011(3). 

PEFC  ST 2003: 2020,  
6.1.1.2.4 Audit training 
The  ce rtification body shall e nsure  that auditors have successfully completed 
training in audit techniques based on ISO 19011. 

im plemented by the Certified Body. ISO 
19011 includes re quirements to ensure  
that auditors, and other personnel 
re le vant to the conformance  evaluation of 
an organisation shall be impartial to the 
e ntity(-ies) under evaluation. 

C hain of custody 
For C e rtification Bodies operating chain of 
custody, auditors should have successfully 
com pleted training in audit techniques 
based on ISO 19011 (PEFC ST 2003: 
2020, 6,1,1,2,4). ISO 19011 includes 
re quirements to e nsure that auditors, and 
othe r personnel re levant to the 
conformance evaluation of an 
organisation shall be impartial to the 
e ntity(-ies) under evaluation.  

J ustification 

This indicator is concluded as covered for 
fore st management and chain of custody. 
The  impartiality of auditors is dire ctly (in  
chain of custody) and indire ctly (in forest 
m anagement through ISO 19011 and ISO 
17021) addre ssed in the normative 
re quirement. 

B . 1.2.2 The 
Sche m e shall 
include  
re quirements that 
e nsure that the 
ce rtification 
de cision process 

Anne x 6 – C ertification and Accre ditation procedures, 2007 – Chapter 4 
C ER TIFICATION PROCEDURES 
The  ce rtification body shall have established internal procedures for fore st 
m anagement ce rtification against a national forest ce rtification scheme and 
for chain of custody certification against Annex 4 (Chain of Custody of Forest 
Base d Products – Requirements) or against a scheme specific chain of 
custody standard. The applied ce rtification procedures for forest 

F i ndings 

C ove red 

Fore st management 

According to Certification and 
Accre ditation procedure s, Annex 6 2007 – 
C hapter 3.2, auditors should fulfil ISO 

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is;  
i) we ll de fined 
and; 
ii) e nsure s that 
the  de cision on 
ce rtification is 
conducted by 
positions/bodies 
that are  impartial 
to the  auditee. 

m anagement ce rtification or chain of custody ce rtification against a scheme 
spe cific chain of custody standard shall fulfil or be compatible with the 
re quirements defined in any of the following documents: 
a) ISO  17021(1) if the ce rtification is carried out as management system 
ce rtification, 
b) ISO  Guide 65 (EN 45 011)(2) if the ce rtification is carried out as product 
ce rtification (the term “product” is used in its wide st sense and includes also 
proce sses and services )(2), The applied ce rtification proce dures for chain of 
custody ce rtification against Annex 4 (Chain of C ustody of Forest Based 
Products – R equirements) shall fulfill re quirements defined in ISO Guide 65 
(EN 45 011)(2). The applied auditing procedure s shall fulfill or be compatible 
with the  re quirements of ISO 19011(3).  
… 

PEFC  ST 2003:2020, C hapter 7.6 All the re quirements given in clause 7.6 of 
ISO /IEC 17065:2012(E) apply. 
7.6.1 Audit findings shall be classified as major nonconformities, minor 
nonconformities 
and observations. 
7.6.2 Be fore granting initial ce rtification, as a minimum, m ajor and minor 
nonconformities shall be 
corre cte d and the corrective action(s) verified by the ce rtification body. 
7.6.3 Be fore granting re certification, as a m inimum, major nonconformities 
shall be corrected and the 
corre ctive  action(s) verified by the ce rtification body. 
7.6.4 Major and minor nonconformities identified in the audits shall result in 
corre ctive  action(s) 
by the  clie nt organisation re solving the nonconformities. The corrective 
action plan, including a  
tim e frame, shall be reviewe d and accepted by the ce rtification body. The 
tim e  period for completion of the corrective action(s) for m ajor 
nonconformities identified in s urveillance audits and their ve rification by the 
ce rtification body shall follow the  rules of the certification body but not 
e x ce ed three months. Corrective action(s) for minor nonconformities 
ide ntified during re certification and surveillance audits shall be verified no 
late r than during the next audit. 

19011 (defines qualification and 
com petence  for auditors). In addition, 
according to Annex 6 – C ertification and 
Accre ditation procedure s, 2007 – C hapter 
4, ISO  17021 is re quested to be 
im plemented by the Certified Body. ISO 
19011 and ISO 17021 includes 
re quirements to e nsure the certification 
de cision process is we ll defined and 
e nsures that the decision on certification 
is conducted by positions/bodies that are 
im partial to the auditee. 

C hain of custody 
For C e rtification Bodies operating chain of 
custody, auditors should have successfully 
com pleted training in audit techniques 
based on ISO 19011 (PEFC ST 2003: 
2020, 6,1,1,2,4). ISO 19011 includes 
re quirements to e nsure the certification 
de cision process is we ll defined and 
e nsures that the decision on certification 
is conducted by positions/bodies that are 
im partial to the auditee. In addition, 
according to Chapter 7.6, certification 
de cision should be based on audit 
findings, and in case of initial ce rtification 
and re certification, all non-conformities 
should be closed by the ce rtificate holder, 
prior to the  issue of the certificate.  

J ustification 

This indicator is concluded as covered for 
fore st management and chain of custody. 
The  impartiality of auditors is dire ctly (in 
chain of custody) and indire ctly (in forest 

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B.2 Certification Body requirements for auditing and certification 

B.2.1 

Auditing 
proce ss 

B . 2.1.1 The 
Sche m e shall 
include  
re quirements that 
e nsure that 
C e rtification 
Bodie s apply a 
docum ented 
m e thodology for 
the  e valuation 
(assessments and 
audits) of clients.  

C e rtification and Accre ditation procedure s, Annex 6 2007 
C hapter 4 C ERTIFICATION PROCEDURES 
The  ce rtification body shall have established internal procedures for fore st 
m anagement ce rtification against a national forest ce rtification scheme and 
for chain of custody certification against Annex 4 (Chain of Custody of Forest 
Base d Products – Requirements) or against a scheme specific chain of 
custody standard. 
The  applied ce rtification proce dures for forest m anagement ce rtification or 
chain of custody ce rtification against a scheme specific chain of custody 
standard shall fulfil or be compatible with the re quirements defined in any of 
the  following documents: 
a) ISO  17021(1) if the ce rtification is carried out as management system 
ce rtification, 
b) ISO  Guide 65 (EN 45 011)(2) if the ce rtification is carried out as product 
ce rtification (the term “product” is used in its wide st sense and includes also 
proce sses and services )(2), 
The  applied ce rtification proce dures for chain of custody certification against 
Anne x 4 (Chain of Custody of Fore st Based Products – R equirements) shall 
fulfill re quirements defined in ISO Guide 65 (EN 45 011)(2). 
… 

PEFC  ST 2003:2020  
C hapter 7.4 Audit 
All the  re quirements given in clause 7.4 of ISO/IEC 17065:2012(E) apply. 
7.4.1 The ce rtification body shall have documented procedures to ensure  
that an audit plan is e stablished for e ach audit, to provide a basis for 
agre ement re garding the conduct and scheduling of the audit activities. The 
audit plan shall be communicated and the dates of the audit shall be agreed 
upon in advance with the client organisation. 
Note : Guidance for preparing the audit plan is provided by ISO 19011:2018, 

437 

m anagement through ISO 19011 and ISO 
17021) addre ssed in the normative 
re quirement. 

F i ndings 

C ove red 

Fore st management 
According to Certification and 
Accre ditation procedure s, Annex 6 2007 – 
C hapter 4, it is re quired C ertification 
Bodie s to apply a documented 
m e thodology for the e valuation 
(assessments and audits) of clients. In 
additional, Certification Bodies fulfil or be 
com patible with ISO 17021. ISO 17021 
re que st to apply a documented 
m e thodology for the e valuation 
(assessments and audits) of clients. 

C hain of custody 
According to PEFC ST 2003:2020, 7.4.1; 
7.4.3; 7.4.7 and 7.4.8 it is re quire d for 
C e rtification Bodies to apply a 
docum ented methodology for the 
e valuation (assessments and audits) of 
clie nts.  

J ustification 

This indicator is concluded as covered for 
fore st management and chain of custody. 
The  documented methodology for the 
e valuation (assessments and audits) of 
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clause 6.3.2. 

re quirement. 

7.4.3 The ce rtification body shall have documented procedures for selecting 
and appointing the audit te am, including the audit te am leader. 
Note : Guidance for selecting the audit team and audit team leader is 
provided by ISO 19011:2018, 
clauses 5.5.4. 

7.4.7 The ce rtification body shall have documented procedures for 
de te rmining audit time, and for e ach client organisation the ce rtification 
body shall determine, with input from the audit team, the 
tim e  needed to plan and accomplish a complete and effective audit of the 
clie nt organisation’s PEFC chain of custody. The audit time determined by 
the  ce rtification body, and the justification for the determination, shall be 
re corde d. The minimum time for the on-site audit is four hours, this shall 
not include re porting activities, unless under specific conditions whe re it can 
be  justified and documented. 

7.4.8 The ce rtification body shall have documented procedures for sampling 
within the  audit in accordance with the  guidance provided in ISO 
19011:2018, A.6. 

B . 2.1.2 As a 
m inimum, this 
m e thodology shall 
include  procedures 
for the  following 
activitie s: 
i) Evaluation of 
conformity of 
organisations to 
the  Sche mes (e.g. 
audit of sites, or 
inspection of 
re cords or of self-

7.4.10 In the case of transfer of certification, the ce rtification body shall 
ope rate according to ISO/IEC 17065 clause 7.4.5 and IAF MD2:2017. 

C e rtification and Accre ditation procedure s, Annex 6 2007 
C hapter 4 C ERTIFICATION PROCEDURES 
The  ce rtification body shall have established internal procedures for fore st 
m anagement ce rtification against a national forest ce rtification scheme and 
for chain of custody certification against Annex 4 (Chain of Custody of Forest 
Base d Products – Requirements) or against a scheme specific chain of 
custody standard. 
The  applied ce rtification proce dures for forest m anagement ce rtification or 
chain of custody ce rtification against a scheme specific chain of custody 
standard shall fulfil or be compatible with the re quirements defined in any of 
the  following documents: 
a) ISO  17021(1) if the ce rtification is carried out as management system 
ce rtification, 

F i ndings 

C ove red 

Fore st management 
According to Certification and 
Accre ditation procedure s, Annex 6 2007 – 
C hapter 4, it is re quired for C ertification 
Bodie s to have an internal procedure. 
Although evaluation of conformity of 
organisations to the Schemes; review and 
ce rtification decision; issuance of a 
ce rtificate; and periodic re -assessment 
are  not specifically mentioned, it is 
considered these would be covered. 

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assessment 
de clarations); 
ii) R e view and 
ce rtification 
de cision; 
iii) Issuance of a 
ce rtificate; and 
iv)  Pe riodic re -
assessment. 

b) ISO  Guide 65 (EN 45 011)(2) if the ce rtification is carried out as product 
ce rtification (the term “product” is used in its wide st sense and includes also 
proce sses and services )(2), 
The  applied ce rtification proce dures for chain of custody certification against 
Anne x 4 (Chain of Custody of Fore st Based Products – R equirements) shall 
fulfill re quirements defined in ISO Guide 65 (EN 45 011)(2). 
… 
Additional specific re quirements for ce rtification procedures over and above 
the  ones listed above m ight be defined by the re spective fore st certification 
sche me (i.e. forest management certification and chain of custody 
ce rtification). 
C om pliance of the ce rtification body’s procedures with the  above 
re quirements shall be ve rified by accre ditation according to chapter 5.  

PEFC  ST 2003:2020  
3.5 C e rtificates 
3.5.1 O ne single certificate shall be issued with the  name and address of the 
ce ntral office of the 
clie nt organisation. A list of all the sites that the ce rtificate re lates to shall 
be  issued, either on the ce rtificate itself or in an appendix or as otherwise 
re fe rre d to in the ce rtificate. The scope or other re ference on the certificate 
shall make cle ar that the ce rtified activities are performed by the 
ne twork  of sites in the list. The appendix or other re ference is an integral 
part of the ce rtificate and shall not be separated from the certificate. 

6.1.1.4 R eviewe r and ce rtification decision maker 
The  ce rtification body shall e nsure  that the re viewe r and the certification 
de cision m aker meet the  
following requirements. If the reviewe r and/or the ce rtification decision 
m ak er are  composed by a group of people, at least one of the members 
m e e ts the following requirements. 

6.1.1.4.1 Education 

6.1.1.4.2 W orking e xperience 

6.1.1.4.3 PEFC chain of custody training  

439 

According to Certification and 
Accre ditation procedure s, Annex 6 2007 – 
C hapter 4 re quires the Certification Body 
to fulfil or be compatible with ISO 17021. 
ISO  17021 includes re quirements re lated 
to all points i) – iv) of this indicator.  

C hain of custody 
In re fe rence to part i), according to PEFC 
ST 2003:2020, 7.4.5 audits shall be on -
site  e valuation e xcept in the case of 
organisations without physical possession 
and in the case of multi-site ce rtificates, 
whe re  the  C B could decide to conduct the 
audit in other ways. For an organisation 
without physical possession, remote 
audits could replace on-site evaluation. 

In re fe rence to part ii) according to PEFC 
ST 2003:2020 6.1.1.4, 6.1.2.1, PEFC  
inte rnational states the procedure that 
should be followe d by the person involved 
in the  re view and ce rtification decision. In 
addition, details re lated to the e ducation 
(PEFC  ST 2003:2020 6.1.1.4.1), work ing 
e x perience  (PEFC ST 2003:2020 
6.1.1.4.2), PEFC chain of custody training 
(PEFC  ST 2003:2020 6.1.1.4.3), auditing 
training (PEFC ST 2003:2020 6.1.1.4.4), 
auditing experience  (PEFC ST 2003:2020 
6.1.1.4.5) and competencies (PEFC ST 
2003:2020 6.1.1.4.6) of staff involved in 
this process is e xplained. 

In re fe rence to part iii) according to PEFC 
ST 2003:2020 3.5 PEFC international 
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ce rtificate. According to PEFC ST 
2003:2020 3.5.1 one single ce rtificate 
shall be issued with the name of the 
ce ntral office of the client organisation. 

In re fe rence to part iv) according to PEFC 
ST 2003:2020 7.9 PEFC international 
stating the details of surveillance  audits. 
According to PEFC ST 2003:2020 7.9.1 an 
audit shall be carried  out annually.   

J ustification 

This indicator is concluded as covered for 
fore st management and chain of custody. 
At the  inte rnational le vel, procedures for 
e valuation of conformity of organisations 
to the  Schemes; re view and certification 
de cision; issuance  of a ce rtificate and 
Pe riodic re -assessment are addressed for 
Fore st management, through ISO 17021, 
and directly addressed in PEFC ST 
2003:2020 the normative requirement 
C hain of custody ce rtification.  

6.1.1.4.4 Audit training 

6.1.1.4.5 Audit experience 
6.1.1.4.6 C ompetencies 

6.1.2.1 The ce rtification body shall ensure  that qualified re viewe rs, 
ce rtification decision makers and 
auditors, e very two calendar years, have participated in a re fresher training 
in chain of custody of forest and tre e based products that is re cognised by 
the  PEFC  Council. 

7.4.5 The ce rtification body shall conduct the audit following the re levant 
guidance provided in ISO 19011:2018, clause 6.4. In general, audits (initial, 
surve illance and re certification) shall be conducted on -site, except in those 
case s whe re re quirements 7.4.6 or 7.9.2 of this standard apply, whe re 
ce rtification bodies may decide to conduct remote audits. 

7.4.9 In determining the audit time and sampling within the audit, the 
ce rtification body shall as a m inimum, consider the following aspects: 
a) the  re quirements of the Chain of Custody standard 
b) size and complexity of the clie nt organisation’s operations within the 
scope  of the PEFC chain of custody 
c) e x te nt of supplies that could cre ate a significant risk of procuring raw 
m ate rial from controversial sources  
d) e x tent of PEFC trademarks usage activities 
e ) any outsourcing of any a ctivities included in the scope of the 
organisation’s chain of custody f) the re sults of any prior audits, including 
those  of client organisation’s m anagement systems g) number of sites and 
m ulti-site considerations 

7.9 Surve illance 
7.9.1 The surve illance audits shall be carried out annually. The ce rtification 
body shall carry out at le ast 
four surveillance audits before  the e xpiry date of the ce rtificate.  

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B . 2.1.3 The 
Sche m e shall 
include  
re quirements that 
e nsure that 
C e rtification 
Bodie s have in 
place  - and 
im plement – 
spe cific procedures 
for audits that 
include  at least the 
following: 
i) fre quency of 
audits; (no longer 
than e very 12 
m onths); 
ii) re quirements 
for on-site (field) 
visits whe re  
applicable; 
iii) sampling 
protocol for audits 
(if applicable); 
iv) structure  and 
com petencies of 
the  audit team; 
v) the  m inimum 
se t of aspects that 
ne e d to be 
che ck e d in e very 
audit; 
vi) m inimum 
conte nt of audit 
re ports, including 
non-
conformances, 

C e rtification and Accre ditation procedure s, Annex 6 2007  
4. C ER TIFICATION PROCEDURES 
The  ce rtification body shall have established internal procedures for fore st 
m anagement 
ce rtification against a national forest ce rtification scheme and for chain of 
custody 
ce rtification against Annex 4 (Chain of Custody of Forest Based Products – 
R e quirements) 
or against a scheme specific chain of custody standard. 
The  applied ce rtification proce dures for forest m anagement ce rtification or 
chain of 
custody ce rtification against a scheme specific chain of custody standard 
shall fulfil or 
be  com patible with the re quirements defined in any of the following 
docum ents: 
a) ISO  17021(1) if the ce rtification is carried out as management system 
ce rtification, 
b) ISO  Guide 65 (EN 45 011)(2) if the ce rtification is carried out as product 
ce rtification (the term “product” is used in its wide st sense and includes 
also processes and services )(2), 
The  applied ce rtification proce dures for chain of custody certification against 
Anne x 4 
(C hain of C ustody of Forest Based Products – R equirements) shall fulfill 
re quirements 
de fined in ISO Guide 65 (EN 45 011)(2). 
The  applied auditing procedures shall fulfill or be compatible with the 
re quirements of 
ISO  19011. 
… 
The  m aximum period for surveillance audits is one year and maximum 
pe riod for re assessment 
audit is five ye ars for both forest management and chain of custody 
ce rtifications. 
The  audit e vidence to determine the conformity with the  forest management 
standard 
shall include re levant information from external parties (e.g. government 
age ncies, 

441 

C onclusion 

Partially 
C ove red 

F i ndings and Justification 

F i ndings 

Fore st management 
In re fe rence to part i) According to 
C e rtification and Accre ditation procedures, 
Anne x 6 2007, chapter 4, the maximum 
pe riod for surveillance audits is one ye ar 
and m aximum period for re assessment 
audit is five ye ars. For ii) C hapter 4 of 
Anne x 6 2007 re quires that C ertification 
Bodie s fulfil ISO 17021. ISO 17021 
contains re quirements for on-site (field) 
visits.  In the context of Covid19, as 
e x plained in the guidance from 
05/11/2020, on-site audits could be 
re placed by desk audits for forest 
m anagement ce rtificates. 

In re fe rence to part iii) according to 
Anne x 6 2007, chapter 4, Certification 
Bodie s shall fulfil ISO 17021 and ISO 
19011. ISO 19011 e xplained the 
proce dure  for sampling protocol for 
audits. 

R e garding iv) according to Annex 6 2007, 
chapte r 4, C ertification Bodies shall fulfil 
ISO  17021 and ISO 19011. ISO 17021 
e x plained the competence of personnel 
involve d in m anagement and ce rtification 
activitie s. ISO 19011 explained the 
proce dure  for selecting audit te am 
m e mbers. 

In re fe rence to part v) according to Annex 
6 2007, chapter 4, Certification Bodies 
shall fulfil ISO 17021. ISO 17021 contains 

 
 
 
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clarification of 
scope , audit 
proce ss and 
e valuation 
findings. 
vii) ability for 
unannounced or 
short-notice  audits 
in case  of 
substantiated 
claim s or for other 
re asons.  

com m unity groups, conservations organizations, etc.) as appropriate. 

Sustainable Forest Management auditing of PEFC ce rtified e ntities affected 
by re strictions due to COVID-19 – guidance Version 2 (05/11/2020) 

PEFC  ST 2003:2020  
Introduction 
The  PEFC C ouncil re quires the ce rtification bodies operating chain of custody 
ce rtification meet the  
re quirements of ISO/IEC  17065, PEFC documentation and the re levant 
provisions of ISO 19011 specified in this document. 

4. Sam pling for on-site audits 
4.1 Me thodology 
4.1.1 The ce rtification body can apply sampling of sites for on-site audits 
whe re  the  site sampling is 
appropriate to gain sufficient confidence in the compliance of the m ulti-site 
clie nt organisation  
with the  chain of custody requirements. The certification body shall be able 
to de monstrate its  
justification for the selection of sites for the on -site audits to ensure that all 
diffe rences across the sites and implementation of chain of custody have 
be e n assessed. 

7.9.1 The surve illance audits shall be carried out annually. The ce rtification 
body shall carry out at le ast four surveillance audits before the expiry date 
of the  ce rtificate. 
Note  1: Annually means once e very twe lve months, plus or minus thre e 
m onths. 
Note  2: If the ce rtificate is valid for less than five ye ars, the number of 
surve illance audits can be re duce d accordingly. 

7.9.2 The on-site surveillance  audit m ay be re placed by other audit 
te chniques, such as documentation and records re view, and the period 
be twe e n on-site surveillance audits shall not e xceed two ye ars (plus three 
m onths) whe re: 
a) the  ce rtification body can justify that the audit te chniques used deliver 

the  m inimum set of aspects that need to 
be  che cked in e very audit. Regarding part 
vi) according to Annex 6 2007, chapter 4, 
C e rtification Bodies shall fulfil ISO 17021 
and ISO 19011. ISO 19011 explained the 
m inimum content of audit re ports. 

In re fe rence to part vii) according to 
C e rtification and Accre ditation procedures, 
Anne x 6 2007, chapter 4, certification 
proce dure s for C ertification Bodies is 
e x plained. It is not clear if PEFC 
Inte rnational co nsistently includes the 
ability for unannounced or short-notice  
audits in case of substantiated claims or 
for othe r re asons. 

C hain of custody 
In re fe rence to parts: 

i) according to PEFC ST 2003:2020, 7.9.1 
audits shall be made annually. Based on 
note  1 of this indicator: “Annually means 
once  e very twe lve m onths, plus or minus 
thre e  m onths”. This means that the 
fre quency of audits could be betwe en 9 
m onths and 15 months. 

ii) according to PEFC ST 2003:2020, 7.9.2 
on-site audit could be re placed by desk 
audit. Conditions for doing this are 
de tailed under 7.9.2.  
In the  context of C ovid19, as explained in 
the  guidance from 25/05/2020, on-site 
audits could be re placed by desk audits 
for chain of custody certificates. 

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sufficient confidence  in the 
ce rtifie d entity’s compliance  with the ce rtification crite ria; and 
b) no nonconformity was raised during the previous initial, surveillance  or 
re ce rtification audit; and 
c) the  clie nt organisation procurement does not include significant risk 
supplies; and 
d) the  clie nt organisation provides the ce rtification body with all the re cords 
re quire d to be k ept by the C hain of C ustody standard or a list of all the 
re cords that allow the  ce rtification body to  e stablish an independent 
sam pling; or 
e ) the  submitted re cords provide sufficient evidence  that the client 
organisation or client organisation’s site has not procure d raw m aterial and 
has not sold any product with a PEFC claim since the last audit. 

Appe ndix 4 (normative): Minimum content of audit re ports  
Audit re ports shall include, as a minimum, the following content: 
… 

C hain of custody auditing of PEFC certified companies affected by 
re strictions due to C OVID-19 – guidance Ve rsion 5 (25/05/2020) 

i) https://pefc.org/covid-19  

iii) PEFC  ST 2003:2020, 4. stating the 
sam pling protocol for audits. 

iv) according to PEFC ST 2003:2020, 
Introduction, shall fulfil ISO 17021. ISO 
17021 contains the minimum set of 
aspects that need to be checked in every 
audit. 

v) according to PEFC ST 2003:2020, 
Introduction, shall fulfil ISO 19011. ISO 
19011 explained the procedure for 
se le cting audit team members. 

vi): to PEFC  ST 2003:2020, Appendix 4 
stating the minimum content of audit 
re ports, including non-conformances, 
clarification of scope, audit process and 
e valuation findings. 

vii) It is no t clear if PEFC International 
consistently includes ability for 
unannounced or short-notice audits in 
case  of substantiated claims or for other 
re asons. 

J ustification 

This indicator is concluded as partially 
cove re d for forest m anagement and chain 
of custo dy. In case of forest 
m anagement, it is not cle ar if standards 
consistently includes the ability for 
unannounced or short-notice audits in 
case  of substantiated claims or for other 
re asons.  

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The  PEFC Board of Directors, in its meeting on 17 November 2014 in Paris, 
France , has provided the following interpretations:  
The  re quirement ”the audit evidence to determine the conformity with the 
forest management standard shall include relevant information from 
external parties (e.g. government agencies, community groups, 
conservations organisations etc.) as appropriate” (PEFC TD Annex 6, section 
4) 
shall be understood as “the audit must, amongst other relevant information, 
include sufficient consultation with external stakeholders to ensure that all 
relevant issues are identified relating to compliance with the requirements of 
the standard”. 

B.2.2 

Stak eholde
r 
consultatio
n 

B . 2.2.1 The 
Sche m e shall 
include  
m e chanisms to 
e nsure that 
C e rtification 
Bodie s conduct 
consultation with 
stak eholder 
(including rights 
holders) as 
appropriate in 
re lation to audits 
(only applicable 
whe re  
ne ce ssary** for 
e valuating 
com pliance of 
ce rtificate 
holders).  

The  scheme shall 
e nsure that the 
ce rtification holder 
has a proper 
stak eholder 
consultation 
proce ss in place. 

444 

Partia lly 
C ove red 

In case of Chain of custody, frequency of 
audits m ay exceed 12 months. At the 
sam e time, in the context of Covid19 on-
site  audits could be replace d by desk 
audits. 
F i ndings 

Fore st Management 

During the consultation with scheme 
owne rs, PEFC e xplained that the Board of 
Dire ctors had a meeting in 2014 and 
e x plained that stakeholder consultation 
shall be included in forest management 
ce rtification. This document is not publicly 
available, but was shared with Pre ferre d 
by Nature  for the purposes of this study. 

Findings at the national le vel for Forest 
m anagement 

Brazil, C hina and R ussia assessment 
conclude this indicator as covered, as 
spe cific indicator re lated to the 
stak eholder consultation is added in the 
national standards. In case of Romania, 
the  scheme defines in Annex 12 the 
“R e quirements for C ertification Bodies and 
Auditors for assessing forest ce rtification 
in R omania” (PEFC-RO DST 8012:2017). 
The re  are no re ferences to the need that 
C e rtification Bodies conduct consultation 
with stak eholders. 

C hain of custody 

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to be  conducte d as part of the chain of 
custody ce rtification.  

J ustification 

This indicator is concluded as partially 
cove re d. There are re quirements for 
stak eholder consultation in case of forest 
m anagement ce rtification. Howe ver, 
although the requirement applies to all 
countrie s it appears that is not followe d by 
all assessed national standards. For the 
chain of custody, there is no re quirement to 
conduct stakeholder consultation. 

F i ndings 

According to standards and procedure s 
de ve loped at the international le vel, there 
are  no mechanism in place within the 
PEFC  Sche me to identify (or for the 
C e rtification Body to do so) companies 
sanctioned for corrupt practices. However, 
Fore st Management standard includes an 
indicator re questing ce rtificate holder to 
com ply with the anti-corruption policy. 

Findings at the national le vel for Forest 
m anagement 

This indicator is assessed as not covered 
for all 4 countries. Although, according to 
the  findings from C .2.1.1, national 
standards assessed on this project has 
be e n developed based on the previous 
ve rsion of Forest Management standard.  

Not 
C ove red 

B.2.2 

C orruption 

B . 2.2.2 The 
Sche m e shall 
include  
m e chanisms to 
ide ntify (or for the 
C e rtification Body 
to do so) 
com panies 
sanctioned for 
e ngagement in 
corrupt practices 
re le vant to the 
fore st sector. 

PEFC  ST 1003: 2018 
6.3.1.2 The standard re quires that the organisation shall comply with 
applicable local, national and  
inte rnational le gislation on forest management, including but not limited to 
fore st management 
practice s; nature  and environmental protection; protected and endangere d 
spe cies; property, te nure and land-use rights for indigenous peoples, local 
com m unities or other affecte d stakeholders; health, labour and safety 
issues; anti-corruption and the payment of applicable royalties and taxes. 
6.3.1.3 The standard re quires that whe re no anti-corruption legislation 
e x ists, the organisation must take alternative anti-corruption measure s 
appropriate to the risk of corruption. 

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J ustification 

This indicator is concluded as not covered 
for fore st m anagement and chain of custody. 
The re  are no m echanisms for the scheme - 
or for the  C ertification Body - to identify 
com panies sanctioned for e ngagement in 
corrupt practices relevant to the forest 
se ctor at the level of PEFC International. 

C. Requirements for Certification Schemes 

C.1 Transparency 

C .1.1 

Transpare
ncy 

C .1.1.1 Scheme 
re quirements for 
both C ertificate 
Holde rs and 
C e rtification 
Bodie s shall be 
publicly available 
online.  

i) https://www.pe fc.org/standards-implementation/standards-and-guides 
ii) https://www.pe fc.org/discover-pefc/our-pefc-members/national-members  

F i ndings 

Partially 
C ove red  

iii) https://www.pe fc.org/for-business/certification-and-accre ditation-
bodies/become-a-pefc-notified-certification-body  
iv) https://www.iaf.nu/articles/MLA_Documents/39  

ISO /IEC 17011:2017 8.2 

446 

Management of the scheme is undertaken 
by PEFC  International with support from 
IAF, an organisation allowing the 
organisation to become accreditation 
bodies. Accre ditation bodies, in its turn, 
allowing the organisation to become 
ce rtification bodies. 

PEFC  International has developed a 
we bsite  to acce ss benchmark  and 
norm ative standards (i)  and the forest 
ce rtification systems for all countries (ii). 
In addition, there are  details for 
organisations that would like to become a 
C e rtification body (iii). Howe ver, some 
im portant documents, like the note from 
the  PEFC  Board of Directors meeting from 
17 Nove mber 2014 is not publicly 
available. This note explains that forest 
m anagement ce rtification shall include 

 
 
 
 
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stak eholder consultation. At the same 
tim e , PEFC explains that some national 
sche mes whose endorsement e xpired on 
or afte r 1 January 2017 we re  offered an 
e x traordinary endorsement e xtension to 
facilitate a smooth transition to the 2018 
standard. This procedure is not publicly 
available. 

IAF allow the  organisation to become 
accre ditation bodies, based on Multilateral 
R e cognition Arrangement (MLA). MLA 
allow accre ditation bodies to be 
re cognised by other members of the MLA, 
and this proce ss is done based on 
ISO /IEC Guides. The proce dures related 
to MLA are  publicly available on the 
we bsite  (iv). Howe ver, the standards used 
in the  assessment of an applicant is not 
publicly available (ISO/EC 17011).  

The re  are m ultiple accre ditation bodies 
allowe d to accre dit certification bodies. 
According to ISO/IEC 17011:2017 8.2.1, 
accre ditation body shall make publicly 
available information related to the 
accre ditation body and information about 
the  process. Information like, complaints 
and appeals are part of publicly available 
inform ation. According to ISO/IEC 
17011:2017 8.2.2 shall make publicly 
available information on conformity 
assessment bodies. Howe ver, at a quick 
look , some CBs m ay not share all 
inform ation on their we bsite. For 
e x ample, Be larusian State C entre for 
Accre ditation (BSCA); Lithuanian National 

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Accre ditation Bureau (LA); R omanian 
Accre ditation Association (RENAR ) do not 
have  a list of ce rtification bodies approved 
by the m .  

For organisation providing Forest 
Management, PEFC international define 
re quirements for C ertification Bodies 
(C e rtification and Accre ditation 
proce dure s, 2007 – Annex 6), that apply 
in addition to Accre ditation re quirements. 
The se requirements are publicly available. 

For organisation providing Chain of 
C ustody, PEFC International define 
re quirements for C ertification Bodies 
(PEFC  ST 2003: 2020), that apply in 
addition to Accre ditation re quirements. 
The se requirements are publicly available. 

For both types of ce rtification (FM and 
C oC ) notification procedures re quested in 
orde r to allow C Bs to assess and issue 
C Hs are publicly available. 

J ustification 

This indicator is concluded as partially 
cove re d. The main procedure s re lated to 
how the  scheme is operating are available 
on the  PEFC we bsite. Howe ver, some 
proce dure s related to the accre ditation 
proce ss are not publicly available.  

C .1.1.2 Schemes 
shall include 
re quirements that 

i) https://www.pe fc.org/ 
ii) https://www.pe fc.org/discover-pefc 
iii) https://www.pe fc.org/standards-implementation 

F i ndings 

PEFC  International developed a we bsite 
(i) to give  information to all parties 

Partially 
C ove red 

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e nsure that 
re le vant 
inform ation about 
the  following is 
fre e ly available: 
i) de ve lopment 
and content of the 
Sche m e; 
ii) how the  system 
is gove rned;  
ii) who is 
e valuated and 
unde r what 
proce ss;  
iv) im pact 
inform ation and 
the  various ways 
in which 
stak eholders can 
e ngage. 

C .1.1.3 The 
Sche m e shall 
include  
re quirements that 
e nsure that an up-
to-date register of 
ce rtifie d/verified 
organisations is 
publicly available. 

iv) https://www.pe fc.org/discover-pefc/governance 
v) https://www.pe fc.org/what-you-can-do/become-a-member 
vi) https://www.pe fc.org/contact-us . 

inte re sted to know m ore  about their 
ce rtification (ii). O n the we bsite, there is 
inform ation related to the development 
and content of schemes (iii), related to 
the  governance (iv), and also various 
ways for stakeholders to engage in this 
proce ss: Become a member of the 
inte rnational stakeholder group (v); Add 
que stions or complaints  (vi). Howe ver, 
im pact information are not available on 
the  we bsite. 

J ustification 

This indicator is concluded as partially 
cove re d. Scheme re quirements e nsure that 
re le vant information re lated to development 
of the  Scheme; how the  system are 
gove rned; who is e valuated and process; 
and the various ways in which stakeholders 
can e ngage is freely available. Howe ver, 
im pact information are not available on the 
we bsite . 

https://www.pe fc.org/find-ce rtified 

F i ndings 

Partially 
C ove red 

PEFC  ST 2002: 2020  
5.1.2 Identification at supplier le vel 
5.1.2.1 For all inputs delivere d with a PEFC claim the organisation shall 
ve rify that the supplier is 
cove re d by a PEFC re cognised ce rtificate on the PEFC we bsite. 

P EFC GD 1008: 2019, C hapter 5, table 1 (a) 

PEFC  International has developed an 
online platform to check the status of 
fore st management and chain of custody 
ce rtificates issued by the C ertificate 
Bodie s. Chain of custody re quirements 
include s that ce rtificate holders verify that 
the  supplier is covered by a PEFC 
re cognised ce rtificate using the PEFC 
we bsite . Thus, the certification 
inform ation on the we bsite forms a 
fundamental part of the scheme 

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re quirements.  

As discussed with PEFC, information from 
the  online platform is updated based on 
inform ation communicated by ce rtification 
bodies. Data collecte d for the online 
platform is available in PEFC GD 1008: 
2019, C hapter 5, Table 1. The acce ss to 
the  database is guaranteed for national 
gove rning bodies and the PEFC C ouncil, 
and they are re sponsible for re gistering 
and updating data in the platform. 
As discussed with PEFC, the typical delay 
is a we e k  and depends on how fast 
inform ation is sent from the ce rtification 
body to re sponsible for entering data in 
the  platform. At the same time, PEFC will 
use  a new platform during next m onths. 

Fore st Management Certificates  

 

 

 

The  public information for forest 
m anagement includes organisation 
nam e, address, contact details, type 
of ce rtificate, status, expiry date, 
ce rtificate number and ce rtification 
body.  
The re  is a field within the database 
C om pany P roducts to describe the 
product types within scope, but this 
doe s not appear to be used. Also 
m issing is in formation on species 
within the  scope of the ce rtificate. 
The  database does not include 
inform ation about forest area or 
location within the scope of the 
ce rtificate. The address of Forest 

P EFC GD 1008: 2019, C hapter 5, table 1 (b) 

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 

Management Enterprise Office is 
include d in the database.  
In the  case of group FM certificates, it 
is possible to search all of the group 
m e mbers covered by one group 
ce rtificate. Howe ver for address of 
group members or  information about 
fore st are a or location within the 
scope  of the certificate are not 
disclosed. The address of Group 
Manager O ffice  is included in the 
database. 

C hain of C ustody Certificates  

 

 

 

The  public information for C hain of 
C ustody includes organisation name, 
addre ss, contact details, type of 
ce rtificate, status, expiry date, 
ce rtificate number and ce rtification 
body.  
The re  is a field within the database 
C om pany Products to describe the 
product types within scope, but this 
doe s not appear to be used 
consistently for all ce rtificates. Also 
m issing is in formation on species 
within the  scope of the ce rtificate. 
It is not possible via the platform, to 
de te rmine if products are  made 
of/contain recycle d material. 

J ustification 

This indicator is concluded as partially 
cove re d. A re gister of certified/verified 
organisations is publicly available. The 
database allows to identify the ce rtification 
status of named companies from their name 
or ce rtification code. Howe ver, the database 
doe s not include information about forest 
are a or location within the scope of the 
ce rtificate 

451 

 
 
 
 
 
 
C onclusion 

Not 
C ove red  

ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

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F i ndings and Justification 

C .1.1.4 The 
Sche m e shall 
m ak e summaries 
(or full re ports) 
with re le vant 
findings from 
audits available on 
the  inte rnet. 

i) https://www.pe fc.org/find-certified 

F i ndings 

PEFC  ST 2003: 2020 
3.5 C e rtificates 
3.5.1 O ne single certificate shall be issued with the  name and address of the 
ce ntral office of the 
clie nt organisation. A list of all the sites that the ce rtificate re lates to shall 
be  issued, either on the ce rtificate itself or in an appendix or as otherwise 
re fe rre d to in the ce rtificate. The scope or other re ference on the certificate 
shall make cle ar that the ce rtified activities are performed by the 
ne twork  of sites in the list. The appendix or other re ference is an integral 
part of the ce rtificate and shall not be separated from the certificate. 

Anne x 6 – C ertification and Accre ditation procedures, 2007 – Chapter 4 
C ER TIFICATION PROCEDURES 
The  ce rtification body shall have established internal procedures for fore st 
m anagement ce rtification against a national forest ce rtification scheme and 
for chain of custody certification against Annex 4 (Chain of Custody of Forest 
Base d Products – Requirements) or against a scheme specific chain of 
custody standard. 
The  applied ce rtification proce dures for forest m anagement ce rtification or 
chain of custody ce rtification against a scheme specific chain of custody 
standard shall fulfil or be co mpatible with the re quirements defined in any of 
the  following documents: 
a) ISO  17021(1) if the ce rtification is carried out as management system 
ce rtification, 
b) ISO  Guide 65 (EN 45 011)(2) if the ce rtification is carried out as product 
ce rtification (the term “product” is used in its wide st sense and includes also 
proce sses and services )(2), 
The  applied ce rtification proce dures for chain of custody certification against 
Anne x 4 (Chain of Custody of Fore st Based Products – R equirements) shall 
fulfill re quirements defined in ISO Guide 65 (EN 45 011)(2). 
The  applied auditing procedures shall fulfill or be compatible with the 
re quirements of ISO 19011(3). 
In addition to above requirements the certification body: 
a) informs the relevant PEFC National Governing Bodies about all issued 
fore st management and chain of custody ce rtificates and changes 

According to Annex 6 – C ertification and 
Accre ditation procedure s, 2007 – C hapter 
4, “A summary of the ce rtification report, 
including a summary of findings on the 
auditee’s conformity with the  forest 
m anagement standard, writte n by the 
ce rtification body, shall be made available 
to the  public by the auditee or in 
accordance with any applicable 
re quirements defined by the re spective 
fore st ce rtification scheme.”.  

Howe ve r, re ports are  not available in the 
online platform developed by the PEFC 
Inte rnational (https://www.pe fc.org/find-
ce rtifie d). Howe ver, it has been observed 
that: 

 

 

PEFC  Ge rmany uploads these 
re ports on their national we bsite: 
https://pefc.de/fur-
waldbe sitzer/pefc-meiner-
re gion/. This is a good way to 
give  acce ss to the public to 
re ports;  
According to PEFC Annex 6, each 
auditee is responsible for m aking 
the  re port publicly available. 

In this case, the Scheme is not 
re sponsible for m aking re ports publicly for 
Fore st Management Certificates, and as 
can be  seen from practice, auditing 
re ports are  not available on the internet.  

The re  are no re quirements for public 

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conce rning validity and scope of these certificates, 
In the  case of a multi-site chain of custody ce rtification the certification body 
shall provide the relevant PEFC National Governing Body with a list of all 
site s covered by the multi-site organisation. 
In the  case of a multi-site chain of custody ce rtification covering sites 
locate d in more than one country, the re levant PEFC National Governing 
Body is the PEFC National Governing Body in the country whe re  the head-
office  of the multi-site organisation is re gistered. Information about the sites 
locate d in countries other than where  the head office is re gistere d shall also 
be  provided to the PEFC National Governing Bo dy of that country. 
If the  chain of custody ce rtification has been carried out in a country without 
a PEFC  National Governing Body, the information shall be provided directly 
to the  PEFC C ouncil. 
b) carrie s out control of PEFC logo usage if the ce rtified e ntity is a PEFC logo 
use r. 
The  m aximum period for surveillance audits is one year and maximum 
pe riod for re assessment audit is five ye ars for both forest management and 
chain of custody ce rtifications. 
The  audit e vidence to determine the conformity with th e  forest management 
standard shall include re levant information from external parties (e.g. 
gove rnment agencies, community groups, conservations organizations, etc.) 
as appropriate. 
A sum mary of the ce rtification report, including a summary of findings on 
the  auditee’s conformity with the  forest management standard, writte n by 
the  ce rtification body, shall be m ade available to the public by the auditee or 
in accordance with any applicable re quirements defined by the re spective 
fore st ce rtification scheme. 
Additional specific re quirements for ce rtification procedures over and above 
the  ones listed above m ight be defined by the re spective fore st certification 
sche me (i.e. forest management certification and chain of custody 
ce rtification). 
C om pliance of the ce rtification body’s procedures with the  above 
re quirements shall be ve rified by accre ditation according to chapter 5.  

i) https://www.pe fc.org/standards-implementation/assuring-
com pliance/complaints-and-appeals  

1001:2017 

453 

sum maries of audits in re lation to Chain 
of C ustody or controlled sources. 

PEFC  International that Annex 6 was 
de ve loped a long time ago whe n the 
inte rne t was not used so often, and they 
have  in plan to re vise the procedure. 

J ustification 

This indicator is concluded as not covered.  
The  Scheme is not re questing to make 
re ports publicly available on the internet. 
Howe ve r, some NGBs may re quest this in 
addition to standard requirements from PEFC 
Inte rnational. 

F i ndings 

C ove red  

C om plaints against ce rtified e ntities are 
de alt with by the re spective complaints 

C .1.2 

Im partialit
y 

C .1.2.1 Procedures 
for handling 
com plaints and 
grie vance s shall be 

 
 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

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in place , m ade 
publicly available 
and im plemented. 
The  procedures 
shall be clearly 
publicized, m aking 
it e asy for 
stak eholders to 
submit comments 
or com plaints 
whe re  applicable. 

5.3 Handling of complaints and appeals  
5.3.1 The standardizing body shall establish procedure(s) for dealing with 
any substantial and process complaints and appeals re lating to its standard-
se tting activities. It must m ake procedure(s) acce ssible to stakeholders. 
Upon re ceipt of a complaint or appeal, the standardizing body shall:  
a) ack nowledge re ceipt of the complaint or appeal to the complainant,  
b) gather and verify all necessary information to validate the complaint or 
appeal, evaluate the subje ct matter of the complaint or appeal impartially 
and obje ctively, and make a decision regarding the complaint or appeal, and  
c) form ally communicate the decision on the complaint or appeal to the 
com plainant and describe the handling process.  
5.3.2 The standardizing body shall establish at least one contact point for 
e nquiries, complaints and appeals re lating to its standard -setting activities. 
The  contact point shall be easy to acce ss and re adily available. 

GL 7/2007 PEFC Council procedure s for the investigation and re solution of 
com plaints and Appeals 
1. O BJEC TIVE 
The  obje ctive of this guideline is to describe the re sponsibilities and actions 
of the  PEFC Council and the PEFC National Governing Bodies in re lation to 
the   investigation and re solution of complaints and appeals. 
The  PEFC C ouncil re gards all complaints and appeals as opportunities to 
im prove its services and implement corre ctive and preventive measures. 
The  PEFC C ouncil is committed to monitoring and achieving continual 
im provement in all areas of its  activities and those of its members. 
2. SC O PE 
This guideline details procedure s for complaints and appeals to the PEFC 
C ouncil which concern decisions and/or activities of the PEFC C ouncil or its 
m e mbers   
C om plaints and appeals re lating to the decisions and activities of a certified 
e ntity; an accredited ce rtification body or an accre ditation body shall be 
de alt with by the  complaints and appeals procedures of the re levant 
accre dite d certification body;  accre ditation body; or by the International 
Accre ditation Forum. 
This guideline was approved by the Board on 28th June 2007. 
… 
4.5 C omplaints submitted regarding a specific ce rtified e ntity shall be 

454 

and appeals procedures put in place by 
ce rtification bodies. Issues that remain 
unre solved at this level should be raised 
with the  re spective complaints and 
appeals m echanisms of national 
accre ditation bodies and there after - as 
the  third level of appeal - with the PEFC 
Inte rnational or International 
Accre ditation Forum (GL7/2007, 4.5, 4.6, 
4.7).  The process of the complaint is 
de scribed in detail in GL 7/2007 and 
de fine a cle ar period to re solve the issue 
in dire ct communication (6 m onths).  

If the  ce rtification body, or indeed an 
accre ditation body is judged not to have 
de alt with the complaint appropriately, it 
risk s losing its license to operate. (i). 

In addition, on the process of developing 
national standards, complains and 
appeals are included in the process. 

J ustification 

This indicator is concluded as covered. 
Proce dures for complaints and appeals are 
publicly available and steps for submitting a 
com m ent or complain are cle ar.  

 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

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C onclusion 

C 1.3 

C onflict of 
inte re st 
and 
corruption 

C .1.3.1 The 
C e rtification 
Sche m e shall have 
in place  
re quirements at all 
le ve ls of the 
sche me 
(norm ative 
re quirements for 
C Hs, re quirements 
for C Bs, and for 
the  scheme 
functioning) to 
m anage risks of 
corruption and 
conflict of intere st. 

re fe rre d to the relevant ce rtification body’s own complaints / appeals 
re solution procedure . 
4.6 C omplaints submitted regarding a specific accredited certification body 
shall be referred to the re levant accre ditation body’s (or bodies’) own 
com plaints / appeals re solution proce dure. 
4.7 C omplaints submitted regarding a specific accreditation body shall be 
re fe rre d to the International Accre ditation Forum’s complaints / appeals 
re solution procedure  (www.iaf.nu). 

C e rtification and Accre ditation procedure s, 2007 – Annex 6, 
4. C ER TIFICATION PROCEDURES 
The  ce rtification body shall have established internal procedures for fore st 
m anagement 
ce rtification against a national forest ce rtification scheme and for chain of 
custody 
ce rtification against Annex 4 (Chain of Custody of Forest Based Products – 
R e quirements) 
or against a scheme specific chain of custody standard. 
The  applied ce rtification proce dures for forest m anagement ce rtification or 
chain of 
custody ce rtification against a scheme specific chain of custody standard 
shall fulfil or 
be  com patible with the re quirements defined in any of the following 
docum ents: 
a) ISO  17021(1) if the ce rtification is carried out as management system 
ce rtification, 
b) ISO  Guide 65 (EN 45 011)(2) if the ce rtification is carried out as product 
ce rtification (the term “product” is used in its wide st sense and includes 
also processes and services )(2), 
The  applied ce rtification proce dures for chain of custody certification against 
Anne x 4 
(C hain of C ustody of Forest Based Products – R equirements) shall fulfill 
re quirements 
de fined in ISO Guide 65 (EN 45 011)(2). 
The  applied auditing procedures shall fulfill or be compatible with the 
re quirements of 
ISO  19011. 

455 

F i ndings 

Partially 
C ove red  

The  Scheme does not have public policy 
re late d to the absence of corruption from 
sche me functioning. In the e ndorsement 
of National Systems, an independent 
assessor is appointed by PEFC 
Inte rnational to check  the National 
Syste m . In the selection of assessor, 
im partiality, and absence of conflicts of 
inte re st are part of the selection process.  

According to PEFC “The PEFC Board 
C harter re quires board members to 
dilige ntly and honestly in accordance with 
applicable laws, have a duty to act with 
care  and diligence, in good faith, and 
m aintaining the highest e thical standards, 
m ust disclose conflicts of interest and 
absent themselves from voting on such 
m atte rs; and never act dishonestly or 
re ck le ssly, break the law, take bribes or 
pe rsonal gains. Board m embers are not 
re num erated and the Board, as we ll as 
the  staff, are subject to regular appraisal 
and performance  reviews.”. Howe ver, a 
spe cific re quirement to exclude corruption 
from  all levels (not just PEFC Board) is 

 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

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C onclusion 

PEFC  ST 2003:2020  
Introduction 
The  PEFC C ouncil re quires the ce rtification bodies operating chain of custody 
ce rtification meet the  
re quirements of ISO/IEC  17065, PEFC documentation and the re levant 
provisions of ISO 19011 specified in this document. 

not m ade. 

IAF, organisation that allow organisation 
to be come accre ditation bodies, does not 
have  any public policy re lated to 
corruption or conflict of interest.  

For C e rtification Bodies, according to 
C e rtification and Accre ditation procedures, 
2007 – Annex 6 (for forest m anagement) 
and PEFC ST 2003:2020 (for chain of 
custody) shall fulfil ISO 17021. ISO 7021 
include s clear re quirements re lated to the 
im partiality and self-interest threats. 
Howe ve r, there is no explicit re quirement 
in re lation to corruption.. 

For C e rtificate Holders, Fore st 
Management Standards include under the 
standard re quirements that C H shall 
com ply with anti-corruption laws and in 
countrie s whe re legislation is not 
m e ntioned, clear steps are defined. 
C onflict of interest is not applicable at this 
le ve l.  For C hain of C ustody ce rtification, 
the re  is no re quirement re lated to the 
corruption. 

J ustification 

This indicator is concluded as partially 
cove re d. The Scheme does not manage risks 
of corruption and conflict of intere st at all 
le ve ls of the scheme.  

456 

 
 
 
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C onclusion 

C.2 Scheme & standard scope 

Note : se ction C2 is not specifically re ferring to EUTR issues but has been included as part of the evaluation of schemes to u nderstand scheme structures. 
C .2.1 

F i ndings 

Partially 
C ove red 

Standard 
adaptation 
to the  
national or 
subnationa
l conte x t 

C .2.1.1 
Inte rnational 
standards shall be 
adapted to the 
national or 
subnational 
conte xt in which 
the y are  being 
im plemented and 
contain a list of 
applicable 
le gislation, or the 
Sche m e shall 
e nable/require  
de tailed evaluation 
of applicable 
le gislation in a 
national context. 

PEFC  ST 1001: 2017 6.3.1 The standardizing body shall m ake a public 
announcement of the start of the standard -setting process and include an 
invitation to stakeholders to participate in the proce ss. The announcement 
shall be made in a timely manner through suitable media, as appropriate, to 
give  stakeholders an opportunity for meaningful contributions. The 
announcement and invitation shall include: 
a) ove rview of the standard -setting process, 
b) acce ss to the proposal for the standard (refer to 6 .1), 
c) inform ation about opportunities for stakeholders to participate in the 
proce ss, 
d) re quests to stakeholders to nominate their re presentative(s) or 
the m selves to the work ing group 
(re fe r to 6.4). The re quest to disadvantaged stakeholders and key 
sta k eholders shall be made in a manner that e nsures that the information 
re ache s intended re cipients and in a format that is easy to understand,  
e ) e x plicit invitation and clear instruction on how to submit feedback on the 
scope  and standardsetting process, a nd 
f) acce ss to the standard-setting proce dures. 
Note  1: In a timely manner means (at the latest) four we e ks before the first 
standard-setting activity is 
sche duled to occur. 
Note  2: Through suitable media means at least through the standardizing 
body’s we bsite and by email and/or le tter to identified stakeholders. O ther 
m e dia includes press re leases, news articles, feature s in trade-press, 
inform ation sent to branch organizations, social media, digital media, etc.  

PEFC  GD 1007: 2017, 6.1.2 The assessment may consist of the following 
e le ments: 
a) A ge neral analysis of the structure of the applicant system 
b) An assessment of the standard setting procedures against PEFC ST 1001, 
Standard Setting – R equirements 
c) An assessment of the standard setting process, including a stakeholder 
surve y, against PEFC ST 1001, Standard Se tting – Requirements 

457 

PEFC  system is an umbrella of national 
standards. This means that the 
inte rnational le vel defines the rules that 
should be followe d by national bodies in 
se tting up the standards.  

Fore st management 

The  national body has the powe r to tailor 
the  standard according to the national 
conte xt (PEFC  ST 1001: 2017). In this 
proce ss, new indicators could be added 
re fle cting the issues that are re levant at 
the  local level. According to PEFC GD 
1007:2017, 6.1.2 d), e), f) national 
standards are assessed by the PEFC 
Inte rnational in the e ndorsement process. 

A list of applicable legislation is not 
re que sted to be developed by national 
m e mber/ standard, according to PEFC ST 
1001: 2017.  

In practice , some indicators of PEFC ST 
1003: 2018 may not be included at the 
national level. For e xample, point 6.3.1 of 
PEFC  ST 1003: 2018 - Legal C ompliance  
is not e xplicitly re quested in the Forest 
Management Standards from France , 
Ne the rlands, and R omania. Howe ver, 
othe r countries like Austria, Bulgaria, 
C hina, Estonia, Kore a, and Japan do 

 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

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C onclusion 

d) An assessment of the forest ce rtification standard(s) against PEFC ST 
1003: 2018, Sustainable Forest Management – R equirements 
e ) An assessment of the group ce rtification model against PEFC ST 1002, 
Group Forest Management Certification – Requirements 
f) An assessment of any system specific chain of custody standard(s) 
against PEFC ST 2002: 2020, Chain of Custody of Fore st Based Products – 
R e quirements 
g) An assessment of the procedure s for notification of ce rtification bodies 
against PEFC GD 1004, Administration of the PEFC scheme, chapter 5  
h) An assessment of the procedure s for logo licensing against PEFC GD 
1004, Administration of PEFC scheme, chapter 6  
i) An assessment of the complaints and dispute re solution procedures 
against PEFC GD1004, Administration of PEFC scheme, chapter 8  
j) An asse ssment of the forest management ce rtification and accreditation 
proce dure s against TD Annex 6 (Certification and Accre ditation Procedures) 
k ) An assessment of the chain of custody ce rtification and accreditation 
proce dure s against PEFC ST 2003, R equirements for Certification Bodies 
ope rating Certification against the PEFC International C hain of C ustody 
Standard 
l) Any othe r aspects affecting the applicant system’s compliance with the 
PEFC  Sustainability Be nchmark. 
The  assessment does not cover any other documents from the applicant 
syste m for which no PEFC benchmark  exists. 

PEFC  ST 1001: 2017 8.1 General  
The  standard(s)/normative document(s) shall be re viewe d at intervals that 
do not e xceed a five-year period. The re view shall be based on consideration 
of fe e dback re ceived during the standard’s implementation and a gap 
analysis. If necessary, a stakeholder consultation shall be organized to 
obtain further feedback and input. 

include  this re quirement. The re ason for 
this difference is that national schemes 
have  ye t to update their standards to 
m e e t the newe st ve rsion of PEFC 
norm ative re quirements for FM s tandards. 
Future  m ore, on a check of all national 
standards it was found that no national 
standard has ye t been updated to the 
2018 ve rsion of Benchmark  Standard.   

According to PEFC ST 1001: 2017 8.1, the 
national standards should be periodically 
re vie we d. The period is defined as five 
ye ars. This means that indicators from 
the  curre nt forest management standard 
(PEFC  ST 1003: 2018), in theory will be  
im plemented for all countries at the end 
of 2023. Despite the standard 
re quirements, this is not being followe d 
by all National Governing Bodies. There  
are  countries with forest management 
standards developed or last revised in 
2014 (e.g. Spain, Poland, Belgium). 
More over, there  are countries with 
standards developed based on the “Pan 
Europe an Operational Level Guidelines” - 
de ve loped at the beginning of PEFC 
(1998). The standard for Ireland was 
de ve loped in 2010, but PEFC ST 1003: 
2010 was not used as the basis for 
de ve lopment. The last conformity 
assessment of this standard is from 2011. 
In the  case of Brazil, the standard for 
native  forests was developed in 2004. A 
proce ss to update the standard is in place 
as of the completion of this re port, which 

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m ay be completed by the e nd of 2021. 

For Ire land and Brazil, PEFC explains that 
the  de velopment and endorsement of the 
Brazilian and Irish systems coincided with 
the  re vision of the Technical Document 
and the approval of PEFC 1003:2010. To 
e nsure compliance with the re vised PEFC 
ST 1003, the schemes we re  subject to an 
e x traordinary assessment in 2013. Both 
sche mes are curre ntly being re viewe d for 
com pliance with PEFC  ST 1003:2018. 
Howe ve r, as of the date of this report, 
this process has not been completed. The 
available standard in these countries 
re m ains the standard developed in 2011, 
based on “Pan European Operational Level 
Guide lines. 

For standards not re vised in the last ye ar 
PEFC  e xplains that the re vision of PEFC’s 
be nchmark re quirements is dire ctly linked 
to the  re vision of PEFC e ndorsed 
sche mes. In view of the re vision of the 
PEFC  1003, which was approved in  2018, 
national schemes whose endorsement 
e x pired on or after 1 January 2017 we re  
offe red an e xtraordinary endorsement 
e x te nsion to facilitate a smooth transition 
to the  2018 standard. All national 
standards are under re view, though there  
have  been delays because of the 
challe nging conditions due to COVID.  A 
num ber of systems are curre ntly already 
be ing assessed, with the consultation 
proce ss ongoing.  

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In addition, the standard for the Republic 
of Ire land explicitly states on the 
guidance for the first indicator that 
"C e rtification is not a legal compliance 
audit." 

C hain of C ustody 

PEFC  has two ve rsions of the standard 
that are  applicable to the supply chain 
e ntitie s: PEFC GD 2001: 2014 and PEFC 
ST 2002:2020. The latest version of the 
C hain of C ustody Standard (PEFC ST 
2002:2020), was approved on 14th of 
Fe bruary of 2020, with a transition period 
of 18 m onths + 6 m onths due to the 
C ovid-19 outbre ak.  

J ustification 

This indicator is concluded as partially 
cove re d. W hile there is a system in place 
for national certification standards to be 
updated to the latest version of the 
inte rnational Be nchmark  Standard PEFC 
ST 1003: 2018, there are currently no 
national standards developed in 
conformance with this standard. As of the 
finalisation of this re port, five n ational 
standards we re  still not updated to the 
pre vious versions of the standard 
(although processes to update all of these 
standards are curre ntly in process). PEFC 
e x plains that national adaptation is an 
ongoing process and a number of 
standards will be  updated to the newe st 
ve rsion of the international Be nchmark 

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C .2.2 

Inte rnation
al 
conve ntion
s and 
tre atie s 

C .2.2.1 The 
Sche m e shall 
include  a list of the 
re le vant 
inte rnational 
conve ntions to 
which the  country 
has ratified, and 
which hold le gal 
force  in the 
country. 

Not 
C ove red 

PEFC  ST 1003: 2018 

F i ndings 

Standard in the near future. 

6. Planning 
6.2 Management plan 
6.2.1 The standard re quires that management plans shall be: 
… 
c) base d on applicable local, national and international legislation as we ll as 
e x isting land-use or other 
official plans; and… 

6.3 C ompliance re quirements 
6.3.1 Legal compliance 
… 

6.3.1.1 The standard re quires that the organisation shall iden tify and have 
acce ss to the legislation applicable to its forest m anagement and determine 
how the se compliance obligations apply to the organisation. 

6.3.1.2 The standard re quires that the organisation shall comply with 
applicable local, national and international legislation on forest 
m anagement, including but not limited to fore st management practice s; 
nature  and environmental protection; protected and endangered species; 
prope rty, tenure and land -use rights for indigenous peoples, local 
com m unities or other affecte d stakeholders; health, labour and safety 
issues; anti-corruption and the payment of applicable royalties and taxes. 

8.2 C rite rion 2: Maintenance of forest ecosystem health and vitality 
8.2.9 The standard re quires that pesticides, such as chlorinated 
hydrocarbons whose derivatives remain biologically active and accumulate in 
the  food chain beyond their intended use, and any pesticides banned by 
inte rnational agreement, shall be prohibited. 
Note : “Pesticides banned by international agreements” are defined in the 
Stock holm Convention on Persistent Organic Pollutants. 

PEFC  ST 2002: 2020 
3.7 C ontroversial source s 

461 

Both the  forest m anagement standard 
PEFC  ST 1003: 2018 and the COC 
standard PEFC ST 1003: 2018 re quest 
national standards (forest management) 
a nd C ertificate holders (chain of custody) 
to cove r applicable international 
le gislation.  

Howe ve r, there is no list developed by 
PEFC  International and there  is no 
re quirement for a list of applicable 
inte rnational conventions to which the 
country has ratified to be developed by 
the  national member/ standard, according 
to PEFC  ST 1001: 2017. 

In both forest management and COC 
ce rtification, the onus on the identification 
of re le vant international conventions and 
le gislation is placed on the certificate 
holder. 

J ustification 

This indicator is concluded as not covered. 
The re  is no re quirement to develop a list of 
the  re le vant international conventions to 
which the  country has ratified, and which 
hold le gal force in the country for fore st 
m anagement or chain of custody 
ce rtification. 

 
 
 
 
 
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C .2.3 

Use  of 
contractors 

C .2.3.1 The 
re quirements for 
fore st managers 
and supply chain 
e ntitie s shall be 
applicable to the 
organisation’s 
contractors and 
outsourcing 
facilitie s. 

Fore st and tre e based material source d from: 
a) Activitie s not complying with applicable local, national or international 
le gislation on forest management, including but not limited to forest 
m anagement practices; nature and e nvironmental protection; protected and 
e ndangered species; property, te nure and land-use rights for indigenous 
pe oples, local communities or other affected stakeholders; health, labour 
and safety issues; anti-corruption and the payment of applicable royalties 
and taxes. 
PEFC  ST 1003: 2018 1. Scope 
This document constitutes PEFC International’s Sustainability Be nchmark for 
PEFC  e ndorsed re gional, national or sub-national standards for the 
sustainable management of forests and Trees outside Forests, covering all 
the ir products and services. Through PEFC en dorsed standards, which are 
de ve loped in a balanced multi-stakeholder process following PEFC 
Inte rnational’s Sustainability Benchmark for standard setting, the 
re quirements outlined in this document apply to owne rs and managers, as 
we ll as contractors and other operators operating in PEFC-certified areas. 
The y cover all necessary processes of a m anagement system that aims at 
sustainable forest management. 

PEFC  ST 2002: 2020, Chapter 4.9 Outsourcing 
4.9.1 The organisation may outsource  activities covere d by its PEFC chain of 
custody to another entity. 4.9.2 Through all stages of outsourcing the 
organisation shall be re sponsible for ensuring that all 
outsourced activities meet the re quirements of this standard, including 
m anagement system  
re quirements. The organisation shall have a writte n agre ement with all 
e ntitie s to whom activities have been outsource d, ensuring that:  
a) The  material/products covered by the organisation’s PEFC chain of 
custody are  physically  
se parated from other material or products. 
b) The  organisation has access to the entity’s site(s) for internal and 
e x te rnal auditing of outsourced activities for conformity with the 
re quirements of this standard. 
Note  1: A te mplate for an outsourcing agre ement can be obtained from the 
PEFC  C ouncil and PEFC authorised bodies. 
Note  2: Internal audits of outsourced activities should be conducted at least 

462 

F i ndings 

C ove red 

Fore st Management 

According to PEFC ST 20013: 2018, 1, the 
standard should be applicable also to 
contractors and other operators operating 
in PEFC -certified are as. 

C hain of custody 
For C O C, According to PEFC ST 2002: 
2020, C hapter 4.9, in case of outsourcing, 
the  ce rtificate holder should ensure that 
all activities by the contractor m eet the 
standard re quirements.  

J ustification 

This indicator is concluded as covered. PEFC 
Inte rnational re quirements include a 
re fe re nce to normative re quirements for 
ce rtificate holders also b eing applicable to 
the  organisation’s contractors and 
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annually and before the  
outsourced activity starts. 

C .2.4 

Endorsing 
and 
re cognisin
g of other 
Sche m es 
and 
syste ms 

C .2.4.1 If the 
Sche m e includes 
the  re cognition or 
e ndorsement of 
othe r schemes or 
syste ms, it shall 
e nsure coverage 
and consistent 
im plementation of 
EUTR  
re quirements at all 
le ve ls. 

C.3 Accreditation and oversight 

C .3.1 

Accre ditation  C .3.1.1 The Scheme 

shall include a 
syste m for 
accre ditation or 
ove rsight of 
C e rtification Bodies 
to e nsure  that C Bs 
have  in place the 
re quire d procedures, 
capacity and 
com petencies. 

F i ndings 

PEFC  International does not e ndorse 3 rd 
party schemes.  

Not 
Applicable 

J ustification 

This indicator is concluded as not applicable. 
PEFC  does not endorse 3 rd party private 
voluntary ce rtification schemes. 

C e rtification and Accre ditation procedure s, 2007 – Annex 6 
C hapter 5 Accre ditation 
C e rtification bodies carrying out forest management or chain of custody 
ce rtification, shall be accre dited by a national accre ditation body so as to 
e nsure the cre dibility of the ce rtification work  and to facilitate mutual 
re cognition. An accredited ce rtificate shall bear an accre ditation symbol of the 
re le vant accreditation body. 

Accre ditation bodies shall be a member of the International Accre ditation 
Forum  (IAF) or a member of IAF’s special re cognition regional groups and 
im plement proce dures described in ISO/IEC 17011:2004(4) and other 
docum ents re cognised by the above organisations. 

The  ce rtification body shall undertake forest management or/and chain of 
custody ce rtification as “accre dited certifications”. 

The  ce rtification body carrying out forest m anagement ce rtification or chain of 

463 

F i ndings 

C ove red 

C e rtification bodies performing audits to 
the  PEFC  Forest Management must be 
inde pendent, objective, and qualified. 
Accre ditation bodies shall be a member of 
the  International Accre ditation Forum 
(IAF) or a member of IAF’s special 
re cognition re gional groups (Annex 6 – 
C e rtification and Accre ditation procedures, 
2007 – C hapter 5). 

The  accre ditation is done based on 
ISO /IEC 17021 for Audits of Integrated 
Management Systems; ISO Guide 65; ISO 
19011; ISO/IEC 17065 and PEFC 
standard re quirements. O nce a 

 
 
 
 
 
 
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custody ce rtification against a scheme specific chain of custody standard shall 
be  accre dited based on 17021(1) or ISO Guide 65(2) and the relevant fore st 
m anagement or chain of custody standard(s) / scheme shall be covered by the 
accre ditation scope. 

ce rtification body successfully completes 
the  accre ditation application program, 
which include s an on-site audit and 
witne ss assessment process, it is granted 
accre ditation by accreditation bodies. 

The  ce rtification body carrying out chain of custody certification against Annex 
4 (C hain of Custody of Forest Based Products – R equirements) shall be 
accre dite d based on ISO Guide 65 (EN 45 011)(2). 
Non-conformance with the  accre ditation requirements, re sults in the 
ce rtification bodies not being re garded as having met PEFC Council 
re quirements and their ce rtifications not be considered as ce rtified for PEFC 
purposes. 

In e x ceptional circumstances, the PEFC Council General Assembly can approve 
a tim e  limited e xemption from the above re quirements based on a writte n 
application from the PEFC National Governing Body. The application shall state 
(i) re asons for re questing the e xemption, (ii) description of how the  cre dibility 
of the  ce rtification process will be  assured including a list of measure s currently 
unde rtaken to ensure the cre dibility. 

PEFC  ST 2003: 2020 
Fore word 
…The  PEFC C ouncil re quires that chain of custody ce rtification shall be carried 
out by  
ce rtification bodies who are accre dited by accre ditation bodies that are 
signatories of the Multilateral  
R e cognition Arrangement (MLA) for product ce rtification of IAF. … 
Introduction 
The  PEFC C ouncil re quires the ce rtification bodies operating chain of custody 
ce rtification meet the  
re quirements of ISO/IEC  17065, PEFC documentation and the re levant 
provisions of ISO 19011 specified in this document. 

6.1.1.2.6 C ompetencies 
6.1.1.2.6.1 The ce rtification body shall ensure  that auditors demonstrate ability 
to apply knowle dge and skills in the following areas: … 
6.1.1.2.6.2 The ce rtification body shall ensure  that auditors demonstrate ability 

464 

C hain of custody 

According to Foreword and Introduction 
chapte rs (PEFC ST 2003: 2020) 
C e rtification bodies that wants provide 
C hain of custody ce rtification should be 
accre dite d by a national accre dited body 
and to follow ISO/IEC 17065 and ISO 
19011 standard together with PEFC  ST 
2003: 2020. At the same time indicators 
from  C hapter 6 and 7 (PEFC ST 2003: 
2020) explains the re quirements re lated 
to the  procedures, capacity and 
com petencies. 

J ustification 

This indicator is concluded as covered. PEFC 
Inte rnational includes a system for 
accre ditation of Certification Bodies. This 
syste m includes re quirements to develop 
proce dure s, capacity and competencies. 

 
 
 
 
 
 
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to apply terminology, knowle dge, understanding and skills in the following 
are as of the PEFC chain of custody: 
6.1.1.2.6.3 The ce rtification body shall maintain e vidence of annual monitoring 
of chain of custody auditors, applying methods such as re viewing audit re ports 
or clie nt organisations’ feedback, e tc. based on the fre quency of their usage 
and the le vel of risk linked to their activities, and periodic witne ss audits.  
In particular, the ce rtification body shall re view the  competence of its 
pe rsonnel in the light of their  
pe rformance  in order to identify training needs. 
7.4.1 The ce rtification body shall have documented procedures to ensure  that 
an audit plan is e stablished 
for e ach audit, to provide a basis for agreement re garding the conduct and 
sche duling of the audit activities. The audit plan s hall be communicated and 
the  dates of the audit shall be agreed upon in advance with the  client 
organisation. 
7.4.3 The ce rtification body shall have documented procedures for selecting 
and appointing the audit 
te am , including the audit te am le ader. 
7.4.7 The ce rtification body shall have documented procedures for determining 
audit time, and for e ach client organisation the ce rtification body shall 
de te rmine, with input from the audit te am, the 
tim e  needed to plan and accomplish a complete and effective audit of the client 
organisation’s PEFC chain of custody. The audit time determined by the 
ce rtification body, and the justification for the determination, shall be recorded. 
The  m inimum time for the on-site audit is four hours, 
this shall not include reporting activities, unless under specific conditions where  
it can be  justified and documented. 
7.4.8 The ce rtification body shall have documented procedures for sampling 
within the  audit  
in accordance with the  guidance provided in ISO 19011:2018, A.6. 

PEFC  GD 1006 
4 C onditions for PEFC notification 
The  ce rtification body applying for PEFC  notification from the PEFC C ouncil 
shall: 
- be  a le gal entity; 
- agre e to be listed on the publicly available PEFC Council Internet database 

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C .3.1.2 The Scheme 
shall e nsure  that the 
re quirements and 
proce ss for 
accre ditation is 
publicly available. 

including the 
ce rtification body’s identification data and / or other data as specified by the 
PEFC  C ouncil; 
- have  valid accre ditation, issued by an accre ditation body that is signatory of 
the  Multilateral Recognition Arrangement (MLA) for product ce rtification of the 
Inte rnational Accre ditation Forum (IAF). The accre ditation shall be issued 
against ISO/IEC 17065:2012 and the scope of the accreditation shall explicitly 
include  PEFC 2002:2010; 
- sign a PEFC notification contract with the  PEFC C ouncil (Appendix 1).  
i) https://www.pe fc.org/for-business/certification-and-accre ditation-
bodies/become-a-pefc-notified-certification-body 

C e rtification and Accre ditation procedure s, 2007 – Annex 6 – Chapter 5 
Accre ditation 
C e rtification  bodie s  carrying out fore st m anage m e nt or chain of custody 
ce rtification, shall be accre dited by a national  accre di t at io n b ody  s o as t o  
e nsure   the   cre dibility  of  the   ce rtification  work   and  to  facilitate   m utual 
re cognition. An accredited ce rtificate shall bear an accre ditation symbol o f  t he  
re le vant accreditation body. 
Accre ditation bodies shall be a member of the  I nt e rn at i onal  A ccre di t at ion  
Forum  (IAF) or a member of IAF’s special re cogn i ti on  re g ion al g ro ups a nd 
im ple m e nt  proce dure s  de scribe d  in  ISO /IEC   17011:2004(4)  and  othe r 
docum ents re cognised by the above organisations. 

C hapter 6. PEFC NO TIFICATION O F CERTIFICATION BO DIES 
C e rtification bodies operating forest management and / o r ch ai n o f cu st od y  
ce rtification against the PEFC endorsed national schemes / st an dards  or t h e  
PEFC  inte rnational chain of custody standard (Annex 4  C h ain  of  C u st ody  of  
Fore st Based Products – Requirements) shall be notified by the PEFC Na t ion al 
Gove rning Body of the re levant country. 
PEFC  ST 2003: 2020 
Fore word 
…The  PEFC C ouncil re quires that chain of custody ce rtification shall be carried 
out by  
ce rtification bodies who are accre dited by accre ditation bodies that are 
signatories of the Multilateral  
R e cognition Arrangement (MLA) for product ce rtification of IAF. … 

466 

F i ndings 

 Partially 
C ove red 

The  m anagement of the scheme is done 
by PEFC  International with support from 
IAF, an organisation allowing the 
organisation to become accreditation 
bodies. Accre ditation bodies, in its turn, 
allowing the organisation to become 
ce rtification bodies. 

IAF allow the  organisation to become 
accre ditation bodies, based on Multilateral 
R e cognition Arrangement (MLA). MLA 
allow to accre ditation bodies to be 
re cognised by other members of the MLA, 
and this proce ss is done based on 
ISO /IEC Guides. The proce dures  related 
to MLA are  publicly available on the 
we bsite  (iv). Howe ver, the standards used 
in the  assessment of an applicant is not 
publicly available.  

The re  are m ultiple accre ditation bodies 
allowe d to accre dit certification bodies. 
According to ISO/IEC 17011:2017 8.2.1, 
accre ditation body shall make publicly 
available information related to the 
accre ditation body and information about 

 
 
 
 
 
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Introduction 
The  PEFC C ouncil re quires the ce rtification bodies operating chain of custody 
ce rtification meet the  
re quirements of ISO/IEC  17065, PEFC documentation and the re levant 
provisions of ISO 19011 specified in this document. 

the  process. Information like, complaints 
and appeals are part of publicly available 
inform ation. According to ISO/IEC 
17011:2017 8.2.2 shall make publicly 
available information on conformity 
assessment bodies. Howe ver, at a quick 
look , some CBs m ay not share all 
inform ation on their we bsite. For 
e x ample, Be larusian State C entre for 
Accre ditation (BSCA); Lithuanian National 
Accre ditation Bureau (LA); R omanian 
Accre ditation Association (RENAR ) do not 
have  a list of ce rtification bodies approved 
by the m . 

For organisation providing Forest 
Management, PEFC international define 
re quirements for C ertification Bodies 
(C e rtification and Accre ditation 
proce dure s, 2007 – Annex 6), that apply 
in addition to Accre ditation re quirements. 
The se requirements are publicly available. 

For organisation providing Chain of 
C ustody, PEFC International define 
re quirements for C ertification Bodies 
(PEFC  ST 2003: 2020), that apply in 
addition to Accre ditation re quirements. 
The se requirements are publicly available. 

For both types of ce rtification (FM a nd 
C oC ) notification procedures re quested in 
orde r to allow C Bs to assess and issue 
C Hs are publicly available. 

J ustification 

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C .3.1.3 The Scheme 
shall make publicly 
available, an up-to-
date  list and details 
of all accre dited 
C e rtification Bodies 

C .3.1.4 The 
Accre ditation Body 
shall have 
m e chanisms to 
e nsure that re levant 
pe rsonnel are 
qualified and 
com petent to 
e valuate Certification 
Body’s performance 
in re lation to Scheme 
re quirements. 

i) https://www.pe fc.org/find-certification-bodies  

F i ndings 

C ove red 

This indicator is concluded as partially 
cove re d. Some of the procedures used for 
accre ditation are publicly available, howe ve r 
not all of them. For e xample, ISO/IEC 17011 
use d by IAF to allow an organisation to 
be come an accreditation body is not public. 

PEFC  GD 2001: 2009 

Introduction 

The  governance of the PEFC scheme is based on the principle of subsidiarity 
and decentralised organisational structure. The administration of the PEFC 
sche me is therefore  executed by the PEFC National Governing Bodies whe re 
the y e x ist or directly by the PEFC Council or other authorised bodies in 
countrie s without PEFC National Governing Bodies. 

3.1 Authorised body 

A list with all ce rtification bodies is 
available on the PEFC Website (i). 
C urre ntly, PEFC Scheme has 145 
C e rtification Bodies. 

J ustification 

This indicator is concluded as covered. The 
list and details of all accredited C ertification 
Bodie s are up to date and publicly available. 

F i ndings 

C ove red 

According to the public documents, 
ISO /IEC 17011:2004 and IAF procedure s 
should be followe d. ISO/IEC  17011:2004 
include  requirements re lated to the 
qualification and competence of 
pe rsonnel. Still, the procedure  used by 
IAF to accre dit national bodies is not 
publicly available. Howe ver, ISO 
re quirements covered the re quirements of 
this indicator. 

An e ntity authorised by the PEFC C ouncil to perform the administration of the 
PEFC  scheme on behalf of the PEFC Council 

J ustification 

C e rtification and Accre ditation Proce dures – Annex 6 

This indicator is concluded as covered. PEFC 
Inte rnational includes a system to ensure 
qualification and competence of National 

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5 Accre ditation 

Accre ditation Bodies. 

C .3.2  

O ve rsight 
m e chanism 

C .3.2.1 The 
Sche m e shall 
e nsure that the 
com petence  and 
consistent 
pe rformance  of 
C e rtification 
Bodie s is regularly 
e valuated.  

Pe rformance shall 
e m ploy both desk-
based AND field 
approaches, 
including: 
i) Stak eholder 
consultation 
ii) In-field 
e valuation of the 
pe rformance  of 
the  C e rtification 
Body, whe ther via 
on-site inspections 
of ce rtified forests/ 
supply chain 
e ntitie s or witne ss 
audits of audit 
pe rsonnel. 

Accre ditation bodies shall be a member of the International Accre ditation 
Forum  (IAF) or a member of IAF’s special re cognition regional groups and 
im plement proce dures described in ISO/IEC 17011:2004(4) and other 
docum ents re cognised by the above organisations. 

Anne x 6 – C ertification and Accre ditation procedures, 2007 – Chapter 5 
Accre ditation 
C e rtification bodies carrying out forest management or chain of custody 
ce rtification, shall be accre dited by a national accre ditation body so as to 
e nsure the cre dibility of the ce rtification work  and to facilitate mutual 
re cognition. An accredited ce rtificate shall bear an accre ditation symbol of the 
re le vant accreditation body. 
Accre ditation bodies shall be a member of the International Accre ditation 
Forum  (IAF) or a member of IAF’s special re cognition regional groups and 
im plement proce dures described in ISO/IEC 17011:2004(4) and other 
docum ents re cognised by the above organisations. 
The  ce rtification body shall undertake forest management or/and chain of 
custody ce rtification as “accre dited certifications”. 
The  ce rtification body carrying out forest m anagement ce rtification or chain of 
custody ce rtification against a scheme specific chain of custody standard shall 
be  accre dited based on 17021(1) or ISO Guide 65(2) and the relevant fore st 
m anagement or chain of custody standard(s) / scheme shall be covered by the 
accre ditation scope. 
The  ce rtification body carrying out chain of custody certification against Annex 
4 (C hain of Custody of Forest Based Products – R equirements) shall be 
accre dite d based on ISO Guide 65 (EN 45 011)(2). 
Non-conformance with the  accre ditation requirements, re sults in the 
ce rtification bodies not being re garded as having met PEFC Council 
re quirements and their ce rtifications not be considered as ce rtified for PEFC 
purposes. 
In e x ceptional circumstances, the PEFC Council General Assembly can 
approve a time limited exemption from the above requirements based on a 
writte n application from the PEFC National Governing Body. The application 
shall state (i) re asons for re questing the e xemption, (ii) description of how 
the  cre dibility of the ce rtification process will be  assured including a list of 

469 

F i ndings 

Partially 
C ove red  

PEFC  International is not dire ctly involved 
in the  oversight mechanism. National 
m e mber are  directly involved in the 
ove rsight mechanism and together with 
ISO  standards the oversight mechanism 
are  e nsured at this level. 

At the  same time, PEFC International may 
provide support to certification bodies and 
run training sessions. Ex ample the draft 
guidance for training certification bodies 
to the  ne we st version of PEFC  CoC 
standard. 

According to Annex 6 – C ertification and 
Accre ditation procedure s, 2007 – C hapter 
5 C e rtification Bodies should be accredited 
by a National Body, member of IAF. IAF 
conducts accre ditation of National Bodies. 
National Bodies, based on multiple ISO 
standards. One standard is ISO 17011, 
which include s re quirements re lated to 
the  pe rformance of C ertification Bodies. 

ISO  17011 includes on-site assessment 
and document re view for the  accre ditation 
proce ss. Stakeholder consultation is not 
part of ISO 17011 standard, and it is also 

 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

m e asures currently undertaken to e nsure the cre dibility. 
PEFC  ST 2003: 2020 
8.1 Internal audits of the ce rtification body 
8.1.1 O n re quest, the re sults of annual internal audits, limited to the 
pe rformance  of PEFC chain 
of custody ce rtification activities, shall be provided to the PEFC C ouncil or 
PEFC  National Governing Body. 

C .3.2.2 The 
Sche m e shall 
include  
re quirements that 
e nsure that the 
ove rsight 
m e chanism applies 
a cle ar basis for:  
i) e stablishing 
conformance;  
ii) raising 
corre ctive  actions 
for non-
conformance, and 
e nsuring closure  
within tim e frames 
to avoid le gal non-
com pliance, and;  
iii) ce rtification 
issue (or 
m aintenance ) 
de cision m aking. 

Anne x 6 – C ertification and Accre ditation procedures, 2007 –  
4. C ER TIFICATION PROCEDURES 
… The  applied auditing procedures shall fulfill or be compatible with the  
re quirements of ISO 19011(3)…. 
C hapter 5 Accre ditation 
C e rtification bodies carrying out forest management or chain of custody 
ce rtification, shall be accre dited by a national accre ditation body so as to 
e nsure the cre dibility of the ce rtification work  and to facilitate mutual 
re cognition. An accredited ce rtificate shall bear an accre ditation symbol of the 
re le vant accreditation body. 
Accre ditation bodies shall be a member of the International Accre ditation 
Forum  (IAF) or a member of IAF’s special re cognition regional groups and 
im plement proce dures described in ISO/IEC 17011:2004(4) and other 
docum ents re cognised by the above organisations. 
The  ce rtification body shall undertake forest management or/and chain of 
custody ce rtification as “accre dited certifications”. 
The  ce rtification body carrying out forest m anagement ce rtification or chain of 
custody ce rtification against a scheme specific chain of custody standard shall 
be  accre dited based on 17021(1) or ISO Guide 65(2) and the relevant fore st 
m anagement or chain of custody standard(s) / scheme shall be covered by the 
accre ditation scope. 
The  ce rtification body carrying out chain of custody certification against Annex 
4 (C hain of Custody of Forest Based Products – R equirements) shall be 
accre dite d based on ISO Guide 65 (EN 45 011)(2). 
Non-conformance with the  accre ditation requirements, re sults in  the 
ce rtification bodies not being re garded as having met PEFC Council 
re quirements and their ce rtifications not be considered as ce rtified for PEFC 

470 

not cove red by Annex 6 – Certification 
and Accre ditation procedure s, 2007. 

J ustification 

This indicator is concluded as partially 
cove re d. PEFC International includes in field 
e valuation, but stakeholder consultation is 
not done for the accre ditation process. 

F i ndings 

Partially 
C ove red  

According to Annex 6 – C ertification and 
Accre ditation procedure s, 2007 – C hapter 
5 C e rtification Bodies should be accredited 
by a National Body, member of IAF. IAF 
allows organisation to become 
Accre ditation bodies, based on multiple 
ISO  standards. O ne standard is ISO 
17011, which includes re quirements 
re late d to the performance of Certification 
Bodie s. At the same time, it is a 
re quirement that ISO 19011 to be 
followe d by C ertification bodies. According 
to ISO  19011, e stablishing conformance; 
raising corre ctive actions for non-
conformance, and e nsuring closure  within 
tim e frames to avoid legal non-
com pliance, and; ce rtification issue (or 
m aintenance ) decision making are 
cove re d. 

Fore st management 

At fore st management, there  are cle ar 
rule s for the certificate holders an d bodies 
on what a non-conformity m eans and how 

 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

purposes. 
In e x ceptional circumstances, the PEFC Council General Assembly can 
approve a time limited exemption from the above requirements based on a 
writte n application from the PEFC National Governing Body. The application 
shall state (i) re asons for re questing the e xemption, (ii) description of how 
the  cre dibility of the ce rtification process will be  assured including a list of 
m e asures currently undertaken to e nsure the cre dibility. 

PEFC  ST 1003: 2018 
10. Im provement 
10.1 Nonconformity and corrective action 
10.1.1 The standard re quire s that whe n a nonconformity occurs, the 
organisation shall: 
a) re act to the nonconformity and, as applicable: i. take action to control 
and corre ct it; 
ii. de al with the consequences; 
b) e valuate the need for action to eliminate the causes of the 
nonconformity, in order that it does not 
re cur or occur e lsewhere , by: 
i. re vie wing the nonconformity; 
ii. de te rmining the causes of the nonconformity; 
iii. de termining if similar nonconformities exist, or could potentially occur;  
c) im plement any action needed; 
d) re vie w the  e ffectiveness of any corrective action taken;  
e ) m ake changes to the management system, if necessary. 
10.1.2 The standard re quire s that corre ctive actions shall be appropriate to 
the  e ffects of the  
nonconformities encountered. 
10.1.3 The standard re quire s that the organisation shall re tain documented 
inform ation as e vidence of: a) the nature of the nonconformities and any 
subsequent actions taken; 
b) the  re sults of any corre ctive action. 
10.2 C ontinual improvement 
The  standard re quires that the suitability, adequacy and e ffectiveness of the 
sustainable forest  
m anagement system and the sustainable management of the fore st shall be 
continuously improved. 

471 

it should be addressed (PEFC ST 1003: 
2018, 10) 

C hain of custody 

For chain of custody, there are cle ar rules 
for the  ce rtificate holders and bodies on 
what a non-conformity means and how it 
should be addressed (PEFC ST 2003: 
2020, 7.6) 

Ge ne ral consideration 

For initial audits, all non-conformities 
shall be closed prior the  issue of 
ce rtificate (PEFC ST 2003: 2018, 7.6.2). 
This is in line with EUTR re quirements, as 
all wood shall be effectively “negligible 
risk ” whe n is imported in EU.  

For re ce rtification audits, only major non-
conformities shall be closed prior the 
issue of certificate. In the case of 
surve illance audits, ce rtification bodies 
shall define a timeframe (up to 3 months 
for m ajor non-conformities and up to the 
ne x t audit for m inor non-conformities). As 
som e of these non-conformities may 
re pre sent an infringement of legislation, 
and there fore not in line with Article  4 of 
R e gulation 995/2010, there is a risk that 
ille gal wood may be placed on the EU 
m ark et without additional m easures for a 
pe riod of 3 or 12 months. 

 
 
 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

J ustification 

This indicator is concluded as partially 
cove re d. PEFC International includes a 
syste m to e nsure the oversight mechanism 
applies to points i) – iii) of this indicator. 
Howe ve r in the case of surveillance and re -
ce rtification audits, the definition of non-
conformities is such that there  is a potential 
risk  that a non-conformity may re present an 
infringement of legislation and that, as a 
re sult, illegal wood may enter the EU market 
without m itigation measures to prevent this 
from  occurring for a period of up to 3 or 12 
m onths. 

PEFC  ST 2003: 2020 
7.6.1 Audit findings shall be classified as major nonconformities, minor 
nonconformities and observations. 
7.6.2 Before granting initial certification, as a minimum, major and minor 
nonconformities shall be corrected and the corrective action(s) verified by 
the certification body. 
7.6.3 Before granting recertification, as a minimum, major 
nonconformities shall be corrected and the corrective action(s) verified by 
the certification body. 
7.6.4 Major and minor nonconformities identified in the audits shall result 
in corrective action(s) 
by the client organisation resolving the nonconformities. The corrective 
action plan, including a timeframe, shall be reviewed and accepted by the 
certification body. The time period for completion of the corrective 
action(s) for major nonconformities identified in surveillance audits and 
their verification by the certification body shall follow the rules of the 
certification body but not exceed three months. Corrective action(s) for 
minor nonconformities identified during recertification and surveillance 
audits shall be verified no later than during the next audit. 

3.4.3 For initial and recertification audits, at the time of the deci s i on 
making process, if any site has a nonconformity, certification shall be 
denied  to  the  whole  multi -site  client  organisation  pending 
satisfactory corrective action. 

C .3.2.3 The 
Sche m e shall 
spe cify the 
approach to be 
use d in oversight, 
e nsuring that the 

Anne x 6 – C ertification and Accre ditation procedures, 2007 – Chapter 6 
PEFC  NO TIFICATION O F CER TIFICATION BO DIES 
C e rtification bodies operating forest management and / or chain of custody 
ce rtification against the PEFC endorsed national schemes / standards or the 
PEFC  inte rnational chain of custody standard (Annex 4 Chain of Custody of 
Fore st Based Products – Requirements) shall be notified by the PEFC 

F i ndings 

C ove red  

According to Annex 6 – C ertification and 
Accre ditation procedure s, 2007 – C hapter 
6, PEFC  considers the independence of 
C e rtification Bodies. At the same time, 
Anne x 6 – C ertification and Accre ditation 

472 

 
 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

ove rsight 
m e chanism is 
inde pendent of the 
C e rtification 
Bodie s being 
assessed.  

C .3.2.4  The 
Sche m e shall 
de fine the 
fre quency of 
ove rsight or the 
proce dure  for 
de te rmining the 
fre quency, 
applicable in the 
case  of risk-based 
ove rsight. 

National Governing Body of the re levant country. 
C e rtification bodies operating chain of custody ce rtification against the PEFC 
inte rnational chain of custody standard (Annex 4 C hain of C ustody of Forest 
Base d Products – Requirements) in countries without a PEFC National 
Gove rning Body shall be notified by the PEFC C ouncil. The PEFC Council can 
also decide to notify ce rtification body operating chain of custody 
ce rtification against the PEFC international chain of custody standard (Annex 
4 C hain of C ustody of Forest Based Products – Requirements) in countries 
with a PEFC  National Governing Body if the notification cannot be issued by 
the  re le vant PEFC National Governing Body. 
In orde r to e nsure the independence  of certification bodies the PEFC 
notification conditions decided by the PEFC National Governing Bodies or by 
the  PEFC  Council shall only cover: 
(a) administrative conditions (e.g. communication o f the ce rtification body 
with the  PEFC  National Governing Bodies or the PEFC C ouncil, transfer of 
inform ation, e tc.), 
(b) financial conditions (fees imposed on ce rtified e ntities), 
(c) com pliance with re quirements for ce rtification bodies verified through 
accre ditation as described in chapter 5. 
The  PEFC notification conditions shall not discriminate against certification 
bodies or cre ate trade obstacles. 
PEFC  ST 2003:2020 
7.6 C e rtification decision 
All the  re quirements given in clause 7.6 of ISO/IEC 17065:2012(E) apply. 

Anne x 6 – C ertification and Accre ditation procedures, 2007 – Chapter 5 
Accre ditation 
C e rtification bodies carrying out forest management or chain of custody 
ce rtification, shall be accre dited by a national accre ditation body so as to 
e nsure the cre dibility of the ce rtification work  and to facilitate mutual 
re cognition. An accredited ce rtificate shall bear an accre ditation symbol of the 
re le vant accreditation body. 
Accre ditation bodies shall be a member of the International Accre ditation 
Forum  (IAF) or a member of IAF’s special re cognition regional groups and 
im plement proce dures described in ISO/IEC 17011:2004(4) and other 
docum ents re cognised by the above organisations. 
The  ce rtification body shall undertake forest management or/and chain of 
custody ce rtification as “accre dited certifications”. 

473 

proce dure s, 2007 and PEFC ST 2003:2020 
re que st compliance  with ISO/IEC 
17011:2004 and ISO/IEC 17065:2012. 
Both ISO  standard contains requirement 
re late d to impartiality and as defined by 
ISO  im partiality is similar to independence 
or fre e  of conflict of interest.TBC  

J ustification 

This indicator is concluded as covered. PEFC 
Inte rnational includes a system, ensuring 
that the  oversight mechanism is 
inde pendent of the C ertification Bodies . 

F i ndings 

C ove red  

According to Annex 6 – C ertification and 
Accre ditation procedure s, 2007 – C hapter 
5 C e rtification Bodies should be accredited 
by a National Body, member of IAF. IAF 
conducts accre ditation of National Bodies. 
National Bodies, based on multiple ISO 
standards. One standard is ISO 17011, 
which include s re quirements re lated to 
the  fre quency of oversight or the 
proce dure  for determining the frequency, 
applicable in the case of risk-based 

 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

ove rsight. 

J ustification 

This indicator is concluded as covered. PEFC 
Inte rnational includes re quirements to 
e nsure the frequency of oversight or the 
proce dure  for determining the frequency. 

The  ce rtification body carrying out forest m anagement ce rtification or chain of 
custody ce rtification against a scheme specific chain of custody standard shall 
be  accre dited based on 17021(1) or ISO Guide 65(2) and the relevant fore st 
m anagement or chain of custody standard(s) / scheme shall be covered by the 
accre ditation scope. 
The  ce rtification body carrying out chain of custody certification against Annex 
4 (C hain of Custody of Forest Based Products – R equirements) shall be 
accre dite d based on ISO Guide 65 (EN 45 011)(2). 
Non-conformance with the  accre ditation requirements, re sults in the 
ce rtification bodies not being re garded as having met PEFC Council 
re quirements and their ce rtifications not be considered as ce rtified for PEFC 
purposes. 
In e x ceptional circumstances, the PEFC Council General Assembly can 
approve a time limited exemption from the above requirements based on a 
writte n application from the PEFC National Governing Body. The application 
shall state (i) re asons for re questing the e xemption, (ii) description of how 
the  cre dibility of the ce rtification process will be  assured including a list of 
m e asures currently undertaken to e nsure the cre dibility. 

C.4 Certification process 

C .4.1 

C om plianc
e  
e valuation 

C .4.1.1 The 
Sche m e shall 
include  
re quirements that 
e nsure that the 
C e rtification 
Bodie s applies a 
cle ar basis for:  
i) e stablishing 
conformance;  
ii) raising 
corre ctive  actions 
for non-
com pliance, and;  
iii) ce rtification 

Anne x 6 – C ertification and Accre ditation procedures, 2007 – Chapter 5 
Accre ditation 
C e rtification bodies carrying out forest management or chain of custody 
ce rtification, shall be accre dited by a national accre ditation body so as to 
e nsure the cre dibility of the ce rtification work  and to facilitate mutual 
re cognition. An accredited ce rtificate shall bear an accre ditation symbol of the 
re le vant accreditation body. 
Accre ditation bodies shall be a member of the International Accre ditation 
Forum  (IAF) or a member of IAF’s special re cognition regional groups and 
im plement proce dures described in ISO/IEC 17011:2004(4) and other 
docum ents re cognised by the above organisations. 
The  ce rtification body shall undertake forest management or/and chain of 
custody ce rtification as “accre dited certifications”. 
The  ce rtification body carrying out forest m anagement ce rtification or chain of 
custody ce rtification against a scheme specific chain of custody standard shall 

F i ndings 

C ove red  

According to Annex 6 – C ertification and 
Accre ditation procedure s, 2007 – C hapter 
5 C e rtification Bodies should be accredited 
by a National Body, member of IAF. IAF 
allows organisation to become 
Accre ditation bodies, based on multiple 
ISO  standards. O ne standard is ISO 
17011, which includes re quirements that 
e nsure that the Certification Bodies 
applies a clear basis for i) – iii). 

J ustification 

474 

 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

de cision m aking. 

C .4.1.2 The 
Sche m e 
re quirements for 
e stablishing 
conformance 
should enable 
com parison with 
the  de finition of 
ne gligible and 
non-negligible risk 
as outlined in the 
EUTR  and 
associated guides.  

be  accre dited based on 17021(1) or ISO Guide 65(2) and the relevant fore st 
m anagement or chain of custody standard(s) / scheme shall be covered by the 
accre ditation scope. 
The  ce rtification body carrying out chain of custody certification against Annex 
4 (C hain of Custody of Forest Based Products – R equirements) shall be 
accre dite d based on ISO Guide 65 (EN 45 011)(2). 
Non-conformance with the  accre ditation requirements, re sults in the 
ce rtification bodies not being re garded as having met PEFC Council 
re quirements and their ce rtifications not be considered as ce rtified for PEFC 
purposes. 
In e x ceptional circumstances, the PEFC Council General Assembly can 
approve a time limited exemption from the above requirements based on a 
writte n application from the PEFC National Governing Body. The application 
shall state (i) re asons for re questing the e xemption, (ii) description of how 
the  cre dibility of the ce rtification process will be  assured including a list of 
m e asures currently undertaken to e nsure the cre dibility. 
Anne x 6 – C ertification and Accre ditation procedures, 2007 –  
4. C ER TIFICATION PROCEDURES 
… The  applied auditing procedures shall fulfill or be compatible with the  
re quirements of ISO 19011(3)…. 
C hapter 5 Accre ditation 
C e rtification bodies carrying out forest management or chain of custody 
ce rtification, shall be accre dited by a national accre ditation body so as to 
e nsure the cre dibility of the ce rtification work  and to facilitate mutual 
re cognition. An accredited ce rtificate shall bear an accre ditation symbol of the 
re le vant accreditation body. 
Accre ditation bodies shall be a member of the International Accre ditation 
Forum  (IAF) or a member of IAF’s special re cognition regional groups and 
im plement proce dures described in ISO/IEC 17011:2004(4) and other 
docum ents re cognised by the above organisations. 
The  ce rtification body shall undertake forest management or/and chain of 
custody ce rtification as “accre dited certifications”. 
The  ce rtification body carrying out forest m anagement ce rtification or chain of 
custody ce rtification against a scheme specific chain of custody standard shall 
be  accre dited based on 17021(1) or ISO Guide 65(2) and the relevant fore st 
m anagement or chain of custody standard(s) / scheme shall be covered by the 
accre ditation scope. 

475 

This indicator is concluded as covered. PEFC 
Inte rnational includes re quirements that 
e nsure that the Certification Bodies applies a 
cle ar basis for e stablishing conformance; 
raising corre ctive actions; ce rtification 
de cision m aking. 

F i ndings 

C ove red  

According to Annex 6 – C ertification and 
Accre ditation procedure s, 2007 – C hapter 
5 C e rtification Bodies should be accredited 
by a National Body, member of IAF. IAF 
allows organisation to become 
Accre ditation bodies, based on multiple 
ISO  standards. O ne standard is ISO 
17011, which includes re quirements 
re late d to the performance of Certification 
Bodie s. At the same time, it is a 
re quirement that ISO 19011 to be 
followe d by C ertification bodies. According 
to ISO  19011, e stablishing conformance; 
raising corre ctive actions for non-
conformance, and e nsuring closure  within 
tim e frames to avoid legal non-
com pliance, and; ce rtification issue (or 
m aintenance ) decision making are 

 
 
 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

cove re d. 

Fore st management 

At fore st management, there  are cle ar 
rule s for the certificate holders and bodies 
on what a non-conformity m eans and how 
it should be addressed (PEFC ST 1003: 
2018, 10) 

C hain of custody 

For chain of custody, there are cle ar rules 
for the  ce rtificate holders and bodies on 
what a non-conformity means and how it 
should be addressed (PEFC ST 2003: 
2020, 7.6) 

J ustification 

This indicator is concluded as covered. PEFC 
Inte rnational includes a system to assess 
conformity with the standard.  

The  ce rtification body carrying out chain of custody certification against Annex 
4 (C hain of Custody of Forest Based Products – R equirements) shall be 
accre dite d based on ISO Guide 65 (EN 45 011)(2). 
Non-conformance with the  accre ditation requirements, re sults in the 
ce rtification bodies not being re garded as having met PEFC Council 
re quirements and their ce rtifications not be considered as ce rtified for PEFC 
purposes. 
In e x ceptional circumstances, the PEFC Council General Assembly can 
approve a time limited exemption from the above requirements based on a 
writte n application from the PEFC National Governing Body. The application 
shall state (i) re asons for re questing the e xemption, (ii) description of how 
the  cre dibility of the ce rtification process will be  assured including a list of 
m e asures currently undertaken to e nsure the cre dibility. 

PEFC  ST 1003: 2018 
10. Im provement 
10.1 Nonconformity and corrective action 
10.1.1 The standard re quire s that whe n a nonconformity occurs, the 
organisation shall: 
a) re act to the nonconformity and, as applicable: i. take action to control 
and corre ct it; 
ii. de al with the consequences; 
b) e valuate the need for action to eliminate the causes of the 
nonconformity, in order that it does not 
re cur or occur e lsewhere , by: 
i. re vie wing the nonconformity; 
ii. de te rmining the causes of the nonconformity; 
iii. de termining if similar nonconformities exist, or could potentially occur;  
c) im plement any action needed; 
d) re vie w the  e ffectiveness of any corrective action taken;  
e ) m ake changes to the management system, if necessary. 
10.1.2 The standard re quire s that corre ctive actions shall be appropriate to 
the  e ffects of the  
nonconformities encountered. 
10.1.3 The standard re quire s that the organisation shall re tain documented 
inform ation as e vidence of: a) the nature of the nonconformities and any 
subsequent actions taken; 

476 

 
 
 
ANNEX 4 : SCHEME ASSESSMENT REPORT – PEFC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

b) the  re sults of any corre ctive action. 
10.2 C ontinual improvement 
The  standard re quires that the suitability, adequacy and e ffectiveness of the 
sustainable forest  
m anagement system and the sustainable management of the fore st shall be 
continuously improved. 

PEFC  ST 2003: 2020 

7 .6.1 Audit findings shall be classified as major nonconformities, minor 

nonconformities and observations. 
7 .6.2 Be fore  granting initial ce rtification, as a minimum, m ajor and minor 
nonconformities shall be corrected and the corrective action(s) ve rified by the 
ce rtification body. 
7 .6.3 Be fore  granting re certification, as a m inimum, major nonconformities 
shall be corrected and the corrective action(s) ve rified by the certification 
body. 
7 .6.4 Major and minor nonconformities identified in the audits shall result in 
corre ctive  action(s) 
by the  clie nt organisation re solving the nonconformities. The corrective 
action plan, including a timeframe, shall be re viewe d and acce pted by the 
ce rtification body. The time period for completion of the corrective action(s) 
for m ajor nonconformities identified in surve illance audits and their 
ve rification by the ce rtification body shall follow the  rules of the ce rtification 
body but not e xceed three months. Corre ctive action(s) for minor 
nonconformities identified during re certification and surveillance audits shall 
be  ve rified no later than during the next audit. 

3 .4.3 For initial and re certification audits, at t h e  t i m e  o f t h e  de ci s ion  
m ak ing process, if any site has a nonconformity, ce rt i f ica ti on  sh all  b e  
de nied to the whole multi-site client organisation pendi ng s at i sf act ory  
corre ctive  action. 

PEFC  ST 2003: 2020 
3.5 Major nonconformity 
The  absence of, or failure  to implement and maintain, one or m ore 
re quirements of the Chain of Custody standard, that may re sult in a 
syste mic risk to the function and effectiveness of the chain of custody 
and/or affect confidence in the clie nt organisation’s claims on ce rtified raw 

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C ode 

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I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

C .4.1.3 The 
Sche m e shall 
include  
re quirements that 
e nsure that the 
above 
re quirements are  
in line  with the  
re quirements of 
the  EUTR to 
prohibit illegal 
m ate rial or 
m ate rial with a 
non-negligible risk 
cate gory being 
place d on the EU 
m ark et. 

m ate rial. 
Note : A m ajor nonconformity m ay be an individual nonconformity, or a 
num ber of minor but related  
nonconformities that whe n considered in total are judged to constitute a 
m ajor nonconformity. 
3.6 Minor nonconformity 
A single  failure  to fulfil the re quirements of the C hain of C ustody standard 
that m ay re sult in no systemic risk to the function and e ffectiveness of the 
chain of custody and/or affect confidence in the supplier’s claims on ce rtified 
raw m ate rial. 

Anne x 6 – C ertification and Accre ditation procedures, 2007 –  
4. C ER TIFICATION PROCEDURES 
… The  applied auditing procedures shall fulfill or be compatible with the  
re quirements of ISO 19011(3)…. 
C hapter 5 Accre ditation 
C e rtification bodies carrying out forest management or chain of custody 
ce rtification, shall be accre dited by a national accre ditation body so as to 
e nsure the cre dibility of the ce rtification work  and to facilitate mutual 
re cognition. An accredited ce rtificate shall bear an accre ditation symbol of the 
re le vant accreditation body. 
Accre ditation bodies shall be a member of the International Accre ditation 
Forum  (IAF) or a member of IAF’s special re cognition regional groups and 
im plement proce dures described in ISO/IEC 17011:2004(4) and other 
docum ents re cognised by the above organisations. 
The  ce rtification body shall undertake forest management or/and chain of 
custody ce rtification as “accre dited certifications”. 
The  ce rtification body carrying out forest m anagement ce rtification or chain of 
custody ce rtification against a scheme specific chain of custody standard shall 
be  accre dited based on 17021(1) or ISO Guide 65(2) and the relevant fore st 
m anagement or chain of custody standard(s) / scheme shall be covered by the 
accre ditation scope. 
The  ce rtification body carrying out chain of custody certification against Annex 
4 (C hain of Custody of Forest Based Products – R equirements) shall be 
accre dite d based on ISO Guide 65 (EN 45 011)(2). 
Non-conformance with the  accre ditation requirements, re sults in the 
ce rtification bodies not being re garded as having met PEFC Council 

478 

F i ndings 

Partially 
C ove red 

According to Annex 6 – C ertification and 
Accre ditation procedure s, 2007 – C hapter 
5 C e rtification Bodies should be accredited 
by a National Body, member of IAF. IAF 
allows organisation to become 
Accre ditation bodies, based on multiple 
ISO  standards. O ne standard is ISO 
17011, which includes re quirements 
re late d to the performance of Certification 
Bodie s. At the same time, it is a 
re quirement that ISO 19011 to be 
followe d by C ertification bodies. According 
to ISO  19011, e stablishing conformance; 
raising corre ctive actions for non-
conformance, and e nsuring closure  within 
tim e frames to avoid legal non-
com pliance, and; ce rtification issue (or 
m aintenance ) decision making are 
cove re d. 

Fore st management 

At fore st management, there  are cle ar 
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C onclusion 

re quirements and their ce rtifications not be considered as ce rtified for PEFC 
purposes. 
In e x ceptional circumstances, the PEFC Council General Assembly can 
approve a time limited exemption from the above req uirements based on a 
writte n application from the PEFC National Governing Body. The application 
shall state (i) re asons for re questing the e xemption, (ii) description of how 
the  cre dibility of the ce rtification process will be  assured including a list of 
m e asures currently undertaken to e nsure the cre dibility. 

PEFC  ST 1003: 2018 
10. Im provement 
10.1 Nonconformity and corrective action 
10.1.1 The standard re quire s that whe n a nonconformity occurs, the 
organisation shall: 
a) re act to the nonconformity and, a s applicable: i. take action to control 
and corre ct it; 
ii. de al with the consequences; 
b) e valuate the need for action to eliminate the causes of the 
nonconformity, in order that it does not 
re cur or occur e lsewhere , by: 
i. re vie wing the nonconformity; 
ii. de te rmining the causes of the nonconformity; 
iii. de termining if similar nonconformities exist, or could potentially occur;  
c) im plement any action needed; 
d) re vie w the  e ffectiveness of any corrective action taken;  
e ) m ake changes to the management system, if necessary. 
10.1.2 The standard re quire s that corre ctive actions shall be appropriate to 
the  e ffects of the  
nonconformities encountered. 
10.1.3 The standard re quire s that the organisation shall re tain documented 
inform ation as e vidence of: a) the nature of the nonconformities and any 
subsequent actions taken; 
b) the  re sults of any corre ctive action. 
10.2 C ontinual improvement 
The  standard re quires that the suitability, adequacy and e ffectiveness of the 
sustainable forest  
m anagement system and the sustainable management of the fore st shall be 

on what a non-conformity m eans and how 
it should be addressed (PEFC ST 1003: 
2018, 10) 

C hain of custody 

For chain of custody, there are cle ar rules 
for the  ce rtificate holders and bodies on 
what a non-conformity means and how it 
should be addressed (PEFC ST 2003: 
2020, 7.6) 

Ge ne ral consideration 

For initial audits, all non-conformities 
shall be closed prior the  issue of 
ce rtificate (PEFC ST 2003: 2018, 7.6.2). 
This is in line with EUTR re quirements, as 
all wood shall be effectively “negligible 
risk ” whe n is imported in EU.  

For re ce rtification audits, only major non-
conformities shall be closed prior the 
issue of certificate. In case of surveillance 
audits, ce rtification bodies shall define a 
tim e frame (up to 3 months for m ajor non-
conformities and up to the next audit for 
m inor non-conformities. As some of these 
non-conformities may re present an 
infringement of legislation, and therefore 
not in line with Article  4 of R egulation 
995/2010, illegal wood m ay enter without 
additional measures for a period of 3 or 
12 m onths. 

J ustification 

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C ode 

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C onclusion 

This indicator is concluded as partially 
cove re d. PEFC International includes a 
syste m to assess conformity with the  
standard. Howe ver, in case of surveillance 
audits and re-certification the definition of 
non-conformities is such that there is a 
pote ntial risk that a non-conformity m ay 
re pre sent an infringement of legislation. In 
this case, as a re sult, illegal wood m ay enter 
the  EU m arket without mitigation measure s 
to pre ve nt this from occurring for a period of 
up to 3 or 12 months. 

continuously improved. 

PEFC  ST 2003: 2020 
7.6.1 Audit findings shall be classified as major nonconformities, minor 
nonconformities and observations. 
7.6.2 Be fore granting initial ce rtification, as a minimum, m ajor and minor 
nonconformities shall be corrected and the corrective action(s) ve rified by 
the  ce rtification body. 
7.6.3 Be fore granting re certification, as a m inimum, major nonconformities 
shall be corrected and the corrective action(s) ve rified by the certification 
body. 
7.6.4 Major and minor nonconformities identified in the audits shall result in 
corre ctive  action(s) by the client organisation re solving the nonconformities. 
The  corre ctive action plan, including a timeframe, shall be re viewe d and 
acce pte d by the ce rtification body. The time period for completion of the 
corre ctive  action(s) for major nonconformities identified in surveillance 
audits and their ve rification by the certification body shall follow the  rules of 
the  ce rtification body but not e xceed three months. Corre ctive action(s) for 
m inor nonconformities identified during rece rtification and surveillance 
audits shall be verified no later than during the next audit. 

3 .4.3 For initial and re certification audits, at t h e  t i m e  o f t h e  de ci s ion  
m ak ing process, if any site has a nonconformity, ce rt i f ica ti on  sh all  b e  
de nied to the whole multi-site client organisation pendi ng s at i sf act ory  
corre ctive  action. 

C .4.1.4 the 
Sche m e shall 
include  
re quirements that 
e nsure that the 
de cision process to 
ce rtify 
organisations, or 
m aintain 
ce rtification of 
C Hs, is free from 
conflict of intere st 

C e rtification and Accre ditation procedure s, 2007 – Annex 6 – Chapter 5 
Accre ditation 
C e rtification  bodie s  carrying out fore st m anage m e nt or chain of custody 
ce rtification, shall be accre dited by a national  accre di t at io n b ody  s o as t o  
e nsure   the   cre dibility  of  the   ce rtification  work   and  to  facilitate   m utual 
re cognition. An accredited ce rtificate shall bear an accre ditation symbol o f  t he  
re le vant accreditation body. 
Accre ditation bodies shall be a member of the  I nt e rn at i onal  A ccre di t at ion  
Forum  (IAF) or a member of IAF’s special re cogn i ti on  r e g ion al g ro ups a nd 
im ple m e nt  proce dure s  de scribe d  in  ISO /IEC   17011:2004(4)  and  othe r 
docum ents re cognised by the above organisations. 

F i ndings 

C ove red 

According to the C ertification and 
Accre ditation procedure s (Chapter 5) 
accre ditation of Certification Bodies is 
based ISO17011. ISO re quirements has a 
spe cial chapter speaking about the 
im partiality of activities conducted by 
C e rtification Body. 

J ustification 

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and includes 
che ck s and 
balances. 

ISO  re quirements (standard is not public) 

This indicator is concluded as covered. The 
de cision process to certify organisations or 
m aintain of ce rtification is free from conflict 
of inte rest and includes checks and 
balances. 

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Annex 5: Scheme Assessment  Report 
Forest Stewardship Council (FSC) 

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Table of Contents 

Summary .................................................................................................................. 484 

Introduction............................................................................................................... 490 

Acronyms ................................................................................................................. 491 

1.  Overview of Certification Scheme ................................................................... 492 

2.  About this report ............................................................................................... 498 

2.1. Report structure ............................................................................................. 498 

2.2. Overview of the certification standards used for this analysis  ................... 499 

3.  Evaluation methodology................................................................................... 501 

4.  Overview of findings ......................................................................................... 502 

5.  Evaluation ......................................................................................................... 512 

A. Requirements for Certificate Holders  ............................................................. 512 

A.1a Legal  Requirements  at the forest level  – Forest management 
certification ........................................................................................................ 512 

A.1b  Legal  Requirements at the forest level  – Input  from non-certified  forest 
(Controlled Wood) ................................................................................................ 557 

A.2a Legal requirements for supply chain entities – Certificate holders  ........... 597 

A.2b  Legal  requirements  for supply  chain entities  – Non-certified  supply  chains
 .............................................................................................................................. 607 

A.3 Requirements for material control ................................................................ 616 

A.4 General requirements for Certificate Holders  .............................................. 631 

A.5 Quality and procedural requirements for Certificate Holders ...................... 636 

B. Requirements for Certification Bodies ............................................................ 642 

B.1 General Certification Body requirements ..................................................... 642 

B.2 Certification Body requirements for auditing and certification  .................... 651 

C. Requirements for Certification Schemes ....................................................... 669 

C.1 Transparency................................................................................................. 669 

C.2 Scheme & standard scope............................................................................ 683 

C.3 Accreditation and oversight  ................................................................... 689 

C.4 Certification process...................................................................................... 697 

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Summary 

The scheme  

The  Forest  Stewardship  Council  (FSC)  is  one  of  the  world’s  largest  voluntary  forest 
certification schemes with over 220 million certified hectares and 45,000 certified supply 
chain entities. It is also one of the oldest, having been legally established in 1994.  

FSC operates a third-party system, whereby its main functions are to set the normative 
requirements and guidance, and to manage the strategic direction and day to day running 
of the scheme. Assurance Services International (ASI) conducts assessments and issues 
accreditations to independent Certification Bodies which, in turn, conduct assessments 
and issue certificates. Organisations can apply for certification at the forest and supply 
chain levels, from smallholders and community groups to large fore stry companies, from 
sawmills, to traders, manufacturers and printers. Evaluations of both Certificate Bodies 
and Certificate Holders are performance-based and, thus, include field and witness audits.    

FSC operates two approaches to certification: i) cer tification at the forest management 
level and the supply chain level; and ii) a risk-based approach to managing non -certified 
materials to FSC claim, through the Controlled Wood programme.  

FSC’s Principles and Criteria for Forest Stewardship standard (FSC-STD-01-001), is the 
principal forest management (FM) standard for the scheme. It is an international standard 
based on 10 principles and 70 criteria. The current version of this standard is version 5 -2, 
published in July 2015.  

The international standard  of Principles and Criteria is adapted to regional or national 
certification  standards  by  local  balanced  working  groups following detailed processes 
mandated by FSC, including consultation with a full range of stakeholders.  

FSC’s Chain of Custody Certification (CoC) standard, FSC-STD-40-004 V3.0, is also a 
global  standard,  applied  as is, to all supply chain entities wishing to sell FSC certified 
products with an FSC claim.  

The FSC scheme includes the FSC Controlled Wood (CW) system, of which the principal 
standard is Requirements for Sourcing FSC Controlled Wood (FSC-STD-40-005 V3-1). 
This system allows for the use of non-certified, yet ‘controlled’, wood material to be mixed 
with FSC-certified material, in the manufacture of FSC-certified products. FSC Controlled 
Wood  basically  comprises  a  due  diligence  system  which  is  put  in  place by FSC CoC 
certified supply-chain companies, in order to avoid that any non-certified material entering 
into production derives from five different categories of ‘unacceptable so urces’. T he first 
category of unacceptable sources is illegally harvested wood.  

Once the sources of non-certified material have been assessed for risks of deriving from 
the unacceptable sources, and any identified risks have been mitigated, the raw materi al 
is considered to be ‘controlled’. The FSC Controlled Wood standard is a global standard 
that  mandates  the  use  of  National  Risk  Assessments  which  have  been  developed 
according to FSC’s detailed procedure and which also often contain defined mandatory 
risk mitigation actions. 

Besides  via  the  use  of  a  due  diligence  process  at  the supply chain level, ‘Controlled 
Wood’  material  can  also  enter  into  the  FSC  system  via  certification  at  the  forest 
management (FM) level. In this case, the FM Controlled Wood standa rd (FSC-STD-30-
010 V2-0 FSC Controlled Wood Standard for Forest Management Enterprises)  is applied 
to a forest area, using a similar approach to the FM standard with field audits. The FM CW 
standard is not adapted to the national context in the same way.  

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Whether in relation to FM certification or FM CW certification, reduced requirements exist 
for  Small  and  Low  Intensity  Managed  Forests  (SLIMFs).  SLIMFs  are  also  subject  to 
reduced  requirements  for  external  auditing.  Within  the  FSC  system,  groups  of  small 
organisations (both at the forest and supply chain levels) may seek group (FM or COC) 
certification, which carries with it the advantage of reducing the intensity of external audits 
by the Certification Body (and therefore external costs of certification).   

Finally,  the  FSC  system  provides  for  the  inclusion  of  recycled timber via a dedicated 
Reclaimed Wood standard (Sourcing reclaimed material for use in FSC Product Groups or 
FSC Certified Projects, FSC-STD-40-007 V2-0) which is applied at the supply chain level.  

Overall findings  

Out  of  the  120  indicators  of  the  scheme  assessment  framework  evaluated  within the 
study, 85 were concluded as Covered, 21 as Partially Covered and 12 as Not Covered. 2 
indicators  were  concluded  as  Not  Applicable.  FSC  is  a  fully  developed  scheme  with 
systems for transparency and oversight built in. There are mostly robust processes and 
systems in place, covering all the key components of the certification scheme.  

It  should  be  noted  that this report reflects an evaluation that has  only considered the 
normative and guidance documents relevant to the scheme, along with the websites of 
FSC  and  ASI.  Consideration  of  impact  studies  and  other  information  relating  to  the 
performance  of  certification  schemes  in  general,  are  included  in  a Me ta-report which 
brings together findings in relation to all five schemes.  

Coverage by the scheme of legal requirements at the forest level  

The  first  part  of  this  study  addressed  legal  requirements at the forest level for  forest 
management certification, evaluating how FSC ensures that Certificate Holders comply 
with all applicable legislation. Importantly, the study concluded that legal requirements at 
the forest level are largely Covered by both FSC FM and FM CW certification. Of the 27 
indicators assessed, 24 were concluded as Covered, while 3 were concluded as Partially 
Covered.  

The  partially  covered  indicators  related  to  aspects  of  legal  requirements  concerning 
concession  licenses, land area taxes/fees and requirements to control potential illegal 
activities by third parties within the area managed by the operation. Some of the identified 
gaps related to small ambiguities or omissions in requirements, where a concern included 
within the Scheme Assessment Framework was not explicitly specified in FSC standard 
requirements. 

The principal international forest management (FM) standard for the scheme,  Principles 
and Criteria for Forest Stewardship (FSC-STD-01-001 v5.2), is effectively an international 
standard.  FSC  requires  that  this  standard  be  adapted  to  the  national  or subnational 
context in which it is being implemented by forest organisations. For most indicators in this 
study, the findings of the evaluation of the four national forest management standards 
corroborated the findings of the international  level for forest management certification. 
This  was  particularly  the  case  in  the  evaluation  of  the  China,  Romania  and  Russia 
national standards (with one exception in the Romanian standard), as these have been 
adapted to reflect the requirements of the latest version of the international FM standard. 
In the case of Brazil, three national standards (for different forest types) were evaluated, 
although  they  have  yet  to  be  adapted  to  meet  the  latest  version  of  the  international 
Principles  and  Criteria.  As  a  result,  there  was  less  alignment  with  international  FM 
standard requirements. 

Information provided by FSC shows that, to date, 40 countries have an approved national 
standard which has been updated from the previous version ( version 4-0) to the current 
version of the international Principles and Criteria. For another 38 countries the process is 

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ongoing, to be completed in 2021 according to FSC International. However, the delays in 
updating  all  National  Forest  Stewardship  Standards  (NFSS)  to  meet  the  updated 
international Principles and Criteria represents a gap in the FSC system. 

There  are  streamlined  certification  procedures  for  Small  and  Low  Intensity  Managed 
Forests (SLIMFs) that meet FSC eligibility criteria. The specialised SLIMFs approach to 
certification  was  also  evaluated  within  the  scope  of  this  study,  along  with  group 
certification  models.  They  were  generally  deemed  not  to  impact  the  integrity  of  the 
system.  

The first part of this study also addressed legal requirements at the forest level  for non-
certified material entering the FSC system via Controlled Wood due diligence systems.  
These due diligence systems are implemented by CoC certificate holders. Fully, all 26 
indicators concerning legal requirements at the forest level were evaluated as Covered . 
This indicates that FSC ensures that forest organisations within the Country of Harvest 
which are included within a Controlled Wood due diligence system, are comprehensively 
evaluated for legal requirements at the forest level. 

Coverage by the scheme of legal requirements at the supply chain level  

Two gaps in the FSC system were found at the supply chain level, where several legal 
requirements  covering  trade  and transport in so far as the forest sector is concerned 
(applicable to the country of harvest, in the context of this study) were not covered or only 
partially covered.  

Firstly,  the  study  addressed  requirements  for  legal  compliance  by  Certificate holders 
which are supply chain entities, focussing on the FSC CoC standard. This standard is 
applicable to all certified supply chain entities within the FSC system. Of the 10 indicators 
evaluated,  only  1  was  concluded  as  Covered,  7  as  Partially  Covered,  while 2 as Not 
Covered. This is considered a significant gap within the FSC system. 

The normative requirements of the CoC standard do require Certificate holders to ensure 
the import/export of FSC certified products conforms to all applicable trade and customs 
laws. However, broadly, the language of the requirements is such that they either did not  
fully cover the indicators in this framework, or there were some omissions in relation to 
specific areas of trade law. For example, Certificate holders are not required to comply 
with legislation concerning business registration, nor value-added taxes and  other sales 
taxes.  Other  areas  which  were  only  partially  covered,  include  compliance  with  laws 
pertaining to transport of wood-products, offshore trading or transfer pricing. Full coverage 
was concluded in relation to compliance with customs regulations.  

The  second  significant  gap  is  within  the  due  diligence  requirements  for  non -certified 
material  entering  the  FSC  system,  that  form  part  of  the  FSC  Controlled  Wood 
requirements for supply-chain entities. Here, the risk of illegal trade and transport within 
the country of origin is not considered at all. The FSC Controlled Wood system limits the 
due diligence process to the evaluation of risks of legal non-compliance at the forest level 
and  to  the evaluation of risks pertaining to the mixing of controlled woo d with wood of 
illegal or unknown origin. As a result, of the 10 indicators within this principle, all were 
evaluated as Not Covered. 

Material control 

Of the 7 indicators evaluated in relation to material control, 5 were concluded as Covered 
and 2 as Partially Covered, 

Via the FSC CoC standard and other normative requirements, the FSC system maintains 
a  system  of  material  control,  tracking  and traceability, similar to other fully developed 
certification  schemes.  This  system  includes  systematic  processes  to   enable  the 

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identification of the country of harvest of the material as well as the species included in 
certified  materials  or  products.  Clear  systems  and  measures  are  required  to prevent 
material from non-negligible risk, unverified or potentially illegal sources from entering the 
supply chain and mixing with conforming material. 

Where  there  is  suspicion  or  concerns  regarding  inaccuracy  in  relation  to  volumes of 
products  or  materials  sold  with  FSC  claims,  FSC  conducts  mechanisms  such  as 
transaction verification investigations, in which the traded volumes along supply-chains 
are  analysed.  Transaction  verifications  – led by Accreditation Services International  – 
comprise  a number of investigative activities, including volume data analysis and fibre 
testing.95 These programs provide important and valuable support to ensuring the integrity 
of the FSC system in relation to material control.  

However, the validation of volumes transferred from seller to purchaser is not conducted 
systematically by FSC on an ongoing basis across all supply chains, which means that 
risks  exist  of  errors  -  or  even  fraudulent  activity  –  in  relation to the volumes of FSC-
certified products sold along supply chains. This is considered as a major gap in the F SC 
system. However, it is not a concern specific to FSC, but many of the schemes evaluated 
within this study. It is also one which FSC is aware of, and the scheme is exploring ways 
of improving supply chain integrity, such as via the use of Blockchain technology, although 
these improvements are still under development.  

A further gap to be noted regards reclaimed timber. FSC descriptions of pre -consumer 
material described in Annexes I and II of the FSC reclaimed materials standard FSC -STD-
40-007,  do  not  entirely  align  with  the  definition  of  waste material as defined in  – and 
excluded from the requirements of – the EU Timber Regulation and associated guidance 
documents.  This  discrepancy  between  FSC  and  EU  definitions  means  material  might 
enter the FSC system without the required due diligence. 

Other requirements for certificate holders 

FSC was evaluated according to 9 indicators concerning conflict resolution, corruption and 
other  quality  and  procedural  requirements  for  Certificate  Holders.  Of  these,  6  were 
concluded as Covered, 2 as Partially Covered and one as Not Applicable. 

Importantly,  covered  indicators  included  general  requirements  for  certificate  holders 
relating to conflict resolution and the control of corruption are addressed within the F SC 
system.  FSC  has  requirements  to  ensure  that  disputes  –  including  those  relating  to 
customary  tenure  rights  -  are  identified,  recorded,  and  managed  in  a  robust  and 
transparent way. This includes the cessation of operations whilst disputes of a significant 
magnitude or duration are being resolved.  

Other  quality  and  procedural  requirements  for  Certificate  Holders  were  assessed  as 
mostly covered by the system, including requirements for Certificate Holders to have in 
place  -  and  implement  -  systems  and  procedures  covering  all  requirements  of  the 
Scheme. However, some gaps were identified: a minor issue in relation to qualifications 
and competencies, as well as the fact that FSC only includes requirements for Certificate 
Holders to regularly review (internally) the proper functioning of their own pro cedures, in 
the  case  of  certification  at  the forest level and in relation to the controlled wood DDS 
implemented according to standard FSC-STD-40-005. The scheme does not require the 
same of CoC-certified companies, certified to FSC-STD-40-004 only. 

In relation to requirements for risk-based approaches to sourcing (Due Diligence Systems) 
for non-certified material, FSC was concluded as covering all the quality indicators. T he 
scheme  includes  clear  requirements  to  ensure  consistent  implementation  of  the  Due 

95 see https://fsc.org/en/innovation/blockchain; https://fsc.org/en/supply-chains and https://fsc.org/en/unacceptable-activities  

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Diligence System and ensures that risks are assessed and mitigated prior to shipping and 
sale.  

The DDS comprises a quality management system; procedures for obtaining access to 
information pertinent to the identification of risk; risk assessments, and the  implementation 
of  mitigations  measures when risks are identified. In relation to risk assessments, one 
important  factor  is  the  requirement  that  certificate  holders  are  obliged  to  use  a  risk 
assessment that has been developed by FSC according to their own  procedures which 
determine the methodology for developing, maintaining and approving risk assessments.  

Requirements for Certification Bodies 

Of the 9 indicators covering quality requirements for Certification Bodies were generally 
evaluated as Covered (7 indicators), based on the normative requirements, with just a 
couple of exceptions (resulting in 2 Partially Covered indicators).  

Covered  indicators  concerned  Certification  Bodies having mechanisms to ensure that 
auditor  (and  other  relevant  personnel  of  the  Certification  Body)  qualifications  and 
competence, as well as to ensure impartiality in the conformance evaluation process. FSC 
ensures  that  Certification  Bodies  have  and  apply  a  documented  methodology  and 
procedures for the evaluation of conformity of organisations and issuance of a certificates. 
The procedures address topics such as: audit frequency; the requirement for on -site (field) 
visits where applicable; sampling protocols; unannounced or short-notice audits, and other 
aspects of auditing. 

Importantly,  FSC  also  ensures  that  Certification  Bodies  conduct  consultation  with 
stakeholders, as appropriate, for evaluating compliance of certificate holders in relation to 
Forest management audits, as well as some audits for Controlled Wood. 

One  important  gap  was  identified:  there  are  no  normative  requirements  nor  formal 
processes (to be conducted by FSC or Certification Bodies) for identifying Or ganisations 
sanctioned for engagement in corrupt practices proactively and prior to association with 
FSC.  

Other requirements of the Certification scheme 

Of  the  22  indicators evaluated in relation to general quality requirements for the FSC 
scheme, 16 were concluded as Covered, 5 as Partially Covered and 1 as Not Applicable. 
These  indicators  covered  topics  such as scheme transparency, accreditation and the 
certification process. 

In  relation  to  scheme  transparency,  FSC  scored  highly,  with  five  of  the six in dicators 
evaluated as Covered, based on its normative requirements. This concern issues such as 
ensuring scheme requirements for Certificate Holders and Certification Bodies are publicly 
and  freely  available online, as well as providing a publicly availability of an up-to-date 
register of certified/verified organisations. Critically, summaries of Forest Management 
and Controlled Wood audit reports, with relevant findings from the audits, are available on 
the same online register.  

Procedures for handling complaints and grievances are in place, publicly available and 
implemented. 

To ensure consistency of implementation of requirements, the FSC scheme includes a list 
of  the  relevant  national  laws  and  international  conventions  to  which  the  country  has 
ratified, and which hold legal force in the country. Requirements for forest managers and 
supply chain entities are also applicable to the organisation’s contractors and outsourcing 
facilities. 

In  relation  to issues of accreditation and oversight, most indicators were evaluated as 
covered,  based  on  the  normative  requirements.  FSC  has  in  place  a  system  for  the 
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accreditation and oversight of Certification Bodies to ensure that CBs have in place the  
required procedures, capacity and competencies. The requirements and the process for 
accreditation are publicly available, as is an up-to-date list and details of all accredited 
Certification  Bodies.  Mechanisms  are  in  place  to  ensure  that  relevant  personn el  are 
qualified and competent to evaluate the performance of Certification Bodies.  

Furthermore,  the  competence  and  consistent  performance  of  Certification  Bodies  is 
regularly evaluated, employing both stakeholder consultation and in -field evaluation of 
performance. 

FSC ensures that the oversight mechanism for Certificate Holders applies a clear basis for 
establishing  conformance,  raising  corrective  actions  for  non -conformance,  ensuring 
closure within defined timeframes, and certification issue/maintenance  decision making. 
Certification bodies are required to define a timeframe (up to 3 months for major non -
conformities and up to the next audit for minor non-conformities) in the case of annual 
surveillance  audits.  This  approach  ensures that non-conformances in relation to FSC 
requirements are addressed systematically and within a specific timeframe. It is also an 
approach employed by almost all forest certification schemes. 

However, the same approach also raises a potential risk that a non -conformities which 
relate to – or imply - a legal infringement of legislation, may result in products or materials 
being traded from the Certificate Holder for a period of time, of which the identified non -
conformance was not addressed and verified as closed. These products or materials may 
potentially be interpreted as illegally harvested or non-negligible risk. This itself carries a 
risk that wood products might be placed on the EU market, without mitigation measures to 
reduce the risks having been implemented. 

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Introduction 

The  objective  of  the  Study is to create a resource of knowledge and reference for all 
interested and concerned parties in the forest- and wood-based products sector. It should 
help  Competent  Authorities,  Operators  and  Monitoring  Organisations  covered  b y  the 
EUTR  in  their  understanding  of potential benefits and shortcomings of certification, in 
particular  in  the  context  of  the  implementation  of  the EUTR. As such, one part of the 
overall  objectives  is  to  create  an  overview  of  existing  certificates,  third -party  verified 
schemes and certifying bodies issuing certificates with regard to forests and wood -based 
products  and to evaluate their respective strengths and weaknesses in respect to the 
EUTR obligations. This should, in turn, encourage stronger standard s and transparency of 
certification and third part verification schemes. 

It should be underlined that it is NOT the intention of the study to create a compliance 
checklist  of  certification  schemes.  The  EUTR  continues  to  recognise  third  party 
certification as an important potential tool for risk assessment and risk mitigation but does 
not  recognise  certification  as  proof  of  compliance. This will not change based on this 
study. 

As part of the above objective, this framework has been developed to allow evaluat ion of 
the  differences  and  uniformities  between  certificates  and certifying bodies. It includes 
requirements  to  assess  to  which  degree different forest certification schemes provide 
assurance of low (negligible) risk of ‘legal non-compliance’ of certified material.  

The  Framework  aligns  with  the  definitions  and  approach  to  certification  schemes  as 
described within the EU Timber Regulation (No. 995/2010) and the associated Guidance 
Document,  along  with  additional  requirements  for  the  use  of  third  party  certification 
schemes as outlined in the Commission implementing Regulation (EU) No 607/2012 an d 
specifically Article 4 in the Commission Implementing Regulation (EU) No 607/2012.  

The Framework takes into account verifiers for Article 6 in the EUTR, and documentati on 
for  Article  4  of  the  Implementing  Regulation,  as  well  as  a  wide  array  of sustainability 
standards and benchmarks used in the areas of forest and wood -based products, among 
other resources identified under References. 

The current report includes and assessment of FSC. 

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Acronyms 

CB 

CH 

CITES 

Certification Body 

Certificate Holder 

The  Convention  on  International  Trade  in  Endangered  Species of Wild 
Fauna and Flora 

CNRA   

Centralised National Risk Assessment  

CoC 

CW 

DDS 

Chain of Custody 

Controlled Wood 

Due Diligence System 

EUTR   

European Union Timber Regulation  

FM 

FMU 

FSC 

Forest Management 

Forest Management Unit 

Forest Stewardship Council 

NFSS   

National Forest Stewardship Standard 

NRA 

NS 

RA 

STD 

National Risk Assessment 

National Standard 

Risk Assessment 

Standard 

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34.  Overview of Certification Scheme 

Background 

The Forest Stewardship Council (FSC) is a global, not-for-profit organisation dedicated to 
the  promotion  of  responsible  forest  management  worldwide.  Its  founding  general 
assembly was in 1993 and  it was established as a legal entity in 1994. It was founded 
because of the need for a system that could credibly identify well-managed forests as the 
sources of responsibly produced wood products and build support for the idea of a non -
governmental,  independent,  and  international  forest  certification  system.  FSC  is  a 
membership-based  association  with  diverse  members  that  include  representatives  of 
environmental  and  social  non-governmental  organisations,  the  timber  trade,  forestry 
organisations, indigenous  peoples’ organisations, community forestry groups, workers’ 
trade  unions,  retailers  and  manufacturers, forest certification organisations, individual 
forest owners, and other interested parties. 

Global Governance 

FSC comprises several legal entities. FSC Asociación Civil (FSC AC) is the membership 
organisation,  and  is  registered  in  Oaxaca,  Mexico,  it  owns  FSC  Global  Development 
GmbH  (FSC  GD),  FSC  International  Center  GmbH  (FSC  IC) and Assurance Services 
International GmbH (ASI). FSC GD is a company in Bonn, Germany, which manages the 
FSC brand and trademark, and provides services to partners and constituents around the 
world.  FSC  IC  is  the  entity  responsible  for  developing  and  maintaining the normative 
framework.  ASI,  also  based  in  Bonn,  Germany,  works  as  an  independent  third-party 
accreditation body. ASI is the sole accreditation provider for the FSC system, as well as 
for several other systems, including the Marine Stewardship Council, the Roundtable on 
Sustainable Palm Oil, and the Sustainable Biomass Program. 

The FSC certification system operates as a third-party system with three key actors: F SC 
IC  (under the responsibility of the FSC AC Board, representing FSC’s membership) is 
responsible for the development, maintenance and interpretation of the FSC no rmative 
framework. Certification Bodies evaluate the conformity of organisations applying for and 
holding  certification  against  the  requirements  of  the  normative  framework.  These 
Certification Bodies must be accredited to conduct evaluations and issue FSC certificates 
by  ASI:  just  as  the  certification  bodies  evaluate  the  conformity  of  organisations,  ASI 
checks that the certification bodies follow the relevant accreditation requirements. 

FSC is a member of ISEAL, a global membership organisation for sustaina bility systems. 
FSC has Code Compliant status, meaning that it has successfully undergone independent 
evaluations against the ISEAL Codes of Good Practice in Standards-Setting, Assurance 
and Impacts.  

Accreditation Process 

Organisations  seeking  accreditation  to  certify  against  the  FSC certification standards 
apply  to  ASI.  Once  approved,  the  Certification  Body  will  enter  into  an  accreditation 
agreement  with ASI before accreditation procedures begin. These procedures include 
document review of the Certification Body’s quality management system, a head office 
assessment and witness assessments. Assessment findings are documented in reports 
which are then reviewed and signed off by technical reviewers. If everything is approved, 
the accreditation is granted. According to ASI, the process usually takes 12-24 months. 

ASI conduct annual audits of accredited Certification Bodies, which includes office audits, 
witness audits of auditors and evaluation of audit reports. 

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There  are  currently  41  Certification  Bodies  accredited  for  FSC  certification.  These 
Certification Bodies have varying scopes for their accreditation, differing by technical and 
geographical scope.  

At  the  time  of  writing,  all  accredited  Certification  Bodies  have  FSC  Chain of Custody 
(CoC) certification  in scope (although not all including FSC Controlled Wood), whereas 
only  17  have  FSC  Forest  Management  (FM)  in  scope.  Currently,  twelve  Certification 
Bodies  are  accredited  for  both  FM  and  CoC  Worldwide, with the remainder limited to 
certain countries, are accredited Worldwide with the exclusion of China, or only have a 
limited  geographical  scope  for  FM  certification  and  operate  worldwide  for  CoC.  All 
currently accredited Certification Bodies and their scopes can be found on ASI’s website.    

Certification Standards 

The two main types of certification within the FSC system are Forest Management (FM) 
and Chain of Custody (CoC).  

Forest Management  

FSC Forest Management certification is based on FSC’s ten principles, which intend to 
set out best practices for forest management and are applicable worldwide (see Box 1). 
Each principle has a number of criteria providing practical ways to ascertain if the principle 
is being followed. The FSC Principles and Criteria for Forest Stewardship standard (FSC -
STD-01-001) is the international FM standard. The current version of this standard is V5 -
2, published in July 2015.  

A second key document for FM certification is the International Generic Indicators (F SC -
STD-60-004)  which  aims,  amongst  other  things,  to  operationalise  the  Principles  and 
Criteria (P&C) at the national level and ensure the consistent implementation of the P&C 
worldwide.  The  International  Generic  Indicators  (IGI)  are  adapted  to  the  national  or 
regional  level  by  dedicated  working groups to produce a Nationa l Forest Stewardship 
Standard (NFSS), which is applied in the area it covers. The process of adaptation shall 
follow a dedicated procedure (FSC-PRO-60-006) and is intended “to reflect the diverse 
legal, social and geographical conditions of forests in different parts of the world” (FSC). In 
countries not covered by a national standard, a technical working group may adjust the 
IGI to develop an interim national standard. Thus, the FSC Principles and Criteria (P&C) 
and International Generic Indicators (IGI) set out the global requirements for achieving 
FSC forest management certification. 

Information provided by FSC shows that to date 40 countries have an approved national 
standard which has been transferred to Version 5 of the international standard, and for  a 
further 38 the process is ongoing, to be completed in 2021. 

Box 1. FSC’s  10 Principles  for responsible  forest management 

Principle 1: Com pliance w ith Law s  
Comply  w ith all  applicable  law s, regulations and nationally -ratified  international  treaties,  conventions and 
agreements. 

Principle 2: Workers’ Rights and Em ploym ent Conditions  
Maintain  or enhance the social and economic  w ellbeing of w orkers. 

Principle 3: Indigenous Peoples’ Rights  
Identify and uphold  Indigenous  Peoples’  legal  and customary  rights of ow nership, use and management  of 
land,  territories and resources affected by management  activities. 

Principle 4: Com m unity Relations  
Contribute  to maintaining  or enhancing  the social and economic  w ellbeing of local communities. 

Principle 5: Benefits from  the Forest 
Efficiently manage  the range of multiple  products and services of the Management  Unit  to maintain  or 

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enhance long  term economic  viability  and the range of environmental  and social benefits. 

Principle 6: Environm ental Values and Im pacts 
Maintain,  conserve and/or restore ecosystem services and environmental  values of the Management  Unit,  and 
shall avoid, repair or mitigate  negative  environmental  impacts. 

Principle 7: Managem ent Planning 
Have a management  plan consistent w ith its policies  and objectives and proportionate  to scale, intensity  and 
risks of its management  activities. The  management  plan shall be implemented  and kept  up to date based on 
monitoring  information  in order to promote  adaptive management.  The  associated planning  and procedural 
documentation  shall be sufficient to guide  staff, inform affected stakeholders and interested  stakeholders  and 
to justify management  decisions. 

Principle 8: Monitoring and Assessment 
Demonstrate  that, progress tow ards achieving  the management  objectives, the impacts  of management 
activities and the condition  of the Management  Unit,  are monitored  and evaluated  proportionate  to the scale, 
intensity and risk of management  activities,  in order to implement  adaptive  management. 

Principle 9: High Conservation Values  
Maintain  and/or enhance the High  Conservation  Values in the Management  Unit  through  applying  the 
precautionary approach. 

Principle 10: Im plem entation of Managem ent Activities  
Management  activities conducted by or for the organisation  for the management  unit  shall be selected and 
implemented  consistent w ith the organisation’s  economic,  environmental  and social policies and objectives 
and in compliance  w ith the Principles  and Criteria  collectively. 

Chain of Custody 

FSC Chain of Custody certification applies to manufacturers, processors and traders of 
FSC certified forest products, and ensures that materials and products which are sold with 
FSC claims originate from certified forests, controlled sources, reclaimed materials, or a  
mixture of these. It allows certified companies to label their FSC products, which in turn 
enables  consumers  to  identify  and  choose  products  that  support  responsible  forest 
management. 

Note: a new version of the CoC standard (V3-1) was published during the finalisation of 
this  study,  released  on  February  3,  2021  and  effective  from  May  2021. This version 
introduces the new 'FSC core labour requirements' into FSC CoC certification, based on 
the ILO core conventions. Whilst the full standard has not been evaluated the new section 
is noted at the relevant indicator (Indicator C.2.2.1) and referenced in two other places.  

The  CoC  system  does  not  include,  under  ordinary  circumstances,  any  validation  of 
volumes  transferred from seller to purchaser, vertically along  supply chains. However, 
where  there is suspicion or concerns regarding inaccuracy of volumes, FSC conducts 
transaction verification investigations. 96 Transaction verifications are led by Accreditation 
Services International (ASI), with the required support of certification bodies and certificate 
holders. Certificate holders provide samples of FSC transaction data to their certification 
bodies, which is then forwarded to ASI for analysis.  

Transaction verification also includes the requirement for  certificate holders to support 
fibre testing by surrendering samples and specimens of materials and information about 
species  composition.  FSC  is  exploring  other  ways of improving supply chain integrity, 
including the use of Blockchain technology 97.  

96 See FSC-STD-40-004 V3-0, Requirement 1.7 and FSC-PRO-10-201 V1-0, Clause 1.1 
97 See https://fsc.org/en/innovation/blockchain, https://fsc.org/en/supply-chains, https://fsc.org/en/unacceptable-activities  

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Controlled Wood 

FSC Chain of Custody certification allows for the mixing of FSC certified materials with 
non-certified materials, under special conditions. The non-certified (and non-recycled) 
materials  must  meet  the  ‘FSC  Controlled  Wood’  standard  requirements .  These 
requirements seek to ensure that the non-certified input does not originate from any of five 
unacceptable sources:  

1.  Illegally harvested wood 
2.  Wood harvested in violation of traditional and human rights 
3.  Wood  harvested  in  forests  in  which  high  conservation  values  (HCVs)  are 

threatened by management activities 

4.  Wood harvested in forests being converted to plantations or non -forest use 
5.  Wood from forests in which genetically-modified trees are planted 

FSC Controlled Wood certification can be applied by forest managers in the same way as 
FSC forest management certification. Working to a different standard, FSC Controlled 
Wood certification can also be applied by Chain of Custody certified organisations. In this 
case,  a  due  diligence  process  is  required  to  source  FSC  controlled  wood  from  non-
certified organisations. One of the two types of risks that the due diligence system shall 
address is the risk associated with the origin of the material, for which Certificate Holders 
are  obliged  to use a risk assessment  that has been developed according to a certain 
procedure  (FSC-PRO-60-002  V3-0).  This  procedure  outlines  the  methodology  for 
developing, maintaining, revising, evaluating, and approving risk assessments. F SC has 
assessed  the  risk  in  60  countries  which  can  be  accessed  via  FSC’s  online  Risk 
Assessment Platform. Organisations sourcing from unassessed areas must develop their 
own  ‘Extended  Company  Risk  Assessment’  (ECRA)  using  the  same  requirements,  
framework and procedures as FSC’s risk assessments. 

FSC Material Categories  

There are different material categories that can be used in separate product groups under 
FSC Chain of Custody certification. This is important to note when evaluating the FSC 
system and using FSC material, because material contained in one product group may 
have been subjected to different normative requirements than in another. The claims that 
can be made on sales and delivery documents for the different product groups are:  

  FSC  100%,  which  comprises  material  from  FSC  certified  forests  and  has only 
been handled by Chain of Custody certified organisations in the supply chain.  
  FSC  Controlled  Wood,  which  comprises  material  that  was  either  evaluated  as 
Controlled Wood at the forest management unit level and has only been handled 
by Chain of Custody certified organisations in the supply chain, or material that 
was evaluated as Controlled Wood through a due diligence process and therefore 
has  not  only  been  handled  by  certified  organisations  in  the supply chain. CW 
claims can only be used business to business and not as a final claim category for 
consumers. 

  FSC  Mix  (Credit  or  XX%),  which  contains  a  mixture  of  FSC  100%  and  FSC 

Controlled Wood.  

  FSC  Recycled  (Credit  or  XX%),  which  contains  FSC  Recycled, where relevant 

subdivided into pre-consumer reclaimed and post-consumer reclaimed. 

Group and SLIMF certification models 

At both the FM and CoC levels small organisations can join together to form a group and 
apply for group certification, to share the costs and workload of obtaining and maintaining 
certification.  In  each  case  a  Group  Entity  (a  person  or  group  of  persons,  such  as  a 
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cooperative, association or company) takes responsibility for establishing and managing a 
system  ensuring  compliance  of  the  Group  Members.  There  are  reduced  auditing 
requirements, whereby Certification Bodies audit just a sample of the Group Members 
each year, along with the Group Entity. This reduced external auditing is compensated by 
the fact the Group Entity is required to conduct audits of all Group Members on an annual 
basis, the results of which are audited by the Certification Body at each audit.  

The  evaluation  standards  dictate  the  sampling  methods  the Certification Bodies shall 
employ and the definition of  ‘small’ is defined and, in some cases, national adaptations 
are approved by FSC.   

There are also streamlined certification procedures for Small and Low Intensity Managed 
Forests (SLIMFs) that meet FSC eligibility criteria (as set out in FSC-STD-01-003 V1-0), 
also known in the FSC system as ‘smallholders’.  

Small  means  Forest  Management  Units  (FMUs)  smaller  than  100ha  or  a  regionally 
specified size (up to 1000ha), if included in the addendum to the standard (FSC-STD-01-
003a). This means that the criteria for being classified as a SLIMF varies internationally. 
Low intensity means when the rate of harvesting is less than 20% of the mean annual 
increment (MAI) within the total production forest area of the unit and either the annual 
harvest from the total production forest area is less than 5000 m3 or the average annual 
harvest from the total production forest is less than 5000 m3 / year during the period of 
validity of the certificate.  

Smallholders  do  not  normally  need  the  same  level  of  documentation or management 
systems as managers of larger or more intensively managed woodland areas. There is 
also a reduced intensity of audit, thus, reducing costs.  

With regards to (previous) version 4-0 of the principal forest management (FM) standard 
(Principles and Criteria for Forest Stewardship, FSC-STD-01-001), it was more common 
to develop separate national SLIMF standards (such as is the case for Brazil). For the 
current version 5-2, current practice is to include specific requirements or provisions for 
SLIMF in the main FM standard.  

As  of  December 2020, approximately 20% of all FM certificates (351 out of 1762) are 
SLIMFs. In terms of certified area, this represented a total of 8.59 million ha  (3.8%) out of 
approximately 223.41 million ha. 

Verifying FSC Certificates  

FSC maintains a public certificate database, which can be accessed at http://info.fsc.org/ . 
Certificates  are  searchable  using  various  queries  including  business  name,  country, 
certificate  number,  certification  type,  and  product  type.  The  database  contains  each 
certificate: certificate and license codes, address and contact information of the certified 
organisation, certification validity and dates, group members and sites, and product types. 

Public  summaries of certification reports are required and made available on the FSC 
certificate  database  for  forest  management  and  controlled  wood  forest  management 
certificates, but are not required or available for chain of custody certificates. T he latest 
version of the controlled wood due diligence standard also requires public certification 
summaries. 

Policy and standard development  

FSC  has  a  comprehensive  development,  review  and  revision  process  for its policies, 
standards  and  procedures.  Details  of  the  current  processes  are  published  on  their 
website,  where  anyone  can  sign  up  to  the  relevant  Consultative  Forum.    A  regularly 
updated  overview  and  schedule  of  the  development,  review  and  revision  processe s 
(‘Document Catalogue and Policy Roadmap’) can also be downloaded from the website.  

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FSC’s Development and Revision of FSC Normative Documents Procedure (FSC-PRO-
01-001) specifies how documents of the normative framework are developed, reviewed 
and revised. It involves the establishment of a Steering Committee and Working Group, 
detailed steps that shall be followed at each stage in the process, which includes public 
consultation. The revision of this procedure itself started in November 2020, with the aim  
of streamlining the normative framework.  

Stakeholder engagement  

Stakeholder engagement is a prominent part of FSC. It is built into the system in various 
ways:  it  is  a  requirement  of  FM  certificate  holders  and  of  the  Certification  Bodies 
evaluating them, it’s required during the development of the Risk Assessments and it is an 
important control measure in the due diligence system. At the broader level the whole 
scheme is open for input from anyone: a new consultation platform has been launched 
which provides the opportunity to feedback on specific documents that are currently out 
for consultation, which are advertised on the FSC newsfeed. Additionally, stakeholders 
can give input anytime to the existing normative documents, including the ones not being 
under revision via the ‘contribute to the standards’ webpage.   

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35.  About this report 

1.1 Report structure 

The scheme has been evaluated on two levels: 

 

International  level  –  all  applicable  global  documents  and  information  were 
evaluated, considering how the scheme is structured and functions globally; and  

  National level – where the scheme is adapted to the national level, a sample of 
four  countries  were  selected,  to  see  how  the  international  requirements  and 
processes have been adapted, and if they have been done  so according to the 
scheme’s requirements, thus providing evidence to feed into the findings at the 
international level. The four countries are Brazil, China, Romania and Russia.  

In this version of the report (draft II) the findings from the national-level evaluations have 
been  incorporated into the findings of the international-level evaluation and are, thus, 
presented in summary. The national-level reports will be affixed as annexes to draft III  of 
this report, for full transparency of the details of the study.  

This  study  is  based  on  the  Scheme  Assessment  Framework  (SAF)  (as  described  in 
Section 3 below), the first two sections are about the legal requirements for Certificate 
Holders, the first focusing on the forest level (A1), the second on supply cha in entities 
(A2). Due to the size and complexity of the scheme the findings for these two sections 
have been split up and reported in two sections, each with an additional letter suffix:  

  A.1a Legal Requirements at the forest level – Forest management certification 

o  This covers full FSC FM certification (FSC-STD-01-001, FSC-STD-60-004 
and associated documents) and FM Controlled Wood certification (FSC-
STD-30-010 and associated documents) 

  A.1b Legal Requirements at the forest level – Input from non-certified forest  

o  This  covers  non-certified  material  entering  the  FSC  system  via  the 
Controlled  Wood  due  diligence  system  implemented  by  CoC  certificate 
holders (FSC-STD-40-005 and associated documents) 

  A.2a Legal requirements for supply chain entities – Certificate holders 

o  This  covers  the  CoC  standard  and  the  requirements  that  are  directly 
applicable to COC certificate holders within the FSC system (FSC-STD-40-
004 and associated documents) 

  A.2b Legal requirements for supply chain entities – Non-certified supply chains  

o  This  covers  non-certified  material  entering  the  FSC  system  via  the 
Controlled  Wood  due  diligence  system  implemented  by  CoC  certificate 
holders (FSC-STD-40-005 and associated documents)  and refers to the 
non-certified supply chain entities between the forest gate and the point of 
export in the country of harvest.  

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2.1 Overview  of  the  certification  standards  used  for  this 

analysis 

Type 
General  

Norm ative 

FSC-STD-01-002 FSC Glossary of Terms 

FSC-STD-20-001 General requirements for FSC accredited certification bodies 

FSC-PRO-01-008 V2-0 Processing Complaints in the FSC Certification Scheme 

FSC-PRO-01-005 V3-0 Processing Appeals 

FSC-PRO-01-008 V2-0 Processing Complaints in the FSC Certification Scheme 

FSC-PRO-01-009  V4-0  Processing  Policy  for  Association  Complaints  in  the FSC Certification 
Scheme 

FSC & Corruption 2017 V1-1 

ASI Accreditation Procedure: ASI-PRO-20-101-Accreditation-V5.1 

ASI Findings: ASI-PRO-20-106-ASI Findings-V6.1 

ASI Procedure on Surveillance & Sampling: ASI-PRO-20-105-Surveillance & Sampling-V6.4 

FSC-PRO-10-201 V1-0, Transaction Veri fication Procedure 

Forest 
Managem ent 

FSC-STD-01-001 V5-2 FSC Principles and Criteria for Forest Stewardship 

FSC-STD-60-004 V2-0 International Generic Indicators 

FSC-STD-60-002 V1-0 Structure and Content of National Forest Stewardship Standards 

FSC-PRO-60-006 V2-0 Development and Transfer of National Forest Stewardship  S t a nd a rds t o  
the FSC Principles and Criteria Version 5-1 

FSC-STD-30-010 V2-0 FSC Controlled Wood Standard for Forest Management Enterprises 

FSC-ADV-30-010  V1-0  DATED  10  JULY  2014  Applicable  National  and  Local  Laws  and 
Regulations for Controlled Wood for Forest Management Enterprises 

FSC-POL-20-003 V1-0 FSC Policy on the excision of areas from the scope of certification  

FSC-STD-20-007 V3-0 Forest management evaluations 

FSC-STD-20-007a V1-0 Forest management evaluations addendum – Forest certification reports 

FSC-STD-20-007b V1-0 Forest management evaluations addendum – Forest certificati on  p u bli c 
summary reports 

FSC-STD-20-012  Standard  for  evaluation  of  FSC  Controlled  Wood  in  Forest  Management 
Enterprises 

FSC-STD-20-006 V3-0 Stakeholder consultation for forest evaluations 

FSC-STD-30-005 V2-0 Forest management groups 

FSC-ADV-60-004 V1-0 Advice Note on Transaction Verification for FM/CoC Certificate Holders    

Chain of 
Custody 

FSC-STD-40-004 V3-0 Chain of Custody Certification 

FSC-DIR-40-004 FSC Directive on Chain of 

Custody Certification - Last Updated: 12 August 2020 

Interpretations of the normative framework: Chain of Custody – 30 June 2020 

FSC-STD-40-004a FSC Product Classification Standard 

FSC-STD-40-007 V2-0 Sourcing reclaimed material for use in FSC Product Groups 

or FSC Certified Projects 

FSC-STD-20-011 V4-1 Chain of Custody Evaluations  

FSC-STD-40-003 V2-1 Chain of Custody Certification of Multiple Sites 

FSC-PRO-40-003 V1-1 Development of National Group Chain of Custody Eligibility Criteria 

FSC-PRO-40-003a List of approved national Group Chain of Custody eligibility criteria 

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Due 
Diligence 
System  

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC Controlled Wood 

FSC-PRO-60-002 V3-0 The Development and Approval of FSC National Risk Assessments 

FSC-PRO-60-002a V1-0 FSC National Risk Assessment  Framework Procedure  

FSC-PRO-60-002b V2-0 List of approved FSC Controlled Wood documents 

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ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

36.  Evaluation methodology 

The scheme is evaluated against Scheme Assessment Framework (SAF) and Scheme 
Assessment  Procedure  (SAP)  in  order  to  assess  how  the  scheme  covers  relevant 
requirements of the EUTR, and the criteria defined by the European Commission as the 
basis for this Study. 

For each indicator, we will have a conclusion that will show the level of conformance of 
the Scheme with the indicator: 

Conclusion 

Definition 

Covered 

When  available  Scheme  requirements 
and information  - and any impacts 
evidence available  - indicate the 
coverage of the SAF indicator. 

When  available  Scheme  requirements 
and information  - and any impacts 
evidence available  - indicate only 
partial coverage of the SAF indicator.   

Partially Covered 

Alternatively,  special concerns about 
Scheme  standards, credibility,  rigor or 
coverage may  exist. 

NOTE:  It is important  to justify the 
partial  coverage and indicate  w here 
the issues are w hich result in a 
Coverage  conclusion not being  given. 
When  available  Scheme  requirements 
and information  - and any impacts 
evidence available  - indicate that 
there is no coverage of the SAF 
indicator. 

NOTE:  It is important  to justify a no 
coverage conclusion. 
When,  for w hichever reason, the SAF 
indicator  does not apply.   

Not Covered 

Not Applicable 
(N/A) 

Explanation 
Coverage  is the ability  of the Scheme  to 
provide assurance that material  traded via the 
Scheme  has a low  (negligible)  risk of being 
illegally  harvested, traded in line w ith the 
legality  definition  of the EU  Timber  Regulation. 

Partial  Coverage  means  the Scheme  is only 
partly able – or may be compromised  in one or 
more  w ays – to provide assurance that material 
traded via the Scheme  has a low  (negligible) 
risk of being  illegally  harvested, traded in line 
w ith the legality  definition  of the EU  Timber 
Regulation.   

The  Scheme  is not  – or inadequately  – able to 
provide assurance that material  traded via the 
Scheme  has a low  (negligible)  risk of being 
illegally  harvested, traded in line w ith the 
legality  definition  of the EU  Timber  Regulation.   

501 

 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

37.  Overview of findings 

Conclusion 
Requirements for Certificate Holders 

Requirement Section 
A. 
A.1 Legal Requirements at 
the forest level 
General  findings for A1. 

Summary 

Conclusion 

Summary 

a - Forest management certification 

b - Input from non-certified forest 

A.1a relates to legal  requirements  at the forest level and, in particular, 
forest management  certification. It  evaluates how  the scheme  ensures 
that Certificate  Holders  comply w ith all  applicable  legislation.  It covers 
full FSC  FM  certification (FSC-STD-01-001,  FSC-STD-60-004  and 
associated documents)  and FM  CW  certification (FSC-STD-30-010 
and associated documents). 

Legal  requirements  at the forest level are largely covered for FSC  FM 
certification. Of the 27 indicators concerning legal  requirements  at the 
forest level,  24 w ere evaluated  as covered, w hile 3 as partially 
covered. 

A.1b concerns non-certified material  entering  the FSC  system via the 
Controlled  Wood  due diligence  system w hich is implemented  by CoC 
certificate holders (FSC-STD-40-005  and associated documents).   

It relates to legal  requirements  at the forest level, but specifically input 
from non-certified forest (Controlled  Wood). It  evaluates if the scheme 
ensures that entities  w ithin the Country  of Harvest w hich are included 
w ithin a Controlled  Wood due diligence  system, are evaluated  for legal 
requirements  at the forest level. 

All 26 indicators  concerning legal  requirements  at the forest level w ere 
evaluated  as Covered. 

Some  of these relate to small  ambiguities  or omissions  in 
requirements,  w here areas of legality  defined in the Scheme 
Assessment Framew ork  may not be explicitly specified in standard 
requirements. 

On most  occasions, the four national  forest certification system 
evaluations  corroborate the findings at the international  level 
evaluation.   

A.1.1 Rights  to harvest timber 
w ithin legally  gazetted boundaries 

Partially  covered 

Based on the normative  requirements,  six out of 
the seven indicators for this criterion are Covered 
by the scheme.   

Covered 

Based on the normative  requirements  all seven 
indicators of this criterion  are evaluated  as 
covered by the Scheme. 

The  indicators concluded as Covered  encompass 
legal  requirements  concerning such areas as: 
land tenure and management  rights; the issuing 
of licences; legal  business registration  and other 
relevant legally  required  licenses; management 
planning  and the issuing of harvesting permits. 

These encompass  legal  requirements  concerning 
such areas as: land  tenure and management 
rights; the issuing of concession and harvesting 
licences; legal  business registration  and other 
relevant legally  required  licenses; management 
planning  and the issuing of harvesting permits. 

502 

 
 
 
 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

Partial  coverage is concluded for one indicator 
(A.1a.1.2.1), in the case of FM  and FM  CW 
certification. While  the International  FM  standards 
include  requirements  that ensure compliance  w ith 
legislation  regulating  procedures for the issuing of 
concession licenses (w here they exist), they do 
not explicitly include  the requirement  that licenses 
shall only cover legally  gazetted areas. 

A.1.2 Payments  for harvest rights 
and timber  including  duties related 
to timber  harvesting 

Partially  covered 

Based on the normative  requirements,  one 
indicator  been evaluated  as Covered, the other 
Partially  Covered. 

Covered 

Based on the normative  requirements  all tw o 
indicators of this criterion  are evaluated  as 
covered by the Scheme. 

A.1.3 Timber  harvesting, including 
environmental  and forest 
legislation  including  forest 
management  and biodiversity 
conservation, w here directly 
related  to timber  harvesting 

The  first indicator  is evaluated  as Partially 
covered for FM  certification but covered for FM 
CW  certification. In  the case of FM  certification, 
w hile normative  documents  include  requirements 
that ensure compliance  w ith legislation  regulating 
royalties, stumpage  fees and other volume-based 
fees, land area taxes or fees are not specifically 
mentioned  (A.1a.2.1.1). 

The  second indicator  encompassing  legislation 
related  to value-added  taxes and other sales 
taxes, is covered for both FM  and FM  CW 
certification 

Partially  covered  Of the eight indicators  for this criterion  all but one 

Covered 

have been evaluated  as covered, based on the 
normative  requirements. 

The  indicators concluded as Covered  encompass 
legal  requirements  concerning: harvesting 
regulations  and all affiliated topics; protected 
areas and habitats;  environmental  impact 
assessment and other  environmental 
requirements,  as w ell as health  & safety and legal 
employment. 

In  the case of requirements  to control potential 
illegal  activities by third parties w ithin the area 

503 

These encompass  legal  requirements  concerning 
the payment  of royalties and harvesting fees, as 
w ell as value-added  taxes and other sales taxes.    

Based on the normative  requirements  all seven 
indicators of this criterion  are evaluated  as 
covered by the Scheme. 

These indicators  encompass legal  requirements 
concerning: harvesting regulations  and all  affiliated 
topics; protected areas and habitats; 
environmental  impact  assessment and other 
environmental  requirements,  as w ell as health  & 
safety and legal  employment. 

 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

A.1.4 Third  parties’  legal rights 
concerning use and tenure that 
are affected by timber  harvesting 

Covered 

managed  by the operation,  full coverage is 
concluded for FM  certification, but partial 
coverage is concluded for FM  CW  certification 
w here the control of illegal  activities by third 
parties is limited  to illegal  conversion only 
(A.1a.3.1.2). 

All four indicators for this criterion have been 
evaluated  as Covered,  based on the normative 
requirements.  These encompass  legal 
requirements  w hich concern among  other things: 
respect for customary tenure rights; benefit 
sharing; principles  of 'Free,  Prior  and Informed 
Consent'  in connection  w ith granting  rights to 
forest management,  as w ell as the tenure rights 
of indigenous  and tribal peoples  to forest land. 

A.1.5 Trade  and customs, in so far 
as the forest sector is concerned 

Partially  covered  Of the six indicators included  w ithin this criterion, 

Covered 

all but one have been evaluated  as covered, 
based on the normative  requirements. 

The  indicators concluded as Covered  encompass 
legal  requirements  concerning: the classification 
of species, quantities  and qualities;  trade and 
transport; offshore trading and transfer pricing; 
CITES  and legislation  requiring  due diligence  or 
due care procedures. 

In  the case of legislation  covering Customs 
regulations,  full coverage is concluded  for FM  CW 
certification, but partial  coverage is concluded  for 
FM  certification.  Whilst the international 
framew ork of the scheme provides for full 
coverage, this has not been follow ed through in 
the example  of the National  Standard  for 
Romania  (A.1a.5.4.1). 

Covered 

Based on the normative  requirements  all four 
indicators of this criterion  are evaluated  as 
covered by the Scheme. 

These indicators  encompass legal  requirements 
w hich concern among  other things:  respect for 
customary tenure rights; benefit sharing; principles 
of 'Free, Prior  and Informed  Consent'  in 
connection  w ith granting rights to forest 
management,  as w ell as the tenure rights of 
indigenous  and tribal  peoples to forest land. 

Based on the normative  requirements  all six 
indicators of this criterion  are evaluated  as 
covered by the Scheme. 

These indicators  encompass legal  requirements 
concerning: the classification of species, quantities 
and qualities;  trade and transport; offshore trading 
and transfer pricing;  CITES;  customs regulations 
and legislation  requiring  due diligence  or due care 
procedures. 

A.2 Legal requirements for 
supply chain entities – 

a - Legal requirements for supply chain entities – 
Certificate holders 

b - Legal requirements for supply chain entities – Non-
certified supply chains 

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ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

Certificate holders 
General  findings for A2 

A.2a relates to legal  requirements  for Certificate holders based w ithin 
the Country of Harvest, w hich are supply chain entities.  The legal 
requirements  in question concern trade and customs law s, in so far as 
the forest sector is concerned. 

A.2b relates to legal  requirements  for supply chain entities  based w ithin 
the Country of Harvest, w ithin the non-certified supply chains. The legal 
requirements  in question concern trade and customs law s, in so far as 
the forest sector is concerned. 

This section focuses evaluation  on the CoC  standard,  w hich is 
applicable  to all  certified supply  chain entities  w ithin the FSC  system 
(FSC-STD-40-004  and associated documents).   

Of the 10 indicators  w ithin this principle,  1 w as evaluated as Covered, 
7 as Partially  Covered, w hile 2 as Not  Covered. 

This section focusses evaluation  on non-certified material  entering  the 
FSC  system via the Controlled  Wood  due diligence  system 
implemented  by CoC  certificate holders (FSC-STD-40-005  and 
associated documents)  and refers to the non-certified supply chain 
entities  betw een the forest gate and the point  of export in the country of 
harvest.  

While  the normative  requirements  of the CoC  standard  do require 
Certificate  holders to ensure the import/export  of FSC  certified 
products conforms to all  applicable  trade and customs law s, broadly 
the language  of the requirements  is such that they either did not fully 
cover the indicators  in this framew ork, or there w ere some omissions 
in relation  to specific areas of trade law . 

Of the 10 indicators  w ithin this principle,  all  w ere evaluated as Not 
Covered. 

The  normative  requirements  of the Controlled  Wood  standard FSC-
STD-40-005,  do not cover trade/transport legal  requirements  applicable 
to supply-chain entities  included  w ithin a certified due diligence  system.   

A.2.1. Legal registration 

Not  Covered 

Based on the lack  of applicable  normative 
requirements  the one indicator  for this criterion, 
concerning the existence of legal  business 
registration  and other relevant  legally  required 
licenses, has been evaluated  as not covered 
(A.2a.1.1.1). 

Not  Covered 

A.2.2 Taxes and fees 

Partially  covered 

Based on the normative  requirements  this 
criterion has been  evaluated as partially  covered. 
This is based on the follow ing conclusions for the 
tw o indicators: 

Not  Covered 

 

A Partial  coverage conclusion is made  for the 
first indicator  (A.a2.2.1.1) w hich addresses 
compliance  w ith legislation  covering payment 
of all legally  required taxes, royalties and 
fees. The normative  requirements  applicable 

505 

The  normative  requirements  applicable  to supply-
chain entities  (w ithin the country of harvest) 
included  w ithin a due diligence  system certified 
according to the Controlled  Wood standard FSC-
STD-40-005,  do not cover this criterion. 

The  one indicator  is included  w ithin this criterion, 
concerning the existence of legal  business 
registration  and other relevant  legally  required 
licenses. 

The  normative  requirements  applicable  to supply-
chain entities  (w ithin the country of harvest) 
included  w ithin a due diligence  system certified 
according to the Controlled  Wood standard FSC-
STD-40-005,  do not cover this criterion. 

Tw o indicators  are included  w ithin this criterion, 
concerning compliance  w ith legislation  covering 
payment  of all legally  required  taxes, royalties and 
fees, as w ell as value-added  taxes and other sales 

 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

taxes. 

Not  Covered 

The  normative  requirements  applicable  to supply-
chain entities  (w ithin the country of harvest) 
included  w ithin a due diligence  system certified 
according to the Controlled  Wood standard FSC-
STD-40-005,  do not cover this criterion. 

The  criterion comprises seven indicators 
concerning the follow ing topics: 

classification of species, quantities,  qualities 
trade and transport law s 
offshore trading and transfer pricing 
customs regulations 

 
 
 
 
  CITES 
 

legislation  requiring  due diligence  / due care 
procedures 

A.2.3 Trade  and transport 

Partially  covered 

 

to supply-chain certificate holders do not fully 
cover this indicator. 
The  second indicator  (A.2a.2.2.1) addresses 
compliance  w ith legislation  covering value-
added taxes and other sales taxes. Based on 
the lack of normative  requirements  applicable 
to supply-chain certificate holders, it has 
been evaluated  as Not  Covered. 

Normative  requirements  applicable  to supply-
chain certificate holders, do require them  to 
ensure the import  and/or export of FSC  certified 
products conforms to all  applicable  trade  and 
customs law s. Still,  only one indicator w ithin this 
criterion has been  evaluated as Covered,  w hilst 
the other six indicators  have been evaluated  as 
Partially  Covered.  In relation  to the partial 
coverages: 

 

 

 

 

 

normative  requirements  do not fully cover 
indicator  A.2a.3.1.1 w ith regards to 
legislation  regulating  how  products are 
classified. 
normative  requirements  do not fully cover 
indicator  A.2a.3.2.1 w hich concerns ensuring 
compliance  w ith required  trading permits  and 
documents  that accompany  the transport  of 
w ood. 
for indicators  A.2a.3.3.1/2, normative 
requirements  do not explicitly  refer to 
legislation  regulating  offshore trading or 
transfer pricing. 
the CoC  standard does not explicitly 
reference CITES  permits  or legislation,  at 
export from the country of harvest, by a 
supply chain entity. Hence,  A.2a.3.5.1 has 
been evaluated  as Partially  Covered. 
normative  requirements  do not make  explicit 
reference to legislation  covering due 
diligence/due  care procedures. Hence, 
A.2a.3.6.1 has been evaluated  as Partially 
Covered. 

506 

 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

For indicator  A.2a.3.4.1 w hich concerns 
compliance  by supply-chain certificate holders in 
relation  to customs regulations,  full coverage is 
concluded. 

Conclusion 

Summary 

Partially  covered 

Of the four indicators  for this criterion  three have been evaluated  as covered and one as partially 
covered, based on the normative  requirements. 

Requirement Section 
A.3 Requirements for material control 
A.3.1 Material  control 

Full  coverage is concluded for indicators covering the follow ing topics: 
 

systematic processes to enable  the identification  of the country of harvest of the material  (and 
w here applicable  to a higher  level of detail) as w ell as the species included  in certified materials 
or products. 
clear and effective measures  to prevent material  from non-negligible  risk, unverified or potentially 
illegal  sources from entering  the supply chain and mixing  w ith conforming  material 

 

Partial  coverage is concluded because there is limited  validation  of volumes  transferred along  the 
supply chain (and A.3.1.1.4). It  is noted that the FSC  system includes  mechanisms  such as 
transaction verifications  - conducted by its certification body and Accreditation  Services International 
– w here there is suspicion or concerns regarding  inaccuracy of volumes.  This  comprises a number  of 
activities, including  volume  data analysis and fibre testing. How ever, despite these efforts, FSC  CoC 
certification does not include  systematic validation  of volumes  transferred from seller to purchaser, 
w hich is considered as a major  gap in the system. 

A.3.2 Recycled  material 

Partially  covered 

Of the three indicators for this criterion tw o have been evaluated  as covered and one as partially 
covered, based on the normative  requirements. 

Partial  coverage has been concluded because FSC  descriptions of pre-consumer  material  described 
in Annexes I and II  of the FSC  reclaimed  materials  standard FSC-STD-40-007,  may not entirely align 
w ith the definition  of w aste material  as described by the EUTR  and associated guidance  document 
(A.3.2.1.1). 

Full  coverage is concluded for indicators covering processes to enable  the identification  of w aste and 
to prevent mixing  of reclaimed  material  that w ould qualify for an exemption  under the EUTR  from 
being  missed w ith material  that w ould not qualify. 

507 

 
 
  
 
 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

A.4 General requirements for Certificate 
Holders 
A.4.1 Conflict  resolution 

A.4.2 Corruption 

A.5 Quality and procedural requirements 
for Certificate Holders 
A.5.1 Internal  procedures for Certificate Holders 

Covered 

Covered 

The  indicator for this criterion has been  evaluated  as Covered, based on the scheme  normative 
requirements.  It concerns conflict resolution  – specifically that disputes are identified,  recorded and 
managed  in a robust and transparent w ay. 

The  indicator for this criterion has been  evaluated  as Covered, based on the scheme  normative 
requirements.  It requires that certificate holders do not engage in  corrupt practices related  to illegal 
harvesting. 

Partially  covered 

Based on the normative  requirements  this criterion has been evaluated  as partially  covered. This is 
based on the follow ing conclusions for the tw o indicators: 

A.5.2 Qualification  and competence 

Partially  covered 

 

 

A full coverage conclusion is made  for the first indicator (A.5.1.1). FSC  includes  requirements  for 
Certificate  Holders  to have in place  - and implement  - systems and procedures covering all 
requirements  of the Scheme.   
Partial  coverage has been concluded for the second indicator. The  FSC  Scheme  requires that 
Certificate  Holders  regularly review  the proper functioning  of their ow n procedures, in the case of 
certification at the forest level and in relation  to the controlled  w ood DDS  implemented  according 
to standard FSC-STD-40-005.  How ever, the scheme does not require  the same  of CoC-certified 
companies,  certified to FSC-STD-40-004  only (A.5.1.2). 

Partial  coverage has been concluded for the indicator  w ithin this criterion,  because the scheme  does 
not have a requirement  that organisations  certified to the FM  CW  standard have personnel  w ith 
sufficient qualifications  and competencies  (A.5.2.1). Requirements  covering this indicator  exist in all 
other parts of the scheme  and certification types. 

A.5.3 Risk  based approaches to sourcing, trade 
or production 

Covered 

Of the four indicators  for this criterion,  three have been evaluated  as Covered  and one Not Applicable 
to the FSC  Scheme,  based on the normative  requirements. 

Full  coverage is concluded for indicators covering risk based approaches to sourcing non-certified 
material  (Due  Diligence  Systems), w hich concern the  need for: 
 
 

clear requirements  to ensure consistent implementation  of the Due  Diligence  System 
a requirement  that ensures that w henever there is a change in the risk related  to illegal  harvest, 
trade or transport in a supply chain  – or a supply chain covered by a DDS  – the risk shall be 
assessed and mitigated  prior to shipping  and sale. 
requirements  to ensure that the DDS  comprises,  at a minimum,  the follow ing elements:  a quality 
management  system; ii) procedures for obtaining  access to information  pertinent  to the 

 

508 

 
 
 
 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

identification  of risk; risk assessments, and the implementation  of mitigations  measures w hen 
risks are identified 

The  indicator w hich is Not  Applicable  concerns cases w here other 3rd party schemes are permitted 
to be used by the due diligence  system as meeting  specific due diligence  requirements.  FSC 
Controlled  Wood  standard FSC-STD-40-005  does not include  the recognition  of other 3rd party 
schemes. 

Requirements for Certification 

B. 
Bodies 
B.1 General  Certification  Body requirements 

Partially  covered 

Three  of the four indicators  have been evaluated  as Covered,  based on the normative  requirements. 
These concern collectively: 

B.2 Certification  Body requirements  for auditing 
and certification 

Partially  covered 

  mechanisms  to ensure that auditors, and other relevant personnel  of the Certification  Body, are 

 

qualified  and competent 
requirements  to ensure that auditors, and other personnel relevant to the conformance 
evaluation  of an organisation  shall be impartial  to the entity(-ies) under evaluation,  and that the 
certification decision process is impartial  also. 

Partial  coverage has been concluded for one indicator  (B.1.1.2) due to the lack  of competence 
requirements  specific to auditors evaluating  companies  against the Requirements  for Sourcing FSC 
Controlled  Wood  (FSC-STD-40-005)  w hich requires the evaluation  of a DDS. 
Four of the five indicators have been evaluated  as covered, based on the normative  requirements. 
These concern collectively: 

 

ensuring that Certification  Bodies apply a documented  methodology  for the evaluation 
(assessments and audits) of clients 

  minimum  methodologies  and procedures for the evaluation  of conformity of organisations  and 

issuance of a certificates. 

  Certification  Body implemented  procedures for audits  that address  topics such as: audit 

frequency; the requirement  for on-site (field) visits w here applicable;   sampling  protocols; 
unannounced  or short-notice audits,  and other aspects of auditing. 
ensuring that Certification  Bodies conduct consultation  w ith stakeholder  (including  rights holders) 
as appropriate  in relation  to audits. 

 

The  fifth indicator (B.2.2.2)  has been evaluated  as Partially  Covered.  Mechanisms  exist w hich could 
identify and deal w ith corrupt practices by Certificate  Holders.  How ever, there are no nor mative 
requirements,  nor formal  processes, for identifying  Organisations  sanctioned for engagement  in 
corrupt practices proactively and prior to association  w ith FSC.   

C. 

Requirements for Certification 

509 

 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

Schemes 
C.1  Transparency 

Partially  covered 

Five of the six indicators have been evaluated  as covered, based on the normative  requirements. 
These concern collectively, the follow ing: 

C.2  Scheme  & standard scope 

Partially  covered 

 

 

 

Scheme  requirements  for Certificate  Holders  and Certification  Bodies, as w ell as other relevant 
information  about the Scheme  must  be publicly  and freely available  online. 
publicly  availability  of an up-to-date register of certified/verified organisations,  as w ell as 
summaries  of reports (or full reports) w ith relevant findings from audits. 
Procedures  for handling  complaints  and grievances being  in place,  publicly available  and 
implemented. 

The  sixth indicator has been evaluated  as Partially  Covered.  The normative  requirements  applicable 
to supply-chain certificate holders do not fully cover the requirement  of the indicator  that the scheme 
has in place requirements  (at all  levels of the scheme) to manage  risks of corruption and conflict of 
interest. 

One of the four indicators w ithin this criterion, one has been  evaluated as Partially  Covered and tw o 
have been evaluated  as Covered, based on the normative  requirements.  The fourth is not applicable 
because FSC  does not recognise nor endorse other schemes  or systems (C.2.4.1). 

Indicator  C.2.1.1  concerns standards being  adapted to the national  or subnational  context in w hich 
they are being implemented  and containing  a list of applicable  legislation,  or that the Scheme  shall 
enable/require  detailed  evaluation  of applicable  legislation  in a national  context. This indicator  has 
been evaluated  as Partially  Covered,  due the delays in updating  all  National  Forest Stew ardship 
Standards (NFSS)  to meet  the updated  international  Principles  and Criteria  (FSC-STD-01-001  V5). 

The  tw o indicators evaluated  as covered, concern that:   

 

 

the scheme include  a list of the relevant international  conventions to w hich the country has 
ratified, and w hich hold legal  force in the country. 
requirements  for forest managers  and supply chain entities  to be applicable  to the organisation’s 
contractors and outsourcing facilities 

C.3  Accreditation and oversight 

Partially  Covered 

Seven of the eight  indicators have been evaluated  as covered, based on the normative  requirements. 
Four of them  concern collectively,  different aspects of accreditation: 

 

 

the scheme must  have a system for accreditation  or oversight of Certification  Bodies to ensure 
that CBs have in place the required  procedures, capacity and competencies  
requirements  and the process for accreditation  must  be publicly  available,  as is an up-to-date  list 
and details  of all accredited Certification  Bodies. 

  mechanisms  to ensure that relevant personnel  are qualified  and competent  to evaluate  the 

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performance of Certification  Bodies. 

Three  more indicators   concern collectively, different aspects of oversight mec hanisms: 

 

 

 

the specification of the approach to be used in oversight, ensuring that the oversight mechanism 
is independent  of the Certification  Bodies  being assessed.  
the frequency of oversight  - or the procedure for determining  the frequency - applicable  in the 
case of risk-based oversight. 
the use of both stakeholder  consultation  and in-field evaluation  of performance during  the 
accreditation  of certification bodies. 

One indicator  is evaluated  as Partially  Covered,  concern that the scheme: 

 

ensures that the oversight mechanism  applies  a clear basis for: establishing  conformance; 
raising corrective actions for non-conformance,  ensuring closure w ithin reasonable timeframes, 
and certification issue/maintenance  decision making   (C.3.2.2).  FSC  requirements  for non-
conformities  are structured in a w ay that there is a potential  risk that a non-conformity may 
represent an infringement  of legislation  and that, as a result, illegal  w ood may enter the EU 
market  w ithout mitigation  measures to prevent this from occurring for a period of up to 3 or 12 
months 

C.4  Certification  process 

Partially  covered 

Three  of the four indicators  for this criterion  have been evaluated  as Covered,  based on the 
normative  requirements.  These  encompass the certification process and  compliance  evaluation. 

One indicator  is  concluded  as partially  covered, ow ing to the same issue as described in C.3.2.2 
above. There is a potential  risk that a non-conformity may  represent an infringement  of legislation 
and that, as a result, illegal  (or non-negligible)  w ood from entering  the EU  market  w ithout mitigation 
measures  to prevent this from occurring for a period of up to 3 or 12 months. 

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38.  Evaluation 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

A. Requirements for Certificate Holders 

R e quirements applicable to the C ertificate Holders. These include requirements to comply with applicable le gislation, as we ll  as re quirements re levant to e nsuring continued 
pe rformance  and integrity of the operations – as far as is re lated to legal compliance . 
A.1a Legal Requirements at the forest level – Forest management certification 

This principle re lates to how the  scheme e nsures that Certificate Holders comply with all applicable legislation. This section relates to requirements of the Scheme that applies to 
C e rtificate Holders - or other e ntities subje ct to the normative requirements of the Scheme (e.g. included within the scope of a certified due dili gence system) - within the Country 
of Harve st. 

Due  to the size and complexity of the scheme the findings for this section have been split up and reported in two sections. This section (A.1a) covers full FSC FM ce rtification (FSC-
STD-01-001, FSC-STD-60-004 and associated documents) and FM C ontrolled W ood ce rtification (FSC-STD-30-010 and associated documents). The next section (A.1b) will focus on 
non-certified material entering the FSC system via the C ontrolled Wood due diligence  system which is implemented by CoC ce rtifica te holders (FSC-STD-40-005 and associated 
docum ents). 

A . 1a.1.1 

A .1a.1 R ights to  harvest 
tim ber within legally 
g a zetted b oundaries 
Land te nure 
and 
m anagement 
rights 

A . 1a.1.1.1. The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
le gislation 
cove ring land 
te nure  rights, 
including 
customary 
rights as we ll as 

FSC -STD-60-004  V2-0  Inte rnational  Ge ne ric 
Indicators 

Principle   1, 
De ve lopers: 

Instructions 

for  Standard 

“Standard De velopers shall*: 

• Ide ntify whe re customary rights* g ove rn  u se  
and  acce ss,  and,  whe re   applicable ,  write  
additional indicators to ensure that these ri g ht s 
to  carry  out  activitie s  within the  scope  of the  
ce rtificate are documented (Indicator 1.1.1); 

•  Ide ntify  the   appropriate   proce ss  that 

512 

F i ndings 

FM C e rtification: Covered. 

FM C W  C ertification: 
C ove red. 

FSC  Standard FSC-STD-60-004 V2-0 
Inte rnational Generic Indicators (IGI)s 1.2.1 
– 1.2.3 cover land tenure and m anagement 
rights. The instructions for Standard 
De ve lopers under Principle 1 re quire  that 
national level indicators be specifically 
include d whe re these are  governed by 
customary rights.  

IGI 1.3.1 covers legal compliance of 

 
 
 
 
 
 
 
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C onclusion 

m anagement 
rights.  

re cognizes and grants customary rights* relate d 
to  use   and  acce ss  and  how  such re cognize d 
custom ary  rights*  are   to  be   docum e nte d 
(Indicator 1.2.1); 

• Ide ntify whe re customary te nure s* to manage  
and use resources exist at the national level and  
e nsure   that  the se   are   incorporate d  into 
indicators (Indicator 1.2.1).”  

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

activitie s undertaken. The instructions for 
Standard Developers re quire  that “a list of 
all applicable laws, obligatory codes of 
practice  and legal and customary rights at 
the  national and, whe re applicable, s ub-
national level”. The re quired list is outlined 
in Anne x A of the standard and covers land 
te nure  and management rights, including 
customary rights.  

C rite ria 1.2:  

“The  Organization* shall demonstrat e  t h at  t h e  
le gal status* of the Management Unit*, including 
te nure * and use rights*, and its boundaries, are  
cle arly de fined.” 

C rite ria 1.3:  

local 

““The  Organization* shall have legal* ri g ht s t o  
ope rate in the Management Unit*, which f i t  t h e  
le gal status* of The  O rgani zat i on  and  of  t he  
Manage m e nt  Unit, and shall com ply with the  
associated legal obligations in applicable national 
and 
re gulations  and 
adm inistrative re quirements.  T he  l e gal  ri g ht s 
shall  provide   for  harve st  of  products  and/or 
supply of ecosystem services* from  wi t h i n  t he  
Management Unit. The O rganiz at ion  sh all  p ay  
the  le gally prescribed charges ass oci ate d  wi t h  
such rights and obligations.” 

laws*  and 

FSC -STD-60-004 V2-0 IGIs 1.2.1 – 1.2.3: 

“1.2.1  Le gal*  te nure *  to  m anage   and  use  
re sources within the scope of the ce rt i fi cat e  i s  
docum ented.”  

“1.2.2 Legal* te nure * is g ran t e d b y  a l e g all y  
com pe te nt*  authority  according  to  le gally 
pre scribed proce sses.” 

The  four national level evaluations 
corroborate the findings at the international 
le ve l (see report Annexes for details). 

R e quirement 3.1 of the FSC C ontrolled 
W ood FM standard (FSC-STD-30-0010) 
state s that “all harve sting shall take place  in 
com pliance with all laws applicable to 
harve sting in the jurisdiction in accordance  
with the  crite ria outlined in table 1”. Land 
te nure  and management rights are  not 
re fe re nced in the table. Howe ver, a 
norm ative An Advice Note ‘Applicable 
National and Local Laws and Regulations for 
C ontrolled W ood for Forest Management 
Ente rprises’ (FSC-ADV-30-010 V1-0) was 
published (first in March 2013 and re vised 
July 2014) to ensure alignment with the 
EUTR  (and other similar le gislation). It 
contains a list of applicable National and 
Local Laws and R egulations that must be 
com plied with, superseding Table 1 in the 
standard. This list covers land tenure and 
m anagement rights.  

“1.2.3 The boundaries of all Management Units*  
within  the   scope   of  the   ce rtificate  are  cle arly 

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 

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C onclusion 

that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d.  

m ark ed or documented and  cl e arl y  s hown  o n 
m aps.” 

Unde r C riteria 1.3 Instructions for Developers: 

“Standard De velopers shall* complete a list of all 
applicable laws*, obligatory codes of  p ract i ce * 
and le gal* and customary rights* at the national 
and,  whe re   applicable ,  sub -national le ve l as 
outlined in Annex A.” 

Principle 1, Annex A: Minimum list of appli cabl e  
re gulations  and  nationally-ratifie d 
laws, 
inte rnational 
conve ntions  and 
agre ements. 

tre atie s, 

1. Le gal* rights to harvest 

1.1  Land  te nure *  and  m anage m e nt  rights: 
Le gislation  cove ring  land  te nure *  rights, 
including  custom ary  rights*  as  we ll  as 
m anagement rights, that  i ncl u de s t h e  u se  of  
le gal*  m e thods to obtain te nure * rights and 
m anage m e nt  rights.  It  a lso  cove rs  le gal* 
busine ss  re gistration  and  tax   re gistration, 
including re levant legally re quire d licenses. 

IGI 1.3.1: 

“1.3.1  All  activitie s  unde rtak e n 
the  
Management Unit* are carried out in compliance  
with: 

in 

1)  Applicable   laws*  and  re gulations  and 
adm inistrative re quirements, 

2) Le gal* and customary rights*; and 

3) O bligatory codes of practice*.” 

FSC -STD-30-010 V2-0 

R e quirement 3.1: 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 

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C onclusion 

outlined in table 1.” 

FSC -ADV-30-010 V1-0 Dated 10 July 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

1.1: “The O rganization* shall* be a legally 
de fined entity with cle ar, documented and 
unchallenged le gal registration*, with writte n 
authorization from the legally competent* 
authority for specific activities.” 

1.2: “The O rganization* shall* demonstrate 
that the  legal* status of the Management 
Unit*, including tenure* and use rights*, and 
its boundaries, are cle arly defined.” 

1.3: “The O rganization* shall* have legal* 
rights to operate in the Management Unit*, 
which fit the  le gal* status of The 
O rganization* and of the Management Unit*, 
and shall* comply with the associated le gal* 
obligations in applicable national and local 
laws* and regulations and administrative 
re quirements. The legal* rights shall* provide 
for harve st of products and/or supply of 
e cosystem services* from within the 
Management Unit*. The Organization* shall* 
pay the  legally prescribed charges associated 
with such rights and obligations.” 

1.7: ““The Organization* shall* publicize a 
com m itment not to offer or re ceive bribes in 
m oney or any other form of corruption, and 
shall* comply with anti-corruption legislation 
whe re  this e xists. In the absence of 
anticorruption le gislation, The O rganization* 
shall* implement other anticorruption 
m e asures proportionate to the scale* and 

515 

A . 1a.1.1.2. The 
Sche m e shall 
include  
re quirements to 
e nsure that 
lice nses, right 
of te nure and 
m anagement 
rights, have 
be e n issued: 

i)  according to 
the  le gally 
pre scribed 
proce dure , 

ii) in 
com pliance with 
third parties' 
le gal rights 
conce rning 
te nure , 

iii) spe cifying 
the  le gally-
gazetted 
boundaries, 
and; 

iv) with 

F i ndings 

FM C e rtification: Covered. 

FM C W  C ertification: 
C ove red. 

R e quirements i) to iii) are covered by FSC 
Standard FSC-STD-60-004 V2-0 
Inte rnational Generic Indicators (IGI)s 1.1 
to 1.3.  

IGI 1.7 explicitly addresses the potential for 
corrupt practices and includes re quirements 
to e x clude corruption. The instructions for 
Standard Developers also give guidance on 
how this can be addressed whe re anti-
corruption laws and re gulations are 
ine ffective or do not e xist.  

Thre e  of the national-level e valuations 
corroborate the international level finding, 
with the  e xception of Brazil (see re port 
Anne xes for details). The Brazilian standards 
have  ye t to be updated to Version 5 of the 
Inte rnational FM standard (FSC-STD-01-
001). Ve rsion 4 of International FM standard 
doe s not e xplicitly address the issue of 
corruption. See C .2.1.1. for how de layed 
transfer of national standards impacts the 
findings of this study. 

R e quirement 3.1 of the FSC C ontrolled 
W ood standard (FSC-STD-30-001) states 
that “all harvesting shall take place in 

 
 
 
 
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F i ndings and Justification 

C onclusion 

absence of 
corrupt 
practice s. 

inte nsity* of management activities and the 
risk * of corruption.” 

FSC -STD-60-004 V2-0 

1.7 Instructions for Standard De velopers:  

“This C riterion* re cognizes that corruption is 
ge nerally re garded as illegal but that not all 
countrie s have or im plement anti-corruption 
laws and re gulations. 

W he re anti-corruption laws and regulations 
are  ine ffective or do not exist, Standard 
De ve lopers shall* include other anti-
corruption m easures that m ay include for 
e x ample, The O rganization* develops or 
participates in formal integrity pacts with 
othe r organizations in the public and private 
se ctors, such that each participant agrees in 
we ll publicized statements not to engage in 
corruption by offering or re ceiving bribes, 
whe the r in m oney or in any other forms 
(Indicator 1.7.4). 

An inde pendent third party with e xpertise in 
such m atters should then monitor* 
pe rformance  related to such statements.” 

com pliance with all laws applicable to 
harve sting in the jurisdiction in accordance  
with the  crite ria outlined in table 1”. Above 
the  table is an ‘intent box’ that states “The 
Fore st Management Enterprise shall provide 
e vide nce that legal procedures have been 
followe d to gain permits and licenses”, thus 
cove ring i). ii) covere d by R equirement 4.2 
and iii) is specified in table 1 (d).  

C orruption is not mentioned in the 
C ontrolled W ood standard itself but the 
norm ative Advice Note specifies legal 
m e thods of obtaining concession licenses 
and harve sting permits, noting how 
corruption is a we ll-known issue associated 
with such lice nses.  

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

FSC -STD-30-010 V2-0 

“Inte nt box: The Forest Management Enterpri se  
shall  provide   e vide nce   that le gal proce dure s 
have   be e n  followe d  to  gain  pe rm its  and 
lice nses.”  

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

“4.2. No conflicts re lating to land te nure  or l a nd 
use  rights of traditional or indi ge nou s p e opl e s 
groups e xist in the FMUs und e r co nt rol  o f t h e  

516 

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d for 
FM ce rtification and FM C ontrolled Wood. 
The  Brazilian standards have yet to be 
updated to the latest version of the 
Inte rnational FM standard. See C .2.1.1. for 
how de layed transfer of national standards 
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A . 1a.1.1.3 The 
Sche m e shall 
include  
re quirements 
that e nsure the 
e x istence of 
le gal business 
re gistration, 
and other 
re le vant legally 
re quire d 
lice nses.  

Fore st  Manage m e nt  Ente rprise   for  which  a 
re solution process has not been agre e d b y  t h e  
m ain  partie s  to  the  dispute  (se e  se ction 4.4 
be low).”  

FSC -ADV-30-010 V1-0 Dated 10 July 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

“1.1 The Organization* shall* be a legally 
de fined entity with cle ar, documented and 
unchallenged le gal registration*, with writte n 
authorization from the legally competent* 
authority for specific activities.” 

FSC -STD-60-004 V2-0 

“1.1.1 Legal re gistration* to carry out all 
activitie s within the scope of the ce rtificate is 
docum ented and unchallenged. 

1.1.2 Legal re gistration* is granted by a 
le gally competent* authority according to 
le gally prescribed processes.” 

Principle 1, Annex A: Minimum list of appli cabl e  
re gulations  and  nationally-ratifie d 
laws, 
inte rnational 
conve ntions  and 
agre ements. 

tre atie s, 

1. Le gal* rights to harvest 

1.1  Land  te nure *  and  m anage m e nt  rights: 
Le gislation  cove ring  land  te nure *  rights, 
including  custom ary  rights*  as  we ll  as 
m anagement rights, that  i ncl u de s t h e  u se  of  
le gal*  m e thods to obta in te nure * rights and 
m anage m e nt  rights.  It  also  cove rs  le gal* 
busine ss  re gistration  and  tax   re gistration, 

517 

F i ndings 

FM C e rtification: Covered. 

C rite rion 1.1 of the FM standard e xplicitly 
cove rs this re quirement.  

FM C W  C ertification: 
C ove red. 

All harve sting shall take place in compliance  
with all laws applicable to harvesting in the 
jurisdiction in accordance with the crite ria 
outlined in table 1. 

The  four national level evaluations 
corroborate the findings at the international 
le ve l (see report Annexes for details). 

R e quirement 3.1 of the FSC C ontrolled 
W ood standard (FSC-STD-30-001) states 
that “all harvesting shall take place in 
com pliance with all laws applicable to 
harve sting in the jurisdiction in accordance  
with the  crite ria outlined in table 1”. 
Business re gistration is not included in the 
table . Howe ver, a normative Advice Note for 
this re quirement contains a list of applicable 
National and Local Laws and Regulations 
that m ust be complied with, superseding 
Table 1 in the standard. This list covers land 

 
 
  
 
 
 
 
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C onclusion 

including re levant legally re quire d licenses. 

FSC -STD-30-010 V2-0 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

FSC -ADV-30-010 V1-0 Dated July 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

te nure  and management rights, which 
include s “legal business re gistration and tax 
re gistration, including relevant le gal 
re quire d licenses.” 

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d at 
the  inte rnational level. 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

F i ndings 

local 

“1.3 The Organization* shall have legal * ri g ht s  
to ope rate in the Management Unit *,  wh i ch  f i t  
the  le gal status* of The Organization and of t h e  
Manage m e nt  Unit, and shall com ply with the  
associated legal obligations in applicable national 
and 
re gulations  and 
adm inistrative re quirements.  T he  l e gal  ri g ht s 
shall  provide   for  harve st  of  products  and/or 
supply of ecosystem services* from  wi t h i n  t he  
Management Unit. The O rganiz at ion  sh all  p ay  
the  le gally prescribed charges ass oci ate d  wi t h  
such rights and obligations.” 

laws*  and 

“1.7  The   O rganization*  shall  publicize   a 
com m itm e nt  not  to offe r or re ce ive  bribe s in 
m oney or any other form of corruption, and shall 
com ply  with  anti-corruption  le gislation whe re  
this e x ists. In the absence  of  an ti - corru pt i on 
le gislation, The O rganizati on  sh all  i m pl e m e nt  

518 

C rite rion 1.3 of the International FM 
Standard re quires that all activities 
unde rtaken in the forest are compliant. 
Standard Developers are instructe d to 
com plete a m inimum list of applicable laws, 
re gulations and nationally-ratified 
inte rnational tre aties, conventions and 
agre ements. Annex A gives an outline of all 
type s to be included and Concession licenses 
are  e x plicitly included.   

FSC  Standard FSC-STD-60-004 V2-0 
Inte rnational Generic Indicator 1.7.4 
addre sses the issue of legal obtainment of 
the  conce ssion licenses.  

FM C e rtification: Partially 
C ove red. 

FM C W  C ertification: 
Partially C overed. 

A . 1a.1.2 

C once ssion 
lice nses 

A . 1a.1.2.1 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
le gislation 
re gulating 
proce dure s for 
the  issuing of 
conce ssion 
lice nses, 
including use of 
le gal methods 
to obtain 
conce ssion 
lice nses and 
that lice nses 

 
 
 
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are  cove ring 
only le gally 
gazetted areas 

othe r anti-corruption measures proportionate  t o 
the   scale *  and  inte nsity*  of  m anage m e nt 
activitie s and the risk* of corruption. 

FSC -STD-60-004 V2-0 

1.3 Instructions for Standard De velopers: 

“Standard De velopers shall* complete a list of all 
applicable laws*, obligatory codes of  p ract i ce * 
and le gal* and customary rights* at the national 
and,  whe re   applicable ,  sub -national le ve l as 
outlined in Annex A.” 

Principle 1, Annex A: Minimum list of appli cabl e  
re gulations  and  nationally-ratifie d 
laws, 
inte rnational 
conve ntions  and 
agre ements. 

tre atie s, 

1.2 C oncession licenses 

Le gislation  re gulating  proce dure s for issuing 
fore st* conce ssion licenses, including the use  of  
le gal* methods to obtain conce ssi on l i ce n se s.  
Bribe ry, corruption and nepotism are particularly 
we ll-k nown  issue s  that  are   conne cte d  with 
conce ssion lice nses. 

“1.7.4  Bribe ry,  coe rcion  and  othe r  acts  of 
corruption do not occur.” 

FSC -STD-30-010 V2-0 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

FSC -ADV-30-010 V1-0 Dated 10 July 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

519 

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 
applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. A norm ative Advice Note for this 
re quirement contains a list of applicable 
National and Local Laws and Regulations 
that m ust be complied with, superseding 
Table 1 in the standard. This list covers 
conce ssion lice nces, including use of le gal 
m e thods to obtain them.  

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

Howe ve r, neither the International FM nor 
FM C W  normative documents reference 
re quirements to e nsure that licenses are 
cove ring only le gally gazetted areas. Nor is 
this re flected in the Russian standard (FSC-
STD-R US-02-2020). 

The  Brazilian FSC standards for fore st 
m anagement in general terms call for 
com pliance with le gislation and a ddress the 
issue of holding concession licenses through 
com petent bodies. Howe ver, the use of legal 
m e thods to obtain concession licenses is not 
dire ctly addressed by the curre nt standards. 
Howe ve r, it is noted that these standards 
have  ye t to be transferred to the m ost up to 
date  ve rsion of the International FM 
standard. See C .2.1.1. for how delayed 

 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

C ode 

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S t andard re ference 

F i ndings and Justification 

C onclusion 

transfer of national standards impacts the 
findings of this study. 

This indicator is not applicable for China nor 
R om ania, whe re  land is not leased in this 
way.   

Se e  re port Annexes for details of the 
national level evaluations.  

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Partially 
C ove red. While normative documents 
include  requirements that ensure 
com pliance with le gislation re gulating 
proce dure s for the issuing of conce ssion 
lice nses (whe re they exist), they do not 
e x plicitly include the re quirement that 
lice nses shall only cover le gally gazetted 
are as.  

Se e  C .2.1.1. for how de layed transfer of 
national standards impacts the findings of 
this study. 

A . 1a.1.3 

Management 
and 
harve sting 
planning 

A . 1a.1.3.1 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
le gislation and 
le gal obligations 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

F i ndings 

FM C e rtification: Covered. 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 
and agreements. Annex A gives an outline 

FM C W  C ertification: 
C ove red. 

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C onclusion 

for 
m anagement 
planning, 
including 
conducting 
fore st 
inve ntories, 
having a forest 
m anagement 
plan and related 
planning and 
m onitoring. 

FSC -STD-60-004 V2-0 

1.3 Instructions for Standard De velopers: 

“Standard De velopers shall* complete a list of all 
applicable laws*, obligatory codes of  p ract i ce * 
and le gal* and customary rights* at the national 
and,  whe re   applicable ,  sub -national le ve l as 
outlined in Annex A.” 

Principle 1, Annex A: Minimum list of appli cabl e  
re gulations  and  nationally-ratifie d 
laws, 
inte rnational 
conve ntions  and 
agre ements. 

tre atie s, 

Anne x A: 
“1.3 Management and harvesting planning 
Any national or sub-national legal* 
re quirements for Management Planning, 
including conducting forest* inventories, 
having a forest* management plan* and 
re late d planning and monitoring, impact 
assessments, consultation with other entities, 
as we ll as approval of these by legally 
com petent* authorities.” 

FSC -STD-30-010 V2-0 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

FSC -ADV-30-010 V1-0 Dated 10 July 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

of all types to be included. Section 1.3 of 
the  Annex is on Management and harvesting 
planning, whe re all aspects of this 
re quirement are e xplicitly included.   

The  four national level evaluations 
corroborate the findings at the international 
le ve l (see report Annexes for details). 

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 
applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. A norm ative Advice Note for this 
re quirement contains a list of applicable 
National and Local Laws and Regulations 
that m ust be complied with, superseding 
Table 1 in the standard. This list covers all 
aspects of management and harvesting 
planning of this re quirement.  

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d. 

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C onclusion 

A . 1a.1.3.2 The 
Sche m e shall 
include  
re quirements 
that all legally 
re quire d 
planning 
docum ents 
have  been 
approved prior 
to 
im plementation 
of fore st 
harve sting 
activitie s. 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

F i ndings 

FM C e rtification: Covered. 

FM C W  C ertification: 
C ove red. 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

FSC -STD-60-004 V2-0 

1.3 Instructions for Standard De velopers: 

“Standard De velopers shall* complete a list of all 
applicable laws*, obligatory codes of  p ract i ce * 
and le gal* and customary rights* at the national 
and,  whe re   applicable ,  sub -national le ve l as 
outlined in Annex A.” 

Principle 1, Annex A: Minimum list of appli cabl e  
re gulations  and  nationally-ratifie d 
laws, 
inte rnational 
conve ntions  and 
agre ements. 

tre atie s, 

Anne x A: 
“1.3 Management and harvesting planning 
Any national or sub-national legal* 
re quirements for Management Planning, 
including conducting forest* inventories, 
having a forest* management plan* and 
re late d planning and monitoring, impact 
assessments, consultation with other entities, 
as we ll as approval of these by legally 
com petent* authorities.” 

FSC -STD-30-010 V2-0 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

FSC -ADV-30-010 V1-0 Dated 10 July 2014 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 
and agreements. Annex A gives an outline 
of all types to be included. In Section 1.3, 
on Management and harvesting planning, it 
is included that approval shall be given by 
le gally competent authorities. 

The  four national level evaluations 
corroborate the findings at the international 
le ve l (see report Annexes for details). 

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 
applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. A norm ative Advice Note for this 
re quirement contains a list of applicable 
National and Local Laws and Regulations 
that m ust be complied with, superseding 
Table 1 in the standard. This includes that 
all le gally re quire d planning documents have 
be e n approved. 

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

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C onclusion 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d. 

A . 1a.1.4 

Harve sting 
pe rm its 

A . 1a.1.4.1 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
le gislation 
re gulating the 
issuing of 
harve sting 
pe rm its, 
lice nses or 
othe r le gal 
docum ents 
re quire d for 
spe cific 
harve sting 
ope rations. 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

FSC -STD-60-004 V2-0 

1.3 Instructions for Standard De velopers: 

“Standard De velopers shall* complete a list of all 
applicable laws*, obligatory codes of  p ract i ce * 
and le gal* and customary rights* at the national 
and,  whe re   applicable ,  sub -national le ve l as 
outlined in Annex A.” 

Principle 1, Annex A: Minimum list of appli cabl e  
re gulations  and  nationally-ratifie d 
laws, 
inte rnational 
conve ntions  and 
agre ements. 

tre atie s, 

Anne x A 
“1.4 Harvesting permits  
National or sub-national laws and re gulations 
re gulating procedures for issuing harvesting 
pe rm its, licenses or other le gal* documents 
re quire d for specific harvesting operations. 
This includes the use of legal* methods to 

523 

F i ndings 

FM C e rtification: Covered. 

FM C W  C ertification: 
C ove red. 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 
and agreements. Annex A gives an outline 
of all types to be included. Section 1.4 of 
the  Annex is on harvesting permits, whe re 
all aspects of this requirement are  explicitly 
include d.   

The  four national level evaluations 
corroborate the findings at the international 
le ve l (see report Annexes for details). 

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 
applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. A norm ative Advice Note for this 
re quirement contains a list of applicable 
National and Local Laws and Regulations 
that m ust be complied with, superseding 
Table 1 in the standard. This list covers 

 
 
 
 
 
 
 
 
 
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C ode 

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I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

obtain the permits. C orruption is a we ll-known 
issue that is connected with the  issuing of 
harve sting permits.” 

FSC -STD-30-010 V2-0 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

harve sting permits. 

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

FSC -ADV-30-010 V1-0 Dated 10 July 2014 

J ustification 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d. 

A . 1a.2.1 

A .1a.2 Payments f or harvest 
r ig hts a nd timber including 
d uties r elated to timber 
ha rvesting 
Paym ent of 
royaltie s and 
harve sting 
fe e s 

A . 1a.2.1.1 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
le gislation 
cove ring 
paym ent of all 
le gally re quire d 
fore st 
harve sting-

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

F i ndings 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

FSC -STD-60-004 V2-0 

1.3 Instructions for Standard De velopers: 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 
and agreements. Annex A gives an outline 
of all types to be included. Section 2.1 of 
the  Annex is dedicated to the payment of 
royaltie s and harvesting fees. It explicitly 
re fe rs to “royalties, stumpage fees and 

524 

FM C e rtification: Partially 
C ove red. 

FM C W  C ertification: 
C ove red. 

 
 
 
 
  
 
 
 
 
 
 
 
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C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

spe cific fees 
such as 
royaltie s, 
stum page fees 
and other 
volum e-based 
fe e s, as we ll as 
land area taxes 
or fe e s. 

“Standard De velopers shall* complete a list of all 
applicable laws*, obligatory codes of  p ract i ce * 
and le gal* and customary rights* at the national 
and,  whe re   applicable ,  sub -national le ve l as 
outlined in Annex A.” 

Principle 1, Annex A: Minimum list of appli cabl e  
re gulations  and  nationally-ratifie d 
laws, 
conve ntions  and 
inte rnational 
agre ements. 

tre atie s, 

Anne x A: 
“2.1 Payment of royalties and harvesting fees  
Le gislation covering payment of all legally 
re quire d forest* harvesting specific fe es such 
as royalties, stumpage fees and  other 
volum e-based fees. This includes payments of 
the  fe es based on the correct classification of 
quantities, qualities and species. Incorrect 
classification of forest* products is a we ll-
k nown issue that is often combined with 
bribe ry of officials in charge of controlling the 
classification.” 

FSC -STD-30-010 V2-0 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accord ance with the  criteri a 
outlined in table 1.” 

FSC -ADV-30-010 V1-0 DATED 10 JULY 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

othe r volume-based fees” in the examples it 
give s but not land area taxes or fees. 

It doe s, howe ver, specify that the fees shall 
be  based on the correct classification of 
quantities, qualities and species and 
highlights that the incorre ction classification 
of fore st products is a we ll-known issue. 
Howe ve r, this is not reflected in the 
R om anian National Standard.  

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 
applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. A norm ative Advice Note for this 
re quirement contains a list of applicable 
National and Local Laws and Regulations 
that m ust be complied with, superseding 
Table 1 in the standard. This list covers 
paym ent of royalties and harvesting fees. 

The  FSC  Controlled W ood FM s tandard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Partially 
C ove red for FSC  FM certification and 
C ove red for FSC  FM CW ce rtification at the 

525 

 
 
 
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F i ndings and Justification 

C onclusion 

A . 1a.2.2 

Value -added 
tax e s and 
othe r sales 
tax e s 

inte rnational le vel. In the case of FM 
ce rtification, while  normative documents 
include  requirements that ensure 
com pliance with le gislation re gulating 
royaltie s, stumpage fees and other volume-
based fees, land area taxes or fees are not 
spe cifically mentioned 

F i ndings 

FM C e rtification: Covered. 

FM C W  C ertification: 
C ove red. 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 
and agreements. Annex A gives an outline 
of all types to be included. Section 2.2 of 
the  Annex is dedicated to Value-added taxes 
and other sales taxes, the te xt of which 
e ffe ctively m irrors this re quirement.  

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 
applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. A norm ative Advice Note for this 
re quirement contains a list of applicable 
National and Local Laws and Regulations 
that m ust be complied with, superseding 
Table 1 in the standard. This list covers 
value -added taxes and other sales taxes. 

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 

A . 1a.2.2.2 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
le gislation 
cove ring 
diffe rent types 
of sales taxes 
that apply to 
the  m aterial 
be ing sold, 
including selling 
m ate rial as 
growing forest 
(standing stock 
sale s). 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

FSC -STD-60-004 V2-0 

1.3 Instructions for Standard De velopers : 

“Standard De velopers shall* complete a list of all 
applicable laws*, obligatory codes of  p ract i ce * 
and le gal* and customary rights* at the national 
and,  whe re   applicable ,  sub -national le ve l as 
outlined in Annex A.” 

Principle 1, Annex A: Minimum list of a ppli cabl e  
re gulations  and  nationally-ratifie d 
laws, 
inte rnational 
conve ntions  and 
agre ements. 

tre atie s, 

Anne x A: 
“2.2 Value added taxes and other sales taxes  
Le gislation covering different types of sales 
tax e s which apply to the material being sold, 
including the sale of material as growing 
fore st* (standing stock sales).” 

526 

 
 
 
 
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C onclusion 

FSC -STD-30-010 V2-0 

C W  SLIMF too.   

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

J ustification 

FSC -ADV-30-010 V1-0 DATED 10 JULY 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d. 

A . 1a.3.1 

A .1a.3 T imber harvesting, 
inc luding environmental a nd 
f o rest legislation including 
f o rest management a nd 
b io diversity c onservation, 
whe re d irectly r elated to 
tim ber harvesting 
Tim ber 
harve sting 
re gulations 

A . 1a.3.1.1 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
le gal obligations 
for harve sting 
te chniques and 
te chnology 
including timing 
of harve st, 
se le ctive 
cutting, shelter 
wood 
re ge neration, 
cle ar fe lling, 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

FSC -STD-60-004 V2-0 

1.3 Instructions for Standard De velopers: 

“Standard De velopers shall* complete a list of all 
applicable laws*, obligatory codes of  p ract i ce * 
and le gal* and customary rights* at the national 
and,  whe re   applicable ,  sub -national le ve l as 
outlined in Annex A.” 

527 

F i ndings 

FM C e rtification: Covered. 

FM C W  C ertification: 
C ove red. 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 
and agreements. Annex A gives an outline 
of all types to be included. Section 3.1 of 
the  Annex is dedicated to Timber harvesting 
re gulations, which specifies all inclusions 
state d in the requirement with two 
e x ce ptions: 

1. 

2. 

Tim ing of harvest 

Mis-use of salvaging permits or, 

 
 
 
 
 
 
 
 
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C onclusion 

transport of 
tim be r from 
fe lling sites and 
se asonal 
lim itations e tc. 

This includes 
the  m is-use of 
salvaging 
pe rm its or other 
spe cific 
m inisterial 
pe rm its, with 
the  inte ntion of 
circum ve nting 
harve st 
re gulations 

A . 1a.3.1.2 The 
Sche m e shall 
include  
re quirements to 
control potential 
ille gal activities 

Principle 1, Annex A: Minimum list of appli cabl e  
re gulations  and  nationally-ratifie d 
laws, 
conve ntions  and 
inte rnational 
agre ements. 

tre atie s, 

Anne x A: 
“3.1 Timber harve sting re gulations 
Any le gal* requirements for harvesting 
te chniques and te chnology including selective 
cutting, shelter wood re generations, clear 
fe lling, transport of timber from the felling 
site , seasonal limitations, etc. Typically this 
include s regulations on the size of felling 
are as, minimum age and/or diameter for 
fe lling activities, and elements that shall* be 
pre se rved during felling, e tc. Establishment of 
sk idding or  hauling trails, road construction, 
drainage systems and bridges, etc., shall* 
also be considered as we ll as the planning and 
m onitoring of harve sting activities. Any legally 
binding codes for harvesting practices shall* 
be  considere d.” 

FSC -STD-30-010 V2-0 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

FSC -ADV-30-010 V1-0 DATED 10 JULY 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

othe r specific ministerial permits. 

Howe ve r, Se ction 3.1 states what 
re gulations are  typically included and 
spe cifies that legally binding codes for 
harve sting practices shall also be 
considered. The situation is the same in the 
C ontrolled W ood system. 

The  four national level evaluations corroborate 
the  findings at the international level (see 
re port Annexes for details). 

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d. 

F i ndings 

FM C e rtification: Covered. 

“1.4 The Organization* shall* develop and 
im plement m easures, and/or shall* e ngage 
with re gulatory agencies, to systematically 
prote ct the Management Unit* from 

C rite rion 1.4 covers the re quirement. The 
Inte rnational Generic Indicators and 
instructions for standard developers guide 
how this is to be incorporated even whe n it 

FM C W  C ertification: 
Partially C overed. 

528 

 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

by third parties 
within the  are a 
m anaged by the 
ope ra  
ion. 

unauthorized or illegal re source use, 
se ttlement and other illegal activities.” 

FSC -STD-60-004 V2-0 

C rite rion  1.4, 
De ve lopers: 

Instructions 

for  Standard 

“Standard De velopers shall* develop 
indicators that apply both whe n the land is 
owne d by a third party and also whe n The 
O rganization* needs to implement a 
collaborative strategy with the re gulatory 
body, landowner and/or other stakeholders to 
pre ve nt, by all re asonable* means, illegal 
activitie s. This C riterion* re cognizes that it is 
not always possible for The O rganization* to 
e nforce protective measures, for e xample 
whe n The  Organization* is not the landowne r 
or doe s not have appropriate le gal* rights of 
control (Indicators 1.4.1 and 1.4.2). 
Me asures to protect the Management Unit* 
from  unauthorized or illegal re source use, 
se ttlement and other illegal* activities 
e m phasize prevention rather than control 
‘afte r the e vent’ and m ay include: 

 Fore st* roads have gates and/or have 
controlled access to areas of high risk*; 

 Te mporary roads are physically closed off 

afte r harvesting; 

 Fore st* roads are patrolled to detect and 

pre ve nt illegal a ccess to the forest*; and 
 Pe rsonnel and re sources have been 

assigned to detect and control illegal activities 
prom ptly, within their le gal* rights*.” 

FSC -STD-30-010 V2-0 

529 

is not possible for C ertificate Holders to 
e nforce protective measures, for e xample, 
whe n the y are not the landowner or they do 
not have appropriate legal rights of control.  

The  four national level evaluations corroborate 
the  findings at the international level (see 
re port Annexes for details). 

It is noted, howe ver, there is no distinction 
be twe e n “illegal” activities conducted under 
customary law and illegal activities 
conducted by outsiders with no customary 
or othe r rights. 

The re  is no re quirement in the Controlled 
W ood Standard covering this requirement. 
Inte rpretation 09 states that conversion 
cause d by illegal activities at the hands of 
third parties shall be considered a non-
conformance but does not refer to any other 
ille gal activities.  

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d for 
FM C e rtification, but Partially Covered for 
FSC  FM C ontrolled W ood whe re the control 
of ille gal activities by third parties is limited 
to ille gal conversion only.  

 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

INT-STD-30-010_09 
“In some concession areas, conversion is 
ofte n being done through illegal logging and 
e ncroachment by parties other than the forest 
m anager. As the primary objective is 
plantation m anagement on such concessions, 
little  or no effort is made to control the illegal 
conve rsion occurring in the natural forests. 
Do the  re quirements of 6.1 apply to activities 
carrie d out by parties other than the forest 
m anager or their contractors? To put another 
way, would uncontrolled illegal activities 
carrie d out by parties other than the FME 
re sulting in conversion of forests 
to non-fore st use on the FMU(s) included in 
the  scope of the e valuation be a 
nonconformance with crite rion 6.1? 
Ye s. As FSC-STD-30-010 is applied at the 
le ve l of the FMU, activities taking place in 
FMUs included in the scope of the ce rtificate 
shall be considered in determining 
conformance with 
the  re quirements, re gardless of who carries 
out the  activities. Therefore , if forest 
conve rsion is occurring as the re sult of illegal 
activitie s within the FMU, this constitutes a 
nonconformance with C lause 6.1.” 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

530 

A . 1a.3.2 

Prote cted 
site s and 
spe cies 

A . 1a.3.2.1 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
le gislation 
re late d to 

F i ndings 

FM C e rtification: Covered. 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally 
ratifie d international tre aties, conventions, 
and agreements. Annex A gives an outline 
of all types to be included. Section 3.2 of 

FM C W  C ertification: 
C ove red. 

 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

prote cte d are as 
as we ll as 
prote cte d, rare, 
or e ndangered 
spe cies, 
including their 
habitats and 
pote ntial 
habitats. 

FSC -STD-60-004 V2-0 

1.3 Instructions for Standard De velopers: 

“Standard De velopers shall* complete a list of all 
applicable laws*, obligatory codes of  p ract i ce * 
and le gal* and customary rights* at the national 
and,  whe re   applicable ,  sub -national le ve l as 
outlined in Annex A.” 

Principle 1, Annex A: Minimum list of appli cabl e  
laws,  re gulations  and  nationally  ratifie d 
inte rnational 
conve ntions,  and 
agre ements. 

tre atie s, 

Anne x A: 
“3.2 Protected sites and species International, 
national, and sub national tre aties, laws, and 
re gulations re lated to protected areas, 
allowable forest* uses and activities, and/or 
rare , thre atened, or e ndangered species, 
including their habitats* and potential 
habitats*.” 

FSC -STD-30-010 V2-0 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

FSC -ADV-30-010 V1-0 DATED 10 JULY 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

the  Annex is dedicated protected sites and 
spe cies, the text of which e ffectively m irrors 
this re quirement. 

The  four national level evaluations 
corroborate the findings at the international 
le ve l (see report Annexes for details). 

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 
applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. A norm ative Advice Note for this 
re quirement contains a list of applicable 
National and Local Laws and Regulations 
that m ust be complied with, superseding 
Table 1 in the standard. This list covers 
prote cte d sites and species. 

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d. 

531 

 
 
 
  
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

A . 1a.3.2.2 
R e quirements 
that e nsure 
com pliance with 
le gislation 
re late d to 
prote cte d are as 
and habitats, 
shall include 
that the  
ide ntification of 
prote cte d are as 
is conducted 
according to the 
le gal 
re quirements. 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

FSC -STD-60-004 V2-0 

1.3 Instructions for Standard De velopers: 

“Standard De velopers shall* complete a list of all 
applicable laws*, obligatory codes of  p ract i ce * 
and le gal* and customary rights* at the national 
and,  whe re   applicable ,  sub -national le ve l as 
outlined in Annex A.” 

Principle 1, Annex A: Minimum list of appli cabl e  
re gulations  and  nationally-ratifie d 
laws, 
inte rnational 
conve ntions  and 
agre ements. 

tre atie s, 

Anne x A: 
“3.3 Environmental re quirements  
National and sub national laws and 
re gulations re lated to the identification and/or 
prote ction* of e nvironmental values* 
including but not limited to those re lating to 
or affe cted by harvesting, acce ptable levels 
for soil damage, e stablishment of buffer zones 
(e .g., along water courses, open are as and 
bre e ding sites), maintenance of re tention 
tre e s on the felling site, seasonal limitations 
of harve sting time, environmental 
re quirements for fore st* machineries, use of 
pe sticides* and other chemicals, biodiversity 
conse rvation*, air quality, protection* and 
re storation* of wate r quality, operation of 

532 

F i ndings 

FM C e rtification: Covered. 

FM C W  C ertification: 
C ove red. 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 
and agreements. Annex A gives an outline 
of all types to be included. Section 3.3 of 
the  Annex is dedicated environmental 
re quirements and includes “laws and 
re gulations re lated to the identification 
and/or protection of environmental values”.  

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 
applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. Table 1 includes the re quirement for 
e vide nce that timber is harvested from 
authorized areas (e.g. not from protected 
are as whe re  harvest is not allowe d). A 
norm ative Advice Note for this re quirement 
contains a list of applicable National and 
Local Laws and R egulations that must be 
com plied with, superseding Table 1 in the 
standard. This describes the minimal list of 
applicable laws, re gulations and 
inte rnational tre aties and conventions that 
shall be considered in re lation to FSC-STD-
30-010 V2-0, highlighting that legislation 
re late d to protected are as as we ll as 
prote cte d, rare or e ndangered species, 
including their habitats and potential 
habitats, is covered. 

 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

re cre ational e quipment, development of n on-
fore stry infrastructure*, mineral e xploration 
and e xtraction, e tc.” 

FSC -STD-30-010 V2-0 

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting  
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d. 

Table 1:  
d) Evide nce that timber is harve sted from 
authorized areas (e.g. not from protected 
are as whe re  harvest is not allowe d). 

FSC -ADV-30-010 V1-0 DATED 10 JULY 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

d) Evide nce that timber is harve sted from 
authorized areas (e.g. not from protected 
are as whe re  harvest is not allowe d) 

3.2 Protected sites and species 
C ove rs le gislation related to protected areas 
as we ll as protected, rare or endangere d 
spe cies, including their habitats and potential 
habitats. 

A . 1a.3.3 

Environmental 
re quirements 

A . 1a.3.3.1 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
le gislation 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

F i ndings 

FM C e rtification: Covered. 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 

FM C W  C ertification: 
C ove red. 

533 

 
 
 
 
 
 
 
  
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

re late d to 
e nvironmental 
im pact 
assessment in 
conne ction with 
harve sting, 
acce ptable 
le ve ls of 
dam age and 
disturbance of 
soil re source s, 
e stablishment 
of buffer zones 
(e .g. along 
wate rcourses, 
ope n areas, 
bre e ding sites), 
m aintenance  of 
re tained tre es 
on fe lling sites, 
se asonal 
lim itations on 
harve sting, and 
e nvironmental 
re quirements 
for fore st 
m achinery. 

Principle 6: 
“The  Organization* shall* maintain, 
conse rve* and/or re store* 
e cosystem services* and environmental 
value s* of the Management Unit*, and shall* 
avoid, repair or m itigate negative 
e nvironmental impacts.” 

“6.1 The Organization* shall* assess 
e nvironmental values* in the Management 
Unit* and those values outside the 
Management Unit* potentially affected by 
m anagement activities. This assessment 
shall* be undertaken with a level of detail, 
scale  and frequency that is proportionate to 
the  scale, intensity and risk* of m anagement 
activitie s, and is sufficient for the purpose of 
de ciding the necessary conservation* 
m e asures, and for detecting and monitoring 
possible negative impacts of those activities.” 

“6.2 Prior to the start of site-disturbing 
activitie s, The Organization* shall* identify 
and assess the scale, intensity and risk* of 
pote ntial impacts of management activities on 
the  ide ntified e nvironmental values*.” 

“6.3 The Organization* shall* identify and 
im plement e ffective actions to prevent 
ne gative impacts of management activities on 
the  e nvironmental values*, and to m itigate 
and re pair those that occur, proportionate to 
the  scale, intensity and risk* of these 
im pacts.” 

FSC -STD-60-004 V2-0 

1.3 Instructions for Standard De velopers: 

“Standard De velopers shall* complete a list of all 
applicable laws*, obligatory codes of  p ract i ce * 

534 

and agreements. Annex A gives an outline 
of all types to be included. Section 3.3 of 
the  Annex is dedicated to e nvironmental 
re quirements and covers all e lements of the 
re quirement; it does not specifically mention 
e nvironmental impact assessment but it is 
considered that this would fall under 
le gislation related to the “protection of 
e nvironmental values”. Furthermore , 
Principle 6 is dedicated to e nvironmental 
value s and impacts and includes three 
crite ria on e nvironmental impact 
assessment.  

The  four national level evaluations 
corroborate the findings at the international 
le ve l (see report Annexes for details). 

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 
applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. A norm ative Advice Note for this 
re quirement contains a list of applicable 
National and Local Laws and Regulations 
that m ust be complied with, superseding 
Table 1 in the standard. This list covers 
e nvironmental re quirements. 

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

and le gal* and customary rights* at the national 
and,  whe re   applicable ,  sub -national le ve l as 
outlined in Annex A.” 

J ustification 

Principle 1, Annex A: Minimum list of appli cabl e  
re gulations  and  nationally-ratifie d 
laws, 
inte rnational 
conve ntions  and 
agre ements. 

tre atie s, 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d. 

Anne x A: 
“3.3 Environmental re quirements  
National and sub national laws and 
re gulations re lated to the identification and/or 
prote ction* of e nvironmental values* 
including but not limited to those re lating to 
or affe cted by harvesting, acce ptable levels 
for soil damage, e stablishment of buffer zones 
(e .g., along water courses, open are as and 
bre e ding sites), maintenance of re tention 
tre e s on the felling site, seasonal limitations 
of harve sting time, environmental 
re quirements for fore st* machineries, use of 
pe sticides* and other chemicals, biodiversity 
conse rvation*, air quality, protection* and 
re storation* of wate r quality, operation of 
re cre ational e quipment, development of non-
fore stry infrastructure*, mineral e xploration 
and e xtraction, e tc.” 

FSC -STD-30-010 V2-0 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

FSC -ADV-30-010 V1-0 DATED 10 JULY 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-

535 

 
 
 
  
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

A . 1a.3.4 

He alth and 
safe ty 

A . 1a.3.4.1 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
He alth & Safety 
le gislation. 

STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

F i ndings 

FM C e rtification: Covered. 

FM C W  C ertification: 
C ove red. 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

Principle 2: 
“The  Organization* shall* maintain or 
e nhance the social and 
e conomic we llbeing of work ers*.” 

“2.3 The Organization* shall* implement 
he alth and safety practice s to protect 
work e rs* from occupational safety and health 
hazards. These practices shall*, proportionate 
to scale , intensity and risk* of management 
activitie s, meet or exce ed the 
re com mendations of the ILO Code of Practice  
on Safety and Health in Forestry W ork.” 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 
and agreements. Annex A gives an outline 
of all types to be included. Section 3.4 of 
the  Annex is dedicated to health and safety, 
the  te x t of which effectively mirrors this 
re quirement. Additionally, C riteria 2.3 
spe cifically re fere nces m eeting (or 
e x ce eding) the re commendations of the ILO 
C ode of Practice on Safety and Health in 
Fore stry W ork.  

The  four national level evaluations 
corroborate the findings at the international 
le ve l (see report Annexes for details). 

FSC -STD-60-004 V2-0 

1.3 Instructions for Standard De velopers: 

“Standard De velopers shall* complete a list of all 
applicable laws*, obligatory codes of  p ract i ce * 
and le gal* and customary rights* at the national 
and,  whe re   applicable ,  sub -national le ve l as 
outlined in Annex A.” 

Principle 1, Annex A: Minimum list of appli cabl e  
re gulations  and  nationally-ratifie d 
laws, 
inte rnational 
conve ntions  and 
agre ements. 

tre atie s, 

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 
applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. A norm ative Advice Note for this 
re quirement contains a list of applicable 
National and Local Laws and Regulations 
that m ust be complied with, superseding 
Table 1 in the standard. This list covers 
he alth and safety, as detailed in this 
re quirement. 

Anne x A: 

536 

 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

“3.4 He alth and safety  
Le gally re quired personal protection* 
e quipment for persons involved in harve sting 
activitie s, implementation of safe felling and 
transport practices, e stablishment of 
prote ction* zones around harvesting sites, 
safe ty requirements for m achinery used, and 
le gally re quire d safety re quirements in 
re lation to chemical usage. The health and 
safe ty requirements that shall* be considered 
re le vant to operations in the fore st* (not 
office  work , or other activities le ss re lated to 
actual 
fore st* operations).” 

FSC -STD-30-010 V2-0 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

FSC -ADV-30-010 V1-0 DATED 10 JULY 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

FSC -STD-60-004 V2-0 

537 

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d. 

F i ndings 

FM C e rtification: Covered. 

FM C W  C ertification: 
C ove red. 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 
and agreements. Annex A gives an outline 
of all types to be included. Section 3.5 of 
the  Annex is dedicated to legal e mployment, 

A . 1a.3.5 

Le gal 
e m ployment 

A . 1a.3.5.1 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
le gislation for 
e m ployment of 
pe rsonnel 
involve d in 

 
 
 
  
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

harve sting (and 
in-forest 
proce ssing) 
activitie s 
including but 
not lim ited to 
re quirements 
for: contracts 
and work ing 
pe rm its, 
obligatory 
insurances, 
ce rtificates of 
com petence  
and other 
training 
re quirements, 
and payment of 
social and 
incom e taxes.  

the  te x t of which effectively mirrors this 
re quirement and A.1a.3.5.2.  

The  four national level evaluations 
corroborate the findings at the international 
le ve l (see report Annexes for details). 

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 
applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. A norm ative Advice Note for this 
re quirement contains a list of applicable 
National and Local Laws and Regulations 
that m ust be complied with, superseding 
Table 1 in the standard. This list covers legal 
e m ployment. 

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d. 

1.3 Instructions for Standard De velopers: 

“Standard De velopers shall* complete a list of all 
applicable laws*, obligatory codes of  p ract i ce * 
and le gal* and customary rights* at the national 
and,  whe re   applicable ,  sub -national le ve l as 
outlined in Annex A.” 

Principle 1, Annex A: Minimum list of appli cabl e  
re gulations  a nd  nationally-ratifie d 
laws, 
inte rnational 
conve ntions  and 
agre ements. 

tre atie s, 

Anne x A: 
“3.5 Le gal* e mployment  
Le gal* re quirements for e mployment of 
pe rsonnel involved in harvesting activities 
including re quirements for contracts and 
work ing permits, re quirements for obligatory 
insurance, re quirements for competence 
ce rtificates and other training re quirements, 
and payment of social and income taxes 
withhe ld by the employer. Also covered are 
the  observance of minimum work ing age and 
m inimum age for personnel involved in 
hazardous work , le gislation against forced and 
com pulsory labor, and discrimination and 
fre e dom of association.” 

FSC -STD-30-010 V2-0 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

FSC -ADV-30-010 V1-0 DATED 10 JULY 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

538 

 
 
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C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

A . 1a.3.5.2 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
le gislation for 
m inimum 
work ing age 
and m inimum 
age  for 
pe rsonnel 
involve d in 
hazardous 
work , 
le gislation 
against forced 
and compulsory 
labour, and 
discrim ination 
and le gislation 
allowing for 
fre e dom of 
association. 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

FSC -STD-60-004 V2-0 

1.3 Instructions for Standard De velopers: 

“Standard De velopers shall* complete a list of all 
applicable laws*, obligatory codes of  p ract i ce * 
and le gal* and customary rights* at the national 
and,  whe re   applicable ,  sub -national le ve l as 
outlined in Annex A.” 

Principle 1, Annex A: Minimum list of appli cabl e  
re gulations  and  nationally-ratifie d 
laws, 
inte rnational 
conve ntions  and 
agre ements. 

tre atie s, 

Anne x A: 
“3.5 Le gal* e mployment  
Le gal* re quirements for e mployment of 
pe rsonnel involved in harvesting activities 
including re quirements for contracts and 
work ing permits, re quirements for obligatory 
insurance, re quirements for competence 
ce rtificates and other training re quirements, 
and payment of social and income taxes 
withhe ld by the employer. Also covered are 
the  observance of minimum work ing age and 
m inimum age for personnel involved in 
hazardous work , le gislation against forced and 
com pulsory labor, and discrimination and 
fre e dom of association.” 

539 

F i ndings 

FM C e rtification: Covered. 

FM C W  C ertification: 
C ove red. 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 
and agreements. Annex A gives an outline 
of all types to be included. Section 3.5 of 
the  Annex is dedicated to legal e mployment, 
the  te x t of which effectively mirrors this 
re quirement and A.1a.3.5.2.  

The  four national level evaluations 
corroborate the findings at the international 
le ve l (see report Annexes for details). 

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 
applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. A norm ative Advice Note for this 
re quirement contains a list of applicable 
National and Local Laws and Regulations 
that m ust be complied with, superseding 
Table 1 in the standard. This list covers legal 
e m ployment. 

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

FSC -STD-30-010 V2-0 

J ustification 

A . 1a.4.1 

A .1a.4 T hird p arties’ legal 
r ig hts c oncerning use and 
te nure that are a ffected b y 
tim ber harvesting 
C ustomary 
rights 

A . 1a.4.1.1 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
re spe ct for 
customary 
te nure  rights 
re le vant to 
fore st 
harve sting 
activitie s. 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

FSC -ADV-30-010 V1-0 DATED 10 JULY 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

FSC -STD-60-004 V2-0 

Principle   1, 
De ve lopers: 

Instructions 

for  Standard 

“Standard De velopers shall*: 

• Ide ntify whe re customary rights* g ove rn  u se  
and  acce ss,  and,  whe re   applicable ,  write  
additional indicators to ensure that these ri g ht s 
to  carry  out  activitie s  within the  scope  of the  
ce rtificate are documented (Indicator 1.1.1); 

•  Ide ntify  the   appropriate   proce ss  that 
re cognizes and grants customary rights* relate d 

540 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d. 

F i ndings 

FM C e rtification: Covered. 

FM C W  C ertification: 
C ove red. 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 
and agreements. Annex A gives an outline 
of all types to be included. Section 4.1 of 
the  Annex is dedicated to customary rights, 
the  te x t of which effectively mirrors this 
re quirement. 

The  four national level evaluations 
corroborate the findings at the international 
le ve l (see report Annexes for details). This 
indicator is not applicable in R omania.  

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 

 
  
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

to  use   and  acce ss  and  how  such re cognize d 
custom ary  rights*  are   to  be   docum e nte d 
(Indicator 1.2.1); 

• Ide ntify whe re customary te nure s* to manage  
and use resources exist at the national level and  
e nsure   that  the se   are   incorporate d  into 
indicators (Indicator 1.2.1).”  

Anne x A: 

applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. A norm ative Advice Note for this 
re quirement contains a list of applicable 
National and Local Laws and Regulations 
that m ust be complied with, superseding 
Table 1 in the standard. This list covers 
customary rights. 

“4.1  C ustom ary  rights*  Le gislation  cove ring 
customary rights* re levant to forest* harvesting  
activitie s, including re quirements co v e ri ng t h e  
sharing of benefits and indigenous rights.” 

FSC -STD-30-010 V2-0 

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

J ustification 

FSC -ADV-30-010 V1-0 DATED 10 JULY 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d. 

A . 1a.4.1.2 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
le gal obligations 
conce rning 
be nefit sharing 
the y have 
ne gotiated with 
com m unities or 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

F i ndings 

FM C e rtification: Covered. 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

Principle 3: 
“The  Organization* shall* identify and 
uphold* Indigenous Peoples’* legal* and 
customary rights* of ownership, use and 
m anagement of land, territories* and 

541 

FM C W  C ertification: 
C ove red. 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 
and agreements. Annex A gives an outline 
of all types to be included. Section 4.1 
include s requirements covering the sharing 
of be nefits, while section 4.3 of the Annex is 
de dicated to indigenous peoples’ rights. 

 
 
  
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

customary 
use rs. E.g. 
social 
agre ements or 
social 
re sponsibility 
agre ements or 
cahie r de 
charge s, 
de pendent on 
the  country. 

re sources affected by management activities.” 

“3.3 In the event of delegation of control over 
m anagement activities, a binding agre ement* 
be twe e n The Organization* and the 
Indigenous Peoples* shall* be concluded 
through Fre e, Prior and Informed C onsent*. 
The  agreement shall* define its duration, 
provisions for re negotiation, re newal, 
te rm ination, economic conditions and other 
te rm s and conditions. The agreement shall* 
m ak e provision for monitoring by Indigenous 
Pe oples of The O rganization*’s compliance  
with its te rm s and conditions.” 

FSC -STD-60-004 V2-0 

Principle   1, 
De ve lopers: 

Instructions 

for  Standard 

“Standard De velopers shall*: 

• Ide ntify whe re customary rights* g ove rn  u se  
and  acce ss,  and,  whe re   applicable ,  write  
additional indicators to ensure that these ri g ht s 
to  carry  out  activitie s  within the  scope  of the  
ce rtificate are documented (Indicator 1.1.1); 

•  Ide ntify  the   appropriate   proce ss  that 
re cognizes and grants customary rights* relate d 
to  use   and  acce ss  and  how  such re cognize d 
custom ary  rights*  are   to  be   docum e nte d 
(Indicator 1.2.1); 

• Ide ntify whe re customary te nure s* to manage  
and use resources exist at the national level and  
e nsure   that  the se   are   incorporate d  into 
indicators (Indicator 1.2.1).”  

Furthe rm ore, Principle 3 is dedicated to 
indigenous peoples’ rights. Criterion 3.3 
provides for an agreement including 
e conomic conditions in the e vent of 
de le gation of control over management 
activitie s. 

The  four national level evaluations 
corroborate the findings at the international 
le ve l (see report Annexes for details). This 
indicator is not applicable in R omania.  

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 
applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. A norm ative Advice Note for this 
re quirement contains a list of applicable 
National and Local Laws and Regulations 
that m ust be complied with, superseding 
Table 1 in the standard. This list covers 
customary rights and explicitly refers to the 
sharing of benefits and indigenous rights. 

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

Anne x A: 

J ustification 

“4.1  C ustom ary  rights*  Le gislation  cove ring 
customary rights* re levant to forest* harvesting  
activitie s, including re quirements co v e ri ng t h e  

Base d on the normative re quirements, this 

542 

 
 
 
 
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C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

sharing of benefits and indigenous rights.” 

indicator has been evaluated as Covere d. 

“4.3 Indigenous Peoples’* rights Legislation that  
re gulates the rights of Indigenous Pe op le s * as  
far as it is re lated to fore stry activities. Poss ib le  
aspects to consider are  land te nure *, and rig ht s 
to  use   ce rtain  fore st*  re late d  re source s and 
practice  traditional activities, which may involv e  
fore st* lands.” 

FSC -STD-30-010 V2-0 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

FSC -ADV-30-010 V1-0 DATED 10 JULY 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

C ontrolled W ood C ategory 2: W ood harvested 
in violation of traditional and civil rights. 
W he re such legislation e xists. 
4.1 C ustomary rights  
Le gislation covering customary rights re levant 
to fore st harvesting activities including 
re quirements covering sharing of benefits and 
indigenous rights. 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

F i ndings 

FM C e rtification: Covered. 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

Principle 3: 
“The  Organization* shall* identify and 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 
and agreements. Annex A gives an outline 
of all types to be included. Section 4.2 of 
the  Annex is dedicated to 'Free, Prior and 

FM C W  C ertification: 
C ove red. 

543 

A . 1a.4.2 

Fre e , Prior 
and Informed 
C onsent 

A . 1a.4.2.1 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
the  
inte rnationally 
adopted 

 
  
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

principles of 
'Fre e , Prior and 
Informed 
C onsent' in 
conne ction with 
granting rights 
to fore st 
m anagement. 

uphold* Indigenous Peoples’* legal* and 
customary rights* of ownership, use and 
m anagement of land, territories* and 
re sources affected by management activities.” 

“3.2 The Organization* shall* re cognize and 
uphold* the legal* and customary rights* of 
Indigenous Peoples* to maintain control over 
m anagement activities within or re lated to the 
Management Unit* to the e xtent necessary to 
prote ct their rights, re sources and lands and 
te rritorie s*. De legation by Indigenous Peoples 
of control over m anagement activities to third 
partie s re quire s Free, Prior and Informed 
C onsent*.” 

Principle 4: 
“The  Organization* shall* contribute to 
m aintaining or enhancing the social and 
e conomic we llbeing of local communities*.” 

““4.2 The O rganization* shall* re cognize and 
uphold* the legal* and customary rights* of 
local communities* to maintain control over 
m anagement activities within or re lated to the 
Management Unit* to the e xtent necessary to 
prote ct their rights, re sources, lands and 
te rritorie s*. De legation by local communities* 
of control over m anagement activities to third 
partie s re quire s Free, Prior and informed 
C onsent*.” 

FSC -STD-60-004 V2-0 

Principle   1, 
De ve lopers: 

Instructions 

for  Standard 

“Standard De velopers shall*: 

Informed C onsent' in connection with 
granting rights to forest m anagement. 

C rite ria 3.2 and 4.2 specify this re quirement 
for indigenous peoples and local 
com m unities, respectively.  

The  four national level evaluations gave 
varying findings at this indicator: it is 
considered for both Russia and China, not 
applicable for R omania and partially covered 
for Brazil (see re port Annexes for details). 
All the  Brazilian FSC standards  for forest 
m anagement e nsure compliance  with FPIC 
in connection with granting rights to forest 
m anagement, howe ver, it is not applied to 
affe cted local communities. This is under 
discussion in the development of the new 
national standard. See C.2.1.1. for how 
de layed transfer of national standards 
im pacts the findings of this study. 

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 
applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. A norm ative Advice Note for this 
re quirement contains a list of applicable 
National and Local Laws and Regulations 
that m ust be complied with, superseding 
Table 1 in the standard. This list covers free, 
Prior and Informed C onsent. 

• Ide ntify whe re customary rights* g ove rn  u se  
and  acce ss,  and,  whe re   applicable ,  write  
additional indicators to ensure that these ri g ht s 

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 

544 

 
 
 
 
 
 
 
 
 
 
 
 
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C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

to  carry  out  activitie s  within the  scope  of the  
ce rtificate are documented (Indicator 1.1.1); 

applies to whole standard, thus, covers FM 
C W  SLIMF too.   

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d for 
FM ce rtification and FSC  FM C ontrolled Wood. 
The  Brazilian standards do not yet apply FPIC 
to local communities, but have ye t to be 
updated to the latest version of the 
Inte rnational FM standard. See C .2.1.1. for 
how de layed transfer of national standards 
im pacts the findings of this study. 

•  Ide ntify  the   appropriate   proce ss  that 
re cognizes and grants customary rights* relate d 
to  use   and  acce s s  and  how  such re cognize d 
custom ary  rights*  are   to  be   docum e nte d 
(Indicator 1.2.1); 

• Ide ntify whe re customary te nure s* to manage  
and use resources exist at the national level and  
e nsure   that  the se   are   incorporate d  into 
indicators (Indicator 1.2.1).”  

Anne x A: 

““4.2 Fre e Prior and Informed Consent*  

Le gislation covering “fre e  pri or a n d i nf orm e d 
conse nt”  in  conne ction  with  the   transfe r  of 
fore st*  m anage m e nt  rights  and  custom ary 
rights* to The Organization* i n  ch arge  o f t h e  
harve sting operation.” 

FSC -STD-30-010 V2-0 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

FSC -ADV-30-010 V1-0 DATED 10 JULY 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

C ontrolled W ood C ategory 2: W ood harvested 
in violation of traditional and civil rights. 
W he re such legislation e xists 

4.2 Fre e  prior and informed consent 

Le gislation covering “fre e prior and informed 

545 

 
 
 
 
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C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

A . 1a.4.3 

Indigenous 
and 
traditional 
pe oples' 
rights 

A . 1a.4.3.1 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
national 
le gislation and 
inte rnational 
conve ntions 
ratifie d that 
re spe ct the 
te nure  rights of 
indigenous and 
tribal pe oples to 
fore st land as 
we ll as the ir 
right to FPIC. 

conse nt” in connection with transfer of forest 
m anagement rights and customary rights to 
the  organisation in charge of the harve sting 
ope ration. 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

Principle 3: 
“The  Organization* shall* identify and 
uphold* Indigenous Peoples’* legal* and 
customary rights* of ownership, use and 
m anagement of land, territories* and 
re sources affected by management activities.” 

“3.2 The Organization* shall* re cognize and 
uphold* the legal* and customary rights* of 
Indigenous Peoples* to maintain control over 
m anagement activities within or re lated to the 
Management Unit* to the e xtent necessary to 
prote ct their rights, re sources and lands and 
te rritorie s*. De legation by Indigenous Peoples 
of control over m anagement activities to third 
partie s re quire s Free, Prior and Informed 
C onsent*.” 

“3.4 The Organization* shall* re cognize and 
uphold* the rights, customs and culture of 
Indigenous Peoples* as defined in the United 
Nations Declaration on the Rights of 
Indigenous Peoples (2007) and ILO 
C onvention 169 (1989).” 

FSC -STD-60-004 V2-0 

Principle   1, 

Instructions 

for  Standard 

546 

F i ndings 

FM C e rtification: Covered. 

FM C W  C ertification: 
C ove red. 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 
and agreements. Annex A gives an outline 
of all types to be included. Section 4.3 of 
the  Annex is dedicated to indigenous 
pe oples’ rights.  

A whole  principle, Principle 3, is dedicated to 
indigenous peoples’ rights. Criterion 3.4 
spe cifically re fers to the United Nations 
De claration on the Rights of Indigenous 
Pe oples (2007) and ILO C onvention 169 
(1989). W hilst Criterion 3.2 provides for 
'Fre e , Prior and Informed C onsent' (FPIC).  

The  four national level evaluations 
corroborate the findings at the international 
le ve l (see report Annexes for details). This 
indicator is not applicable in R omania.  

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 
applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. A norm ative Advice Note for this 
re quirement contains a list of applicable 
National and Local Laws and Regulations 

 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

C ode 

C riterion 

I ndicators 

S t andard re ference 

F i ndings and Justification 

C onclusion 

that m ust be complied with, superseding 
Table 1 in the standard. This list covers 
indigenous and traditional peoples' rights. 

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d. 

De ve lopers: 

“Standard De velopers shall*: 

• Ide ntify whe re customary rights* g ove rn  u se  
and  acce ss,  and,  whe re   applicable ,  write  
additional indicators to ensure that these ri g ht s 
to  carry  out  activitie s  within the  scope  of the  
ce rtificate are documented (Indicator 1.1.1); 

•  Ide ntify  the   appropriate   proce ss  that 
re cognizes and grants customary rights* relate d 
to  use   and  acce ss  and  how  such re cognize d 
custom ary  rights*  are   to  be   docum e nte d 
(Indicator 1.2.1); 

• Ide ntify whe re customary te nure s* to manage  
and use resources exist at the national level and  
e nsure   that  the se   are   incorporate d  into 
indicators (Indicator 1.2.1).”  

Anne x A: 

“4.3 Indigenous Peoples’* rights Legislation that  
re gulates the rights of Indigenous Pe op le s * as  
far as it is re lated to fore stry activities. Poss ib le  
aspects to consider are  land te nure *, and rig ht s 
to  use   ce rtain  fore st*  re late d  re source s and 
practice  traditional activities, which may involv e  
fore st* lands.” 

FSC -STD-30-010 V2-0 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

FSC -ADV-30-010 V1-0 DATED 10 JULY 2014 

A .1a.5 T rade a nd customs, in 
s o  f ar a s the f orest sector is 
c o ncerned 

547 

 
 
 
  
 
 
 
 
 
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C ode 

C riterion 

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S t andard re ference 

F i ndings and Justification 

C onclusion 

A . 1a.5.1 

C lassification 
of species, 
quantities, 
qualities 

A . 1a.5.1.1 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
le gislation 
re gulating how 
harve sted 
m ate rial is 
classified in 
te rm s of 
spe cies, 
Q uantities and 
qualities in 
conne ction with 
trade  and 
transport.  

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

FSC -STD-60-004 V2-0 

1.3 Instructions for Standard De velopers: 

“Standard De velopers shall* complete a list of all 
applicable laws*, obligatory codes of  p ract i ce * 
and le gal* and customary rights* at the national 
and,  whe re   applicable ,  sub -national le ve l as 
outlined in Annex A.” 

Principle 1, Annex A: Minimum list of appli cabl e  
re gulations  and  nationally-ratifie d 
laws, 
inte rnational 
conve ntions  and 
agre ements. 

tre atie s, 

“5.1  C lassification  of  spe cie s,  quantitie s, 
Q ualities  

Le gislation regulating how harvested m aterial  i s  
classifie d  in  te rm s  of  spe cie s,  volum e s  and 
qualities in connection with trade and transport .  
Incorre ct classification of harvested material is a  
we ll-k nown m ethod to re duce or avoid paym e n t  
of le gally prescribed taxes and fees.” 

IGI 1.5.1: 

“1.5.1  C om pliance   with  applicable   national 
laws*,  local  laws*,  ratifie d*  inte rnational 
conve ntions and obligatory code s o f p ract i ce *  
re lating to the transportation and trade of forest  
products  up  to  the   point  of  first  sale   is 
de m onstrated.” 

FSC -STD-30-010 V2-0 

548 

F i ndings 

FM C e rtification: Covered. 

FM C W  C ertification: 
C ove red. 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 
and agreements. Annex A gives an outline 
of all types to be included. Section 5.1 of 
the  Annex is dedicated to classification of 
spe cies, quantities, qualities.  

The  four national level evaluations 
corroborate the findings at the international 
le ve l (see report Annexes for details). 

R e quirement 3.2 of the C ontrolled Wood 
Standard for Forest Management Enterprises 
e x plicitly covers this re quirement, as does 
the  associated re quirement in the Annex for 
SLIMF operations (Annex 2, 3.3). 
R e quirement 3.1 also states that “all 
harve sting shall take place in compliance 
with all laws applicable to harvesting in the 
jurisdiction in accordance with the crite ria 
outlined in table 1”. A normative Advice  
Note  for this requirement contains a list of 
applicable National and Local Laws and 
R e gulations that must be complied with, 
supe rseding Table 1 in the standard. This 
list cove rs classification of species, 
quantities and quantities.  

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to who le standard, thus, covers FM 

 
 
 
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F i ndings and Justification 

C onclusion 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

“3.2. All species, qualities and quantities shall be 
classifie d  and  m e asure d according to le gally 
pre scribed or acceptable standards.”  

Anne x   2:  R e quire m e nts  for  Sm all  &  Low 
Inte nsity Managed Forest (SLIMF) operations  
“3.3. The Forest Management En t e rpri se  s hal l  
de m onstrate   that  spe cie s,  qualitie s  and 
quantities are classified and m easured according 
to le gally-prescribed or acceptable standards  i n 
the  jurisdiction.”  

FSC -ADV-30-010 V1-0 DATED 10 JULY 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

“1.5 The Organization* shall* comply with the 
applicable national laws*, local laws, ratified* 
inte rnational conventions and obligatory codes 
of practice *, relating to the transportation and 
trade  of forest products within and from the 
Management Unit*, and/or up to the point of 
first sale.” 

FSC -STD-60-004 V2-0 

549 

C W  SLIMF too.   

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d. 

F i ndings 

FM C e rtification: Covered. 

FM C W  C ertification: 
C ove red. 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 
and agreements. Annex A gives an outline 
of all types to be included. Section 5.2 of 
the  Annex is dedicated to trade and 
transport, the text of which e ffectively 
m irrors this re quirement. 

C rite rion 1.5 e nsures legal compliance with 
le gislation regarding trade and transport. 
The  International Generic Indicator 1.5.1 

A . 1a.5.2 

Trade  and 
transport 

A . 1a.5.2.1 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
le gally re quire d 
trading permits 
as we ll as 
le gally re quire d 
transport 
docum ents that 
accom pany 
transport of 
wood from  
fore st 

 
 
 
  
 
 
 
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F i ndings and Justification 

C onclusion 

ope rations. 

1.3 Instructions for Standard De velopers: 

state s that this shall be demonstrated.  

“Standard De velopers shall* complete a list of all 
applicable laws*, obligatory codes of  p ract i ce * 
and le gal* and customary rights* at the national 
and,  whe re   applicable ,  sub -national le ve l as 
outlined in Annex A.” 

Principle 1, Annex A: Minimum list of appli cabl e  
re gulations  and  nationally-ratifie d 
laws, 
inte rnational 
conve ntions  and 
agre ements. 

tre atie s, 

“5.2 Trade and transport  

All re quire d trading and transport permits shall * 
e x ist  as  we ll  as  le gally  re quire d  transport 
docum ents which accompany t he  t ra ns port  o f 
wood from  forest* operations.” 

IGI 1.5.1: 

The  four national level evaluations 
corroborate the findings at the international 
le ve l (see report Annexes for details). 

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 
applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. A norm ative Advice Note for this 
re quirement contains a list of applicable 
National and Local Laws and Regulations 
that m ust be complied with, superseding 
Table 1 in the standard. This list covers 
trade  and transport. 

“1.5.1  C om pliance   with  applicable   national 
laws*,  local  laws*,  ratifie d*  inte rnational 
conve ntions and obligatory code s o f p ract i ce *  
re lating to the transportation and trade of forest  
products  up  to  the   point  of  first  sale   is 
de m onstrated.” 

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d. 

FSC -STD-30-010 V2-0 

“3.1. The Forest Management Enterprise shall 
provide ve rifiable evidence of legal authority 
to harve st in the FMU.” 

FSC -ADV-30-010 V1-0 DATED 10 JULY 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

550 

 
 
  
 
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C onclusion 

A . 1a.5.3 

O ffshore 
trading and 
transfer 
pricing 

A . 1a.5.3.1 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
le gislation 
re gulating 
offshore trading 
and transfer 
pricing.  

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

FSC -STD-60-004 V2-0 

1.3 Instructions for Standard De velopers: 

“Standard De velopers s hall* complete a list of all 
applicable laws*, obligatory codes of  p ract i ce * 
and le gal* and customary rights* at the national 
and,  whe re   applicable ,  sub -national le ve l as 
outlined in Annex A.” 

Principle 1, Annex A: Minimum list of appli cabl e  
re gulations  and  nationally-ratifie d 
laws, 
inte rnational 
conve ntions  and 
agre ements. 

tre atie s, 

“5.3 O ffshore trading and transfer pricing 

Le gislation regulating offshore trading. O ffshore  
trading  with  re late d com panie s place d in tax  
have ns, combined with artificial transfer prices is 
a we ll-k nown way to avoid paym e nt  of  l e gal l y  
pre scribe d  tax e s  and  fe e s  to  the   country  of 
harve st and is considere d t o b e  a n i m port an t  
source  of funds that can be used for payment o f 
bribe ry to the forest* operations and person ne l  
involve d  in  the   harve sting  ope ration.  Many 
countrie s have established legislati on co v e ri ng 
transfer pricing and offshore trading. It shoul d*  
be  noted that only transfer pricing and of f shore  
trading, as far as it is legally pro hi bi t e d i n  t he  
country, can be included here.” 

IGI 1.5.1: 

“1.5.1  C om pliance   with  applicable   national 

551 

F i ndings 

FM C e rtification: Covered. 

FM C W  C ertification: 
C ove red. 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 
and agreements. Annex A gives an outline 
of all types to be included. Section 5.3 of 
the  Annex is dedicated to offshore  trading 
and transfer pricing. 

Thre e  of the four national level evaluations 
corroborate the findings at the international 
le ve l, it is not applicable for R ussia, whe re 
no such legislation e xists (see re port 
Anne xes for details). 

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 
applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. A norm ative Advice Note for this 
re quirement contains a list of applicable 
National and Local Laws and Regulations 
that m ust be complied with, superseding 
Table 1 in the standard. This  list covers 
offshore trading and transfer pricing. 

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

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C riterion 

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S t andard re ference 

F i ndings and Justification 

C onclusion 

A . 1a.5.4 

C ustoms 
re gulations 

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d. 

laws*,  local  laws*,  ratifie d*  inte rnational 
conve ntions and obligatory code s o f p ract i ce *  
re lating to the transportation and trade of forest  
products  up  to  the   point  of  first  sale   is 
de m onstrated.” 

FSC -STD-30-010 V2-0 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

FSC -ADV-30-010 V1-0 DATED 10 JULY 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

A . 1a.5.4.1 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
le gislation 
cove ring areas 
such as 
e x port/import 
lice nses, and 
product 
classification 
re late d to 
customs (codes, 
quantities, 
qualities and 
spe cies). 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

F i ndings 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

FSC -STD-60-004 V2-0 

1.3 Instructions for Standard De velopers: 

“Standard De velopers shall* complete a list of all 
applicable laws*, obligatory codes of  p ract i ce * 
and le gal* and customary rights* at the national 
and,  whe re   applicable ,  sub -national le ve l as 
outlined in Annex A.” 

Principle 1, Annex A: Minimum list of appli cabl e  
re gulations  and  nationally-ratifie d 
laws, 
inte rnational 
conve ntions  and 
agre ements. 

tre atie s, 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 
and agreements. Annex A gives an outline 
of all types to be included. Section 5.4 of 
the  Annex is dedicated to customs 
re gulations, the te xt of which effectively 
m irrors this re quirement. 

Thre e  of the four national level evaluations 
corroborate the findings at the international 
le ve l (see report Annexes for details). 
Howe ve r, the R omanian evaluation found 
that although Section 5.4 of the Annex is 
de dicated to custom re gulations, it does not 
include  any applicable legislation and there 
are  no additional clarifications on custom 

552 

FM C e rtification: Partially 
C ove red. 

FM C W  C ertification: 
C ove red. 

 
 
  
 
 
 
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C onclusion 

“5.4 C ustom regulations  

re gulations in the standard. 

C ustom   le gislation  cove ring  are as  such  as 
e x port/import licenses and product classificatio n 
(code s, quantities, qualities and species).” 

IGI 1.5.1: 

“1.5.1  C om pliance   with  app licable   national 
laws*,  local  laws*,  ratifie d*  inte rnational 
conve ntions and obligatory code s o f p ract i ce *  
re lating to the transportation and trade of forest  
products  up  to  the   point  of  first  sale   is 
de m onstrated.” 

FSC -STD-30-010 V2-0 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

FSC -ADV-30-010 V1-0 DATED 10 JULY 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 
applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. A norm ative Advice Note for this 
re quirement contains a list of applicable 
National and Local Laws and Regulations 
that m ust be complied with, superseding 
Table 1 in the standard. This list covers 
customs regulations. 

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Partially 
C ove red for FM C ertification. Whilst the 
inte rnational framework  of the scheme 
provides for full coverage, this has not been 
followe d through in the example of the 
National Standard for R omania.   

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d for 
FM C W  C ertification.  

553 

 
 
 
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F i ndings and Justification 

C onclusion 

A . 1a.5.5 

C ITES 

A . 1a.5.5.1 The 
Sche m e shall 
include  
re quirements 
that e nsure 
com pliance with 
le gislation 
re late d to 
C ITES permits 
(the  C onvention 
on International 
Trade  in 
Endangere d 
Spe cie s of W ild 
Fauna and 
Flora, also 
k nown as the 
W ashington 
C onvention). 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

“1.5 The Organization* shall* comply with the 
applicable national laws*, local laws, ratified* 
inte rnational conventions and obligatory codes 
of practice *, relating to the transportation and 
trade  of forest products within and from the 
Management Unit*, and/or up to the point of 
first sale.” 

FSC -STD-60-004 V2-0 

1.3 Instructions for Standard De velopers: 

“Standard De velopers shall* complete a list of all 
applicable laws*, obligatory codes of  p ract i ce * 
and le gal* and customary rights* at the national 
and,  whe re   applicable ,  sub -national le ve l as 
outlined in Annex A.” 

Principle 1, Annex A: Minimum list of appli cabl e  
re gulations  and  nationally-ratifie d 
laws, 
conve ntions  and 
inte rnational 
agre ements. 

tre atie s, 

“5.5 C ITES  

C ITES permits (the C onvention on Internati onal  
Trade  in Endangered Species of W ild Fauna a nd 
Flora,  also  k nown  as 
the   W ashington 
C onvention).” 

F i ndings 

FM C e rtification: Covered. 

FM C W  C ertification: 
C ove red. 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 
and agreements. Annex A gives an outline 
of all types to be included. Section 5.5 of 
the  Annex is dedicated to C ITES. 

C rite rion 1.5 e nsures legal compliance with 
le gislation regarding trade and transport. 
IGI 1.5.2 specifies that compliance with 
com pliance with C ITES provisions is 
de m onstrated. 

The  four national level evaluations 
corroborate the findings at the international 
le ve l (see report Annexes for details). 

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 
applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. A norm ative Advice Note for this 
re quirement contains a list of applicable 
National and Local Laws and Regulations 
that m ust be complied with, superseding 
Table 1 in the standard. This list covers 
C ITES. 

IGI 1.5.1: 

“1.5.1  C om pliance   with  applicable   national 
laws*,  local  laws*,  ratifie d*  inte rnational 
conve ntions and obligatory code s o f p ract i ce *  
re lating to the transportation and trade of forest  

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 

554 

 
 
 
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F i ndings and Justification 

C onclusion 

products  up  to  the   point  of  first  sale   is 
de m onstrated.” 

C W  SLIMF too.   

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d. 

IGI 1.5.2: 

“1.5.2  C om pliance   with  C ITES  provisions  is 
de m onstrated, including through posse ss ion  of  
ce rtificates for harvest and trade i n  an y  C ITES  
spe cies.” 

FSC -STD-30-010 V2-0 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

FSC -ADV-30-010 V1-0 DATED 10 JULY 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

A . 1a.5.6 

Le gislation 
re quiring due 
dilige nce / 
due  care 
proce dure s 

A . 1a.5.6.1 The 
sche me shall 
include  
re quirements 
that e nsure 
com pliance with 
le gislation 
cove ring due 
dilige nce/due 
care  
proce dure s, 
including e.g. 
due  
dilige nce/due 
care  systems, 
de claration 
obligations, and 

FSC -STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

Principle 1: 
“The  Organization* shall* comply with all 
applicable laws*, 
re gulations and nationally-ratified* 
inte rnational tre aties, 
conve ntions and agreements.” 

FSC -STD-60-004 V2-0 

1.3 Instructions for Standard De velopers: 

“Standard De velopers shall* complete a list of all 
applicable laws*, obligatory codes of  p ract i ce * 
and le gal* and customary rights* at the national 
and,  whe re   applicable ,  sub -national le ve l as 
outlined in Annex A.” 

Principle 1, Annex A: Minimum list of appli cabl e  
re gulations  and  nationally-ratifie d 
laws, 

555 

F i ndings 

FM C e rtification: Covered. 

FM C W  C ertification: 
C ove red. 

Principle 1 re quires compliance with all 
applicable laws. Standard Developers are 
instructe d to complete a minimum list of 
applicable laws, re gulations and nationally-
ratifie d international tre aties, conventions 
and agreements. Annex A gives an outline 
of all types to be included. Section 6.1 of 
the  Annex is dedicated to due diligence / 
due  care procedure s.  

O f the  four national level e valuations this 
indicator is applicable to the Romanian and 
Brazilian National Standards only, which are  
cove re d by re levant indicators (see re port 

 
 
 
  
 
 
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C onclusion 

/or the  k eeping 
of trade  related 
docum ents, 
le gislation 
e stablishing 
proce dure s to 
pre ve nt trade in 
ille gally 
harve sted 
tim be r and 
products 
de rive d from 
such tim ber, 
e tc. 

inte rnational 
agre ements. 

tre atie s, 

conve ntions  and 

Anne xes for details). 

““6.1 Due diligence / due care procedures  

Le gislation  re quiring  due   dilige nce /due   care  
proce dure s, including, e .g., due  d i li ge n ce /du e  
care  systems, declaration obligations, and/or the 
k e e ping of trade re lated documents, e tc.” 

IGI 1.5.1: 

“1.5.1  C om pliance   with  applicable   national 
laws*,  local  laws*,  ratifie d*  inte rnational 
conve ntions and obligatory code s o f p ract i ce *  
re lating to the transportation and trade of forest  
products  up  to  the   point  of  first  sale   is 
de m onstrated.” 

R e quirement 3.1 of the FSC C ontrolled 
W ood standard states that “all harvesting 
shall take place in compliance with all laws 
applicable to harve sting in the jurisdiction in 
accordance with the  crite ria outlined in table 
1”. A norm ative Advice Note for this 
re quirement contains a list of applicable 
National and Local Laws and Regulations 
that m ust be complied with, superseding 
Table 1 in the standard. This list covers 
Le gislation requiring due diligence/due care 
proce dure s. 

FSC -STD-30-010 V2-0 

“3.1.  All  harve sting  shall  tak e   place   in 
com pliance with all laws applicable to harvesting 
in the  jurisdiction in accordance with the  criteri a 
outlined in table 1.” 

The  FSC  Controlled W ood FM standard also 
cove rs SLIMF in Annex 2. The Advice Note 
that updates the applicable legislation 
applies to whole standard, thus, covers FM 
C W  SLIMF too.   

J ustification 

Base d on the normative re quirements, this 
indicator has been evaluated as Covere d. 

FSC -ADV-30-010 V1-0 DATED 10 JULY 2014 

“No ce rtification of C ontrolled W ood to the 
Fore st Management Enterprise standard FSC-
STD-30-010 shall take place after this date 
without the  application of this Advice Note.” 

i) Evide nce of compliance with le gislation 
e stablishing procedure s to prevent trade in 
ille gally harvested timber and products 
de rive d from such timber. 

6.1. Le gislation re quiring due diligence/due 
care  proce dures. Ex amples: US Lacey Act, EU 
Tim ber R egulation, Australian Illegal Logging 
Prohibition Act (foreseen to enter into force 
30/11/14). 

556 

 
 
 
 
 
  
 
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C ode 

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F i ndings and Justification 

C onclusion 

Le gislation requiring due diligence/due care 
proce dure s, including e.g. due diligence/due 
care  systems, declaration obligations, and/or 
the  k e eping of trade re lated documents e tc. 

A.1b Legal Requirements at the forest level – Input from non-certified forest (Controlled Wood) 

This principle relates to how the scheme ensures that Certificate Holders comply with all applicable legislation. This section relates to requirements of the Scheme that applies to Certificate Holders - or 
other entities subject to the normative requirements of the Scheme (e.g. included within the scope of a certified due diligence system) - within the Country of Harvest. 

Due to the size and complexity of the scheme the findings for this section have been split up and reported in two sections. T his section covers (A.1b) non-certified material entering the FSC system via the 
Controlled Wood due diligence system which is implemented by CoC certificate holders (FSC-STD-40-005 and associated documents). The previous sections (A.1 a) focused on full FSC FM certification 
(FSC-STD-01-001, FSC-STD-60-004 and associated documents) and FM Controlled Wood certification (FSC-STD-30-010 and associated documents).  

A.1b.1.1 

A.1b.1 Rights to harvest tim ber 
w ithin legally gazetted 
boundaries  
Land tenure 
and 
management 
rights 

A.1b.1.1.1. The 
Scheme shall 
include 
requirements that 
ensure 
compliance with 
legislation 
covering land 
tenure rights, 
including 
customary rights 
as well as 
management 
rights.  

FSC-STD-40-005  V3-1  Requirements  for  Sourcing  FSC 
Controlled Wood 

Section E: Terms and definitions 
“Risk assessment: An assessment of the risk  of sourcing 
material from unacceptable sources, including risk 

related to origin and mixing material in supply chains. 

There are sev eral types of risk assessment  for origin 
(Figure 1): 

National risk assessment (NRA): An assessment  of the 
risk  of sourcing from unacceptable sources in a given 
country/region, developed according to FSCPRO-60-002 
The Development and Approval of FSC National Risk 
Assessments.  (Source: FSC-PRO-60-002 The 
Development and Approval of FSC National Risk 

557 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1).  

One of the two types of risks  that the DDS shall 
address is the risk  associated with the origin of the 
material, for which Certificate Holders are obliged 
to use “the applicable FSC risk assessment” 
(Clause 3.1). The defi nition of ‘risk assessment’, 
along with Figure 1, given in Section E of the 
standard provides guidance as to which risk 
assessment  is deemed ‘applicable’. A complex 

 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

Assessments) 

NRAs  approved according to FSC-PRO-60-002 V2-0 (‘old 
NRAs’)  remain valid until 31 December 2018. If the NRA is 
not revised according to FSC-PRO-60-002 V3-0 by 31 
December 2018, areas covered become unassessed 
areas. 

Centralized national risk assessment (CNRA): National 
risk  assessment  or part thereof developed by FSC 
International Center. 

NOTE: NRA and CNRA are collectively referred to as FSC 
risk  assessment. 
Company risk assessment (CRA): An organization’s 
assessment  of the risk  of sourcing from unacceptable 
sources  in unassessed  areas, developed according to 
Annex A of FSC-STD-40-005 V3-1 Requirements for 
Sourcing FSC Controlled Wood. This risk assessment  can 
only be used for a country or part thereof where an FSC 
risk  assessment  for all five controlled wood categories has 
been scheduled by 31 December 2017. 

Extended company risk assessment (ECRA): An 
organization’s assessment  of the risk  of sourcing from 
unacceptable sources in unassessed  areas, developed 
according to FSC-PRO-60-002a FSC National Risk 
Assessment  Framework and the standard FSC-STD-40-
005 V3-1 Requirements for Sourcing FSC Controlled 
Wood. 

The risk assessment  of mixing material in supply chains is 
conducted by the organization for its supply chains.” 

“Figure 1. The hierarchy of risk assessments  that may be 
used for the implementation of this standard. The highest 
listed risk assessment  that exists for the supply area shall 
be used (beginning with 1. National risk assessment 
(NRA)  developed according to FSC-PRO-60-002 V3-0). 
For the list of approved NRAs, and information about the 
version of FSC-PRO-60-002 
used for NRA development, see FSC-PRO-60-002b List of 
FSC Approved Controlled Wood Documents. 

1.  National risk assessment  (NRA) developed 
according to FSC-PRO-60-002 V3-0  
Shall be used by the organization if it exists. 

558 

transition process from older requirements ended 
in 2019 meaning that all applicable FSC ri sk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legality assessment). 
Table 1 covers land tenure and management 
rights, including customary rights. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 

 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

2.  Centralized national risk assessment  (CNRA) 

evaluated as Covered. 

Shall be used if completed for all five controlled 
wood categories, where there is no NRA 
developed according to FSC-PRO-60-002 V3-0, 
and instead of an NRA developed according to 
FSC-PRO-60-002 V2-0. 

3.  National risk assessment  (NRA) developed 

according to FSC-PRO-60-002 V2-0 (‘old 
NRAs’) 
Shall be used if there is neither an NRA 
developed according to FSCPRO-60-002 V3-0 
nor a completed CNRA. It shall not be used 
after 31 December 2018. 
4.  Company risk assessment 

May only be conducted while waiting for the 
delivery of the NRA or CNRA where these are 
scheduled. 
OR 
Extended company risk assessment 
May only be conducted for unassessed risk 
areas where there is no FSC risk  assessment 
available.” 

PART I DUE DILIGENCE SYSTEM 
“3.1 The organization shall use the applicable FSC risk 
assessment  to determine the risk related to the origin of 
the material for each controlled wood category.” 

“3.3 Risk  assessment  of unassessed  areas shall only be 
possible according to the following: 
a) The organization may conduct its own risk  assessment 
according to the requirements in Annex A; and 
b) The organization shall obtain approval of its risk 
assessment,  conducted for its supply area, and/or 
extended to new supply areas, from the certification body 
before using risk designations in its DDS.” 

Annex A - Risk  assessment  by the organization 

“1.1 The organization may conduct the following risk 
assessments  for unassessed  areas (Figure 5): 
a) Company risk assessment  – according to Section 3 
below, and only where an FSC risk assessment  for all five 
controlled wood categories has been scheduled12 by 31 
December 2017; or 

559 

 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

b) Extended company risk assessment  – according to 
Section 2 below, irrespective of whether or not an FSC 
risk  assessment  is scheduled.” 

“2.1 An extended company risk assessment  shall be 
conducted according to the risk assessment  requirements 
in FSC-PRO-60-002a FSC National Risk Assessment 
Framework.” 

FSC-PRO-60-002  V3-0 The Development and Approval of 
FSC National Risk Assessments 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

“3.1.1 The scope of Controlled Wood Category 1 cove rs t h e  
risk  assessment  of illegality and includes: 

a) The identification of applicable legislation in the area under 
assessment  for each indicator listed in Table 1. When  t h e re  
are no relevant laws or regulations for a given indicat o r,  t h e 
indicator shall be considered as ‘not applicable’ for th e  a re a  
under assessment. 

NOTE: General types of legislation not specifically lin ke d  t o  
technical 
legislation 
harvesting 
specifications of trucks)  are not considered ‘relevant’. 

regarding 

(e.g., 

the 

b)  An  assessment  of  l aw  enforcement  in  the  area  under 
assessment.” 

Table 1 

1.1 Land tenure and management rights. 

Legislation covering land tenure rights, including cu st o m a ry 
rights as  well as management rights, that includes the use  o f  
legal methods to obtain tenure rights and management rights. 
It also covers  legal business registration and tax registration,  
including relevant legally required licenses. 

FSC-PRO-60-002b  V2-0  List  of  approved  FSC  Controll ed 
Wood documents 

“1.2  If  an  ‘old  NRA’  is  not  replaced  by  the  FSC  risk 
assessment  approved  according  to  FSC-PRO-60-002 V3-0 
by 30 June 2019, the area covered in the ‘old NRA’ becomes 

560 

 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

unassessed  area. Organizations sourcing material fro m  t h is 
area  will  be  required  to  develop  extended  company  risk 
assessments  (ECRA) instead.” 

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

“3.5.1  Risk  designation 
the  assessment  of 
enforcement  of  applicable  legislation.  When  assessing 
applicable indicators and thresholds, the follo win g a sp e ct s 
shall be taken into account: 

involves 

… 

b) Governance assessment of the forestry sector in the a re a  
under  assessment.  For  governance  assessment  different 
sources  of information may be used (see Clause 3.3);  

… 

index 

of  Transparency 

f)  Assessment  of  corruption:  consultation  with  experts (see 
Annex A) shall take place to evaluate the extent of corruption 
in  the  forestry  sector  in  countries  where  the  corruption 
perceptions 
International 
(http://www.transparency.org/research/cpi/overview)  is  less 
than  50,  taking  into  account  corruption  related  to  forestry 
operations.  Special  attention  shall  be  given  to  the 
enforcement of laws requiring approval from pub lic b o di es,  
such  as  harvesting  permits,  concession  licenses,  custom 
declarations, etc., as well as laws relevant to the purchase o f  
forest products or harvesting rights from publicly owned land.” 

A.1b.1.1.2. The 
Scheme shall 
include 
requirements to 
ensure that 
licenses, right of 
tenure and 
management 
rights, have been 
issued: 

i)  according to the 
legally prescribed 
procedure, 

ii) in compliance 
with third parties' 
legal rights 
concerning 
tenure, 

iii) specifying the 
legally-gazetted 
boundaries, and; 

iv) with absence 
of corrupt 
practices. 

561 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1).  

One of the two types of risks  that the DDS shall 
address is the risk  associated with the origin of the 
material, for which Certificate Holders are obliged 
to use “the applicable FSC risk assessment” 
(Clause 3.1). The defi nition of ‘risk assessment’, 
along with Figure 1, given in Section E of the 
standard provides guidance as to which risk 
assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC ri sk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 

 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legality assessment). 
Table 1 covers points i) to iii). 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Requirements addressing corruption within the 
forest sector is included for all risk assessments 
types (FSC-PRO-60-002a, Clause 3.5.1). 

BN 

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

A.1b.1.1.3 The 
Scheme shall 
include 
requirements that 
ensure the 
existence of legal 
business 
registration, and 
other relevant 
legally required 
licenses.  

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.1 Land tenure and management rights. 

Legislation covering land tenure rights, including cu st o m a ry 
rights as  well as management rights, that includes the use  o f  
legal methods to obtain tenure rights and management rights. 
It also covers  legal business registration and tax registration,  
including relevant legally required licenses. 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1).  

One of the two types of risks  that the DDS shall 
address is the risk  associated with the origin of the 
material, for which Certificate Holders are obliged 
to use “the applicable FSC risk assessment” 
(Clause 3.1). The defi nition of ‘risk assessment’, 
along with Figure 1, given in Section E of the 

562 

 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

standard provides guidance as to which risk 
assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC ri sk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legality assessment). 
Table 1 legal covers business registration and tax 
registration, including relevant legally required 
licenses. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Ri sk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 

563 

 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

A.1b.1.2 

Concession 
licenses 

A.1b.1.2.1 The 
Scheme shall 
include 
requirements that 
ensure 
compliance with 
legislation 
regulating 
procedures for the 
issuing of 
concession 
licenses, including 
use of legal 
methods to obtain 
concession 
licenses and that 
licenses are 
covering only 
legally gazetted 
areas 

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.2 Concession licenses. 

regulating  procedures 

Legislation 
forest 
concession  licenses, including the use of legal methods to 
obtain concession licenses. Bribery, corruption and nepotism  
are  particularly  well -known  issues  that  are  connected with 
concession licenses. 

issuing 

for 

564 

standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1).  

One of the two types of risks  that the DDS shall 
address is the risk  associated with the origin of the 
material, for which Certificate Holders are obliged 
to use “the applicable FSC risk assessment” 
(Clause 3.1). The definition of ‘risk assessment’, 
along with Figure 1, given in Section E of the 
standard provides guidance as to which risk 
assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 

 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legality assessment). 
Table 1 covers concession licenses. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

A.1b.1.3 

Management 
and harvesting 
planning 

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.3 Management and harvesting planning. 

legal  requirements  for 
Any  national  or  sub-national 
Management  Planning, 
forest 
inventories, having a forest Management Pla n a n d  re l at e d 
planning and monitoring, impact assessments, consu l t a t i o n  
with  other  entities,  as  well  as  approval of these by legally 
competent authorities. 

including  conducting 

A.1b.1.3.1 The 
Scheme shall 
include 
requirements that 
ensure 
compliance with 
legislation and 
legal obligations 
for management 
planning, 
including 
conducting forest 
inventories, 
having a forest 
management plan 
and related 
planning and 
monitoring. 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1). One of the two types of risks  that the 
DDS shall address is the risk  associated with the 
origin of the material, for which Certificate Holders 
are obliged to use “the applicable FSC risk 
assessment”  (Clause 3.1). The definition of ‘risk 
assessment’,  along with Figure 1, given in Section 
E of the standard provides guidance as to which 
risk  assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 

565 

 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legality assessment). 
Table 1 covers management and harvesting 
planning. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

566 

 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

A.1b.1.3.2 The 
Scheme shall 
include 
requirements that 
all legally required 
planning 
documents have 
been approved 
prior to 
implementation of 
forest harvesting 
activities. 

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.3 Management and harvesting planning. 

legal  requirements  for 
Any  national  or  sub-national 
Management  Planning, 
forest 
inventories, having a forest Management Pla n a n d  re l at e d 
planning and monitoring, impact assessments, consu l t a t i o n  
with  other  entities,  as  well  as  approval of these by legally 
competent authorities. 

including  conducting 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1). One of the two types of risks  that the 
DDS shall address is the risk  associated with the 
origin of the material, for which Certificate Holders 
are obliged to use “the applicable FSC risk 
assessment”  (Clause 3.1). The definition of ‘risk 
assessment’,  along with Figure 1, given in Section 
E of the standard provides guidance as to which 
risk  assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legality assessment). 
Table 1 covers approval of management planning 
activities by legally competent authorities. 

567 

 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1). One of the two types of risks  that the 
DDS shall address is the risk  associated with the 
origin of the material, for which Certificate Holders 
are obliged to use “the applicable FSC risk 
assessment”  (Clause 3.1). The definition of ‘risk 
assessment’,  along with Figure 1, given in Section 
E of the standard provides guidance as to which 
risk  assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 

A.1b.1.4 

Harvesting 
permits 

A.1b.1.4.1 The 
Scheme shall 
include 
requirements that 
ensure 
compliance with 
legislation 
regulating the 
issuing of 
harvesting 
permits, licenses 
or other legal 
documents 
required for 
specific harvesting 
operations. 

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.4 Harvesting permits 

National  or  sub-national  laws  and  regulations  regulating 
procedures  for  issuing  of  harvesting  permits,  licenses,  or 
other  legal  documents  required  for  specific  harvesting 
operations. This includes the use of legal methods to o b t a i n 
the  permits.  Corruption  is  a  well -known  issue  that  is 
connected with the issuing of harvesti ng permits. 

568 

 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legality assessment). 
Table 1 covers harvesting permits. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

A.1b.2.1 

A.1b.2 Paym ents for harvest 
rights and tim ber including 
duties related to tim ber 
harvesting 
Payment of 
royalties and 
harvesting fees 

A.1b.2.1.1 The 
Scheme shall 
include 
requirements that 

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 

569 

 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

ensure 
compliance with 
legislation 
covering payment 
of all legally 
required forest 
harvesting-
specific fees such 
as royalties, 
stumpage fees 
and other volume-
based fees, as 
well as land area 
taxes or fees. 

Framework Procedure 

… 

Table 1 

1.5 Payment of royalties and harvesting fees. 

Legislation  covering  payment of all legally required forest 
harvesting-specific fees such as  royalties, stumpage fees and 
other volume-based fees. This includes payments of the fee s 
based on the correct classification of quantities, qualities and  
species.  Incorrect  classification  of  forest products is a well -
known issue that is often combined with bribery of officials i n  
charge of controlling the classification. 

requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1).  

One of the two types of risks  that the DDS shall 
address is the risk  associated with the origin of the 
material, for which Certificate Holders are obliged 
to use “the applicable FSC risk assessment” 
(Clause 3.1). The definition of ‘risk assessment’, 
along with Figure 1, given in Section E of the 
standard provides guidance as to which risk 
assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legality assessment). 
Table 1 covers payment of royalties and harvesting 
fees. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 

570 

 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1).  

One of the two types of risks  that the DDS shall 
address is the risk  associated with the origin of the 
material, for which Certificate Holders are obliged 
to use “the applicable FSC risk assessment” 
(Clause 3.1). The definition of ‘risk assessment’, 
along with Figure 1, given in Section E of the 
standard provides guidance as to which risk 
assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of Nati onal 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 

A.1b.2.2 

Value-added 
taxes and other 
sales taxes 

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.6 Value added taxes and other sales taxes. 

Legislation covering different types of sales taxes which apply 
to the material being sold, including the sale o f  m a t e ria l a s 
growing forest (standing stock sales). 

A.1b.2.2.2 The 
Scheme shall 
include 
requirements that 
ensure 
compliance with 
legislation 
covering different 
types of sales 
taxes that apply to 
the material being 
sold, including 
selling material as 
growing forest 
(standing stock 
sales). 

571 

 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legality assessment). 
Table 1 covers value-added taxes and other sales 
taxes. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

A.1b.3 Tim ber harvesting, 
including environm ental and 
forest legislation including 
forest m anagement and 
biodiversity conservation, 
w here directly related to tim ber 

572 

 
 
 
 
 
 
A.1b.3.1 

harvesting 

Timber 
harvesting 
regulations 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.8 Timber harvesting regulations. 

Any  legal  requirements  for  harvesting  techniques  and 
technology, 
including  selective  cutting,  shelter  wood 
regenerations, clear felling, transport of timber from the felling 
site,  seasonal  limitations,  etc.  Typically  this  includes 
regulations on the size of felling areas, minimum age a n d / or 
diameter  for  felling  activities,  and  elements  that  shall  be 
preserved  during  felling,  etc.  Establishment  of skidding or 
hauling  trails,  road  construction,  drainage  systems  and 
bridges, etc., shall also be considered as well as the planning 
and monitoring of harvesting activities. Any le g a lly b i nd in g 
codes for harvesting practices shall be considered.  

A.1b.3.1.1 The 
Scheme shall 
include 
requirements that 
ensure 
compliance with 
legal obligations 
for harvesting 
techniques and 
technology 
including timing of 
harvest, selective 
cutting, shelter 
wood 
regeneration, 
clear felling, 
transport of timber 
from felling sites 
and seasonal 
limitations etc. 

This includes the 
mis-use of 
salvaging permits 
or other specific 
ministerial 
permits, with the 
intention of 
circumventing 
harvest 
regulations 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1).  

One of the two types of risks  that the DDS shall 
address is the risk  associated with the origin of the 
material, for which Certificate Holders are obliged 
to use “the applicable FSC risk assessment” 
(Clause 3.1). The defi nition of ‘risk assessment’, 
along with Figure 1, given in Section E of the 
standard provides guidance as to which risk 
assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC ri sk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 

573 

 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legality assessment). 
Table 1 covers timber harvesting regulations. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1). One of the two types of risks  that the 
DDS shall address is the risk  associated with the 
origin of the material, for which Certificate Holders 
are obliged to use “the applicable FSC risk 
assessment”  (Clause 3.1). The definition of ‘risk 
assessment’,  along with Figure 1, given in Section 
E of the standard provides guidance as to which 
risk  assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 

A.1b.3.2 

Protected sites 
and species 

A.1b.3.2.1 The 
Scheme shall 
include 
requirements that 
ensure 
compliance with 
legislation related 
to protected areas 
as well as 
protected, rare, or 
endangered 
species, including 
their habitats and 
potential habitats. 

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.9 Protected sites and species 

International, national, and sub-national treaties,  l a ws,  a n d  
regulations related to protected areas, allowable fore st  u se s 
and  activities,  and/or  rare,  threatened,  or  endangered 
species, including their habitats and potential habitats. 

574 

 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legal ity assessment). 
Table 1 covers protected sites and species. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

A.1b.3.2.2 
Requirements that 
ensure 
compliance with 

As per A.1b.1.1.1. in addition to the following: 

Findings 

Covered 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

The standard ‘Requirements for Sourci ng FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 

575 

 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

legislation related 
to protected areas 
and habitats, shall 
include that the 
identification of 
protected areas is 
conducted 
according to the 
legal 
requirements. 

… 

Table 1 

1.9 Protected sites and species 

International, national, and sub-national treaties,  l a ws,  a n d  
regulations related to protected areas, allowable fore st  u se s 
and  activities,  and/or  rare,  threatened,  or  endangered 
species, including their habitats and potential habitats. 

requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1). One of the two types of risks  that the 
DDS shall address is the risk  associated with the 
origin of the material, for which Certificate Holders 
are obliged to use “the applicable FSC risk 
assessment”  (Clause 3.1). The definition of ‘risk 
assessment’,  along with Figure 1, given in Section 
E of the standard provides guidance as to which 
risk  assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legality assessment). 
Table 1 covers protected sites and species. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 

576 

 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1). One of the two types of risks  that the 
DDS shall address is the risk  associated with the 
origin of the material, for which Certificate Holders 
are obliged to use “the applicable FSC risk 
assessment”  (Clause 3.1). The definition of ‘risk 
assessment’,  along with Figure 1, given in Section 
E of the standard provides guidance as to which 
risk  assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 

A.1b.3.3 

Environmental 
requirements 

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.10 Environmental requirements. 

National and sub-national laws and regulations related to the  
identification  and/or  protection  of  environmental  values 
including but not limited to those relating t o  o r a f f e ct e d  b y 
harvesting, acceptable levels for soil damage, establishmen t  
of  buffer  zones  (e.g., along water courses, open areas and 
breeding sites), maintenance of retention trees on the felli ng  
site, seasonal limitations of harvesting time, en viro nm en t al 
requirements  for  forest  machineries,  use  of pesticides and 
other  chemicals,  biodiversity  conservation,  air  quality, 
protection  and  restoration  of  water  quality,  operation  of 
recreational  equipment,  development  of  non-forestry 
infrastructure, mineral exploration and extraction, etc. 

A.1b.3.3.1 The 
Scheme shall 
include 
requirements that 
ensure 
compliance with 
legislation related 
to environmental 
impact 
assessment  in 
connection with 
harvesting, 
acceptable levels 
of damage and 
disturbance of soil 
resources, 
establishment of 
buffer zones (e.g. 
along 
watercourses, 
open areas, 
breeding sites), 
maintenance of 
retained trees on 
felling sites, 
seasonal 
limitations on 
harvesting, and 
environmental 

577 

 
 
requirements for 
forest machinery. 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legal ity assessment). 
Table 1 covers environmental requirements. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

A.1b.3.4 

Health and 
safety 

A.1b.3.4.1 The 
Scheme shall 
include 
requirements that 
ensure 
compliance with 
Health & Safety 
legislation. 

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.11 Health and safety. 

Legally required personal protection equipment f o r p e rso n s 
involved in harvesting activities, implementation of safe felling 
and  transport  practices,  establishment  of  protection zones 
around  harvesting  sites, safety requirements for machinery 
used, and legally required safety requirements in rela t io n t o  

578 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1). One of the two types of risks  that the 
DDS shall address is the risk  associated with the 
origin of the material, for which Certificate Holders 
are obliged to use “the applicable FSC risk 
assessment”  (Clause 3.1). The definition of ‘risk 

 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

chemical  usage.  The  health  and  safety requirements that 
shall be considered relevant to operations in the f o re st  (n o t  
office  work,  or  other  activities  not  related  to  actual  forest 
operations). 

assessment’,  along with Figure 1, given in Section 
E of the standard provides guidance as to which 
risk  assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legal ity assessment). 
Table 1 covers health and safety. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 

579 

 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

A.1b.3.5 

Legal 
employment 

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.12 Legal employment. 

Legal requirements for employment of personnel involve d  i n 
harvesting activities including requirements for contracts a n d  
working  permits,  requirements  for  obligatory  in surance, 
requirements for competence certificates and other t ra i n in g 
requirements,  and  payment  of  social  and  income  taxes 
withheld by the employer. Also covered are the obse rva n ce 
of  minimum  working  age and minimum age for personnel 
involved  in  hazardous work, legislation against forced and 
compulsory  labor,  and  discrimination  and  freedom  of 
association. 

A.1b.3.5.1 The 
Scheme shall 
include 
requirements that 
ensure 
compliance with 
legislation for 
employment of 
personnel 
involved in 
harvesting (and 
in-forest 
processing) 
activities including 
but not limited to 
requirements for: 
contracts and 
working permits, 
obligatory 
insurances, 
certificates of 
competence and 
other training 
requirements, and 
payment of social 
and income taxes.  

580 

FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1). One of the two types of risks  that the 
DDS shall address is the risk  associated with the 
origin of the material, for which Certificate Holders 
are obliged to use “the applicable FSC risk 
assessment”  (Clause 3.1). The definition of ‘risk 
assessment’,  along with Figure 1, given in Section 
E of the standard provides guidance as to which 
risk  assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legality assessment). 

 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

Table 1 covers legal employment. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1). One of the two types of risks  that the 
DDS shall address is the risk  associated with the 
origin of the material, for which Certificate Holders 
are obliged to use “the applicable FSC risk 
assessment”  (Clause 3.1). The definition of ‘risk 
assessment’,  along with Figure 1, given in Section 
E of the standard provides guidance as to which 
risk  assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.12 Legal employment. 

Legal requirements for employment of personnel involve d  i n 
harvesting activities including requirements for contracts a n d  
working  permits,  requirements  for  obligatory  insurance, 
requirements for competence certificates and other t ra i n in g 
requirements,  and  payment  of  social  and  income  taxes 
withheld by the employer. Also covered are the obse rva n ce 
of  minimum  working  age and minimum age for personnel 
involved  in  hazardous work, legislation against forced and 
compulsory  labor,  and  discrimination  and  freedom  of 
association. 

A.1b.3.5.2 The 
Scheme shall 
include 
requirements that 
ensure 
compliance with 
legislation for 
minimum working 
age and minimum 
age for personnel 
involved in 
hazardous work, 
legislation against 
forced and 
compulsory 
labour, and 
discrimination and 
legislation 
allowing for 
freedom of 
association. 

581 

 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legal ity assessment). 
Table 1 covers legal employment. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

A.1b.4 Third parties’ legal 
rights concerning use and 
tenure that are affected by 
tim ber harvesting 

582 

 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

A.1b.4.1 

Customary 
rights 

A.1b.4.1.1 The 
Scheme shall 
include 
requirements that 
ensure 
compliance with 
respect for 
customary tenure 
rights relevant to 
forest harvesting 
activities. 

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.13 Customary rights. 

Legislation  covering  customary  rights  relevant  to  forest 
harvesting  activities,  including  requirements  covering  the 
sharing of benefits and i ndigenous rights. 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1). One of the two types of risks  that the 
DDS shall address is the risk  associated with the 
origin of the material, for which Certificate Holders 
are obliged to use “the applicable FSC risk 
assessment”  (Clause 3.1). The definition of ‘risk 
assessment’,  along with Figure 1, given in Section 
E of the standard provides guidance as to which 
risk  assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legal ity assessment). 
Table 1 covers customary rights. 

Where an FSC risk  assessment  (NRA/CNRA)  is 

583 

 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1). One of the two types of risks  that the 
DDS shall address is the risk  associated with the 
origin of the material, for which Certificate Holders 
are obliged to use “the applicable FSC risk 
assessment”  (Clause 3.1). The definition of ‘risk 
assessment’,  along with Figure 1, given in Section 
E of the standard provides guidance as to which 
risk  assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.13 Customary rights. 

Legislation  covering  customary  rights  relevant  to  forest 
harvesting  activities,  including  requirements  covering  the 
sharing of benefits and indigenous rights. 

A.1b.4.1.2 The 
Scheme shall 
include 
requirements that 
ensure 
compliance with 
legal obligations 
concerning benefit 
sharing they have 
negotiated with 
communities or 
customary users. 
E.g. social 
agreements or 
social 
responsibility 
agreements or 
cahier de charges, 
dependent on the 
country. 

584 

 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legality assessment). 
Table 1 covers benefit sharing. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

A.1b.4.2 

Free, Prior and 
Informed 
Consent 

A.1b.4.2.1 The 
Scheme shall 
include 
requirements that 
ensure 
compliance with 
the internationally 
adopted principles 

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.14 Free, Prior and Informed Consent. 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 

585 

 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

of 'Free, Prior and 
Informed Consent' 
in connection with 
granting rights to 
forest 
management. 

Legislation  covering  ‘free,  prior  and  informed  consent’  in 
connection with the transfer of forest management rights, and 
customary  rights  to  the  organization  in  charge  of  the 
harvesting operation. 

Category 1). One of the two types of risks  that the 
DDS shall address is the risk  associated with the 
origin of the material, for which Certificate Holders 
are obliged to use “the applicable FSC risk 
assessment”  (Clause 3.1). The definition of ‘risk 
assessment’,  along with Figure 1, given in Section 
E of the standard provides guidance as to which 
risk  assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legal ity assessment). 
Table 1 covers Free, Prior and Informed Consent. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

586 

 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

A.1b.4.3 

Indigenous and 
traditional 
peoples' rights 

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.15 Indigenous peoples’ rights. 

Legislation that regulates the rights of indigenous pe o p l e a s 
far  as  it  is  related  to  forestry  activities. Possible aspects to 
consider  are  land  tenure,  and  rights  to  use  certain  forest 
related  resources  and  practice  traditional  activities, which 
may involve forest lands. 

A.1b.4.3.1 The 
Scheme shall 
include 
requirements that 
ensure 
compliance with 
national legislation 
and international 
conventions 
ratified that 
respect the tenure 
rights of 
indigenous and 
tribal peoples to 
forest land as well 
as their right to 
FPIC. 

587 

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Control led Wood 
Category 1). One of the two types of risks  that the 
DDS shall address is the risk  associated with the 
origin of the material, for which Certificate Holders 
are obliged to use “the applicable FSC risk 
assessment”  (Clause 3.1). The definition of ‘ri sk 
assessment’,  along with Figure 1, given in Section 
E of the standard provides guidance as to which 
risk  assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-

 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legality assessm ent). 
Table 1 covers Indigenous and traditional peoples' 
rights. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified i n the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

A.1b.5.1 

A.1b.5 Trade and custom s, in 
so far as the forest sector is 
concerned 
Classification of 
species, 
quantities, 
qualities 

A.1b.5.1.1 The 
Scheme shall 
include 
requirements that 
ensure 
compliance with 
legislation 
regulating how 
harvested material 
is classified in 
terms of species, 
Quantities and 
qualities in 

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.16 Classification of species, quantities, qualities. 

Legislation regulating how harvested material is classifie d  i n 
terms  of species, volumes and qualities in connection with 
trade  and  transport.  Incorrect  classification  of  harvested 
material is a well-known method to reduce or avoid payme nt  

588 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1). One of the two types of risks  that the 
DDS shall address is the risk  associated with the 
origin of the material, for which Certificate Holders 
are obliged to use “the applicable FSC risk 
assessment”  (Clause 3.1). The definition of ‘risk 

 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

connection with 
trade and 
transport.  

of legally prescribed taxes and fees. 

assessment’,  along with Figure 1, given in Section 
E of the standard provides guidance as to which 
risk  assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legality assessment). 
Table 1 the classification of species, quantities, 
qualities. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 

589 

 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

A.1b.5.2 

Trade and 
transport 

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.17 Trade and transport. 

All required trading and transport permits shall exist  a s we l l  
as  legally  required transport documents which accompany 
the transport of wood from forest operations. 

A.1b.5.2.1 The 
Scheme shall 
include 
requirements that 
ensure 
compliance with 
legally required 
trading permits as 
well as legally 
required transport 
documents that 
accompany 
transport of wood 
from forest 
operations. 

590 

standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1). One of the two types of risks  that the 
DDS shall address is the risk  associated with the 
origin of the material, for which Certificate Holders 
are obliged to use “the applicable FSC risk 
assessment”  (Clause 3.1). The definition of ‘risk 
assessment’,  along with Figure 1, given in Section 
E of the standard provides guidance as to which 
risk  assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 

 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

Table 1. Requirements for legality assessment). 
Table 1 covers trade and transport. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

A.1b.5.3 

Offshore trading 
and transfer 
pricing 

A.1b.5.3.1 The 
Scheme shall 
include 
requirements that 
ensure 
compliance with 
legislation 
regulating 
offshore trading 
and transfer 
pricing.  

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.18 Offshore trading and transfer pricing. 

Legislation regulating offshore trading. Offshore trading wi t h  
related  companies  placed  in  tax  havens,  combined  with 
artificial transfer prices is a well-known way to avoid payment 
of legally prescribed taxes and fees to the country of harve st  
and is considered to be an important source of funds that can 
be used for payment of bribery to the forest opera t i on s a n d  
personnel involved in the harvesting operation. 

Many countries have established legislation covering transfer 
pricing  and  offshore  trading.  It  should  be  noted  that  only 
transfer  pricing  and  offshore  trading,  as  far  as  it  is legally 
prohibited in the country, can be included here. 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1). One of the two types of risks  that the 
DDS shall address is the risk  associated with the 
origin of the material, for which Certificate Holders 
are obliged to use “the applicable FSC risk 
assessment”  (Clause 3.1). The definition of ‘risk 
assessment’,  along with Figure 1, given in Section 
E of the standard provides guidance as to which 
risk  assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 

591 

 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legal ity assessment). 
Table 1 covers offshore training and transfer 
pricing. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

A.1b.5.4 

Customs 
regulations 

A.1b.5.4.1 The 
Scheme shall 
include 
requirements that 

As per A.1b.1.1.1. in addition to the following: 

Findings 

Covered 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 

592 

 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

… 

Table 1 

1.19 Custom regulations. 

Custom  legislation  covering  areas  such  as  export/import 
licenses  and  product  classification  (codes,  quantities, 
qualities and species). 

ensure 
compliance with 
legislation 
covering areas 
such as 
export/import 
licenses, and 
product 
classification 
related to customs 
(codes, quantities, 
qualities and 
species). 

requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1). One of the two types of risks  that the 
DDS shall address is the risk  associated with the 
origin of the material, for which Certificate Holders 
are obliged to use “the applicable FSC risk 
assessment”  (Clause 3.1). The definition of ‘risk 
assessment’,  along with Figure 1, given in Section 
E of the standard provides guidance as to which 
risk  assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Versi on 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legality assessment). 
Table covers customs regulations. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 

593 

 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1). One of the two types of risks  that the 
DDS shall address is the risk  associated with the 
origin of the material, for which Certificate Holders 
are obliged to use “the applicable FSC risk 
assessment”  (Clause 3.1). The definition of ‘risk 
assessment’,  along with Figure 1, given in Section 
E of the standard provides guidance as to which 
risk  assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 

A.1b.5.5 

CITES 

As per A.1b.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.20 CITES. 

CITES  permits  (the  Convention  on  International  Trade in 
Endangered Species of Wild Fauna and Flora, also known as 
the Washington Convention). 

A.1b.5.5.1 The 
Scheme shall 
include 
requirements that 
ensure 
compliance with 
legislation related 
to CITES permits 
(the Convention 
on International 
Trade in 
Endangered 
Species of Wild 
Fauna and Flora, 
also known as the 
Washington 
Convention). 

594 

 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legality assessment). 
Table 1 covers CITES permits. 

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 
standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

A.1b.5.6 

Legislation 
requiring due 
diligence / due 
care procedures 

A.1b.5.6.1 The 
scheme shall 
include 
requirements that 
ensure 
compliance with 
legislation 
covering due 
diligence/due care 
procedures, 
including e.g. due 
diligence/due care 
systems, 

As per A.1.1.1.1. in addition to the following: 

FSC-PRO-60-002a  V1-0  FSC  National  Risk  Assessment 
Framework Procedure 

… 

Table 1 

1.21 Legislation requiring due diligence/due care procedures. 

Legislation  requiring  due  diligence/due  care  procedures, 
including, e.g., due diligence/due care systems, decl a ra t i on  
obligations, and/or the keeping of trade related d o cu me nt s,  
etc. 

Findings 

Covered 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood 
Category 1). One of the two types of risks  that the 
DDS shall address is the risk  associated with the 
origin of the material, for which Certificate Holders 
are obliged to use “the applicable FSC risk 
assessment”  (Clause 3.1). The definition of ‘risk 

595 

 
 
declaration 
obligations, and 
/or the keeping of 
trade related 
documents, 
legislation 
establishing 
procedures to 
prevent trade in 
illegally harvested 
timber and 
products derived 
from such timber, 
etc. 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

assessment’,  along with Figure 1, given in Section 
E of the standard provides guidance as to which 
risk  assessment  is deemed ‘applicable’. A complex 
transition process from older requirements ended 
in 2019 meaning that all applicable FSC risk 
assessments  at the time of writing are required to 
have been developed according to Version 3-0 of 
FSC’s  procedure for the development of National 
Risk  Assessments  (FSC-PRO-60-002). This 
procedure outlines the methodology for 
developing, maintaining, revising, evaluating, and 
approving risk assessments.   

The requirements for the risk  assessments  are 
included in an addendum to the procedure (FSC-
PRO-60-002a) whilst a second addendum lists all 
approved FSC risk  assessments  (FSC-PRO-60-
002b).  

The requirements for FSC risk  assessments  (FSC-
PRO-60-002a) specify the scope of the legality 
assessments  with indicators for all applicable laws, 
regulations and nationally ratified treaties, 
conventions and agreements (Clause 3.1.1. and 
Table 1. Requirements for legality assessment). 
Table 1 includes a section on due diligence / due 
care procedures.  

Where an FSC risk  assessment  (NRA/CNRA)  is 
not available, the Certificate Holder needs to 
develop their own Extended Company Risk 
Assessment  (ECRA) following the same 
requirements specified in the FSC Risk 
assessment  Framework (FSC-PRO-60-002a).  

Justification 

Based on the normative requirements - both for 
standards applicable to certificate holders and 

596 

 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

standards and procedures for the development of 
FSC risk  assessments  - this indicator has been 
evaluated as Covered. 

A.2a Legal requirements for supply chain entities – Certificate holders  

Trade and customs, in so far as the forest sector is concerned. 

This section shall apply to Certificate Holders - or other entities subject to the normative requirements of the Scheme (e.g. included within the scope of a certified due dili gence system) - within the Country 
of Harvest. 

Due to the size and complexity of the scheme the findings for this section have been split up and reported in two sections. This section (A.2 a) focuses Certificate Holders directly, covering the CoC standard, 
which is applicable to all supply chain entities within the FSC system (FSC-STD-40-004 and associated documents). The next section (A.2b) covers non-certified material entering the FSC system via the 
Controlled Wood due diligence system implemented by CoC certificate holders (FSC-STD-40-005 and associated documents) and refers to the non-certified supply chain entities between the forest gate 
and the point of export in the country of harvest. 

A.2a.1. Legal registration 

A.2a.1.1 

Legal 
Registration 

A.2a.1.1.1 The 
scheme shall 
include 
requirements 
that ensure the 
existence of 
legal business 
registration, and 
other relevant 
legally required 
licenses. 

FSC-STD-40-004 V3-0 Chain of Custody Certification 

Findings 

Not Covered 

There are no requirements in the CoC standard 
covering the existence of legal business registration, 
and other relevant legally required licenses, for 
certificate holders.  

Justification 

Based on the lack of normative requirements 
applicable to supply-chain certificate holders, this 
indicator has been evaluated as Not Covered. 

A.2a.2.1 

A.2a.2 Taxes and fees  
Payment of 
taxes, 
royalties and 
fees 

A.2a.2.1.1 The 
Scheme shall 
include 
requirements 

FSC-STD-40-004 V3-0 Chain of Custody Certification 

Findings 

Partially Covered 

“6. Compliance w ith timber legality legislation 
6.1 The organization shall ensure that its FSC-certified 

Requirement 6.1 of the CoC standard requires the 
Certificate Holder to “ensure that its FSC-certified 

597 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
that ensure 
compliance with 
legislation 
covering 
payment of all 
legally required 
taxes, royalties 
and fees. 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

products conform to all applicable timber legality 
legislation”. It lists three “minimum” areas in which 
the Certificate Holder shall comply, covering trade 
and customs laws at import/export, the collection and 
provision of supply chain information and additional 
measures to aid due diligence on pre-consumer 
material being sold into countries where such timber 
legality legislation applies. A footnote to this 
requirement states that the relevant trade and 
customs laws include “but may not be restricted to… 
taxes and duties applying to timber product exports”.  

Whilst the requirement has been made sufficiently 
broad by the terms “at a minimum” and “may not be 
restricted to” to encompass a whole range of 
legislation, its focus is on ‘timber legality legislation’ 
which considers due diligence systems and the 
legality of timber purchases, rather than the legal 
compliance of the Certificate Holder itself, including 
with regards to legislation covering payment of all 
legally required taxes, royalties and fees. It does also 
not ensure that such fees are paid by other potential 
supply-chain entities which may exist in the country 
of harvest.  

Justification 

The normative requirements applicable to supply-
chain certificate holders do not fully cover this 
indicator the scheme include requirements that 
ensure compliance by the Certificate Holder with 
legislation covering payment of all legally required 
taxes, royalties and fees. It has been evaluated as 
Partially Covered. 

products conform to all applicable timber legality legislation. 
At a minimum, the organization shall: 

a. have procedures in place to ensure the import 
and/or export of FSC certified products by the 
organization conform to all applicable trade and 
customs laws1 (if the organization exports and/or 
imports FSC products); 
b. upon request, collect and provide information 
on species (common and scientific name) and 
country of harvest (or more specific location 
details if required by legislation) to direct 
customers and/or any FSC-certified organizations 
further down the supply chain that need this 
information to comply with timber legality 
legislation. The form and frequency of providing 
this information may be agreed upon between the 
organization and the requester; 

NOTE: If the organization does not possess  the requested 
information on species and country of origin, the request 
shall be passed on to the upstream suppliers until the 
information can be obtained. 

c. ensure that FSC-certified products containing 
pre-consumer reclaimed wood (except reclaimed 
paper) being sold to companies located in 
countries where timber legality legislation applies 
either: 

i. only include pre-consumer reclaimed 
wood materials that conform to FSC 
Controlled Wood requirements in 
accordance with FSC-STD-40-005; or 
ii. inform their customers about the 
presence of pre-consumer reclaimed 
wood in the product and support their 
due diligence 
system as  required by applicable timber 
legality legislation. 
NOTE: Organizations applying option c (i) above may apply 
the requirements for co-products outlined in FSC-STD-40-
005.” 

Footnote:  
“1Trade and Customs Laws, 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 

598 

 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

products 
• Official authorisation that entities exporting timber and 
timber products may require 
• Taxes and duties applying to timber product exports” 

“Timber legality legislation: National or international 
legislation established to ban the illegal trade of forest 
products (e.g. EU Timber Regulation (EUTR), US Lacey 
Act, Australian Illegal Logging Prohibition Act).” 

FSC-DIR-40-004 COC DIRECTIVE 2020 
ADVICE-40-004-11 
“FSC certificate holders exporting and/or importing timber or 
timber products shall have procedures in place to ensure 
that the commercialization of FSC certified and FSC 
Controlled Wood products comply with all applicable trade 
and customs laws.” 
FSC-STD-40-004 V3-0 Chain of Custody Certification 

Findings 

Not Covered 

The CoC standard does not reference VAT or other 
types of sales taxes.  

Justification 

Based on the lack of normative requirements 
applicable to supply-chain certificate holders, this 
indicator has been evaluated as Not Covered. 

A.2a.2.2 

Value-added 
taxes and 
other sales 
taxes 

A.2a.2.2.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
covering 
different types 
of sales taxes 
that apply to the 
material being 
sold, including 
selling material 
as growing 
forest (standing 
stock  sales). 

A.2a.3.1 

A.2a.3 Trade and transport 
A.2a.3.1.1 The 
Classification 
Scheme shall 
of species, 
include 
quantities, 
requirements 
qualities 
that ensure 
compliance with 
legislation 

FSC-STD-40-004 V3-0 Chain of Custody Certification 

Findings 

Partially Covered 

“6. Compliance w ith timber legality legislation 
6.1 The organization shall ensure that its FSC-certified 
products conform to all applicable timber legality legislation. 
At a minimum, the organization shall: 

a. have procedures in place to ensure the import 
and/or export of FSC certified products by the 

The CoC standard contains requirements for 
classifying products according to species and product 
type per FSC definitions (Requirements 7.1 and 7.3, 
also see FSC-STD-40-004a FSC Product 
Classification Standard), and for tracking and 

599 

 
 
 
 
 
 
 
 
 
 
 
 
regulating how 
products are 
classified in 
terms of 
species, 
volumes and 
qualities in 
connection with 
trade and 
transport.  

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

organization conform to all applicable trade and 
customs laws1 (if the organization exports and/or 
imports FSC products); 
b. upon request, collect and provide information 
on species (common and scientific name) and 
country of harvest (or more specific location 
details if required by legislation) to direct 
customers and/or any FSC-certified organizations 
further down the supply chain that need this 
information to comply with timber legality 
legislation. The form and frequency of providing 
this information may be agreed upon between the 
organization and the requester; 

NOTE: If the organization does not possess  the requested 
information on species and country of origin, the request 
shall be passed on to the upstream suppliers until the 
information can be obtained. 

c. ensure that FSC-certified products containing 
pre-consumer reclaimed wood (except reclaimed 
paper) being sold to companies located in 
countries where timber legality legislation applies 
either: 

i. only include pre-consumer reclaimed 
wood materials that conform to FSC 
Controlled Wood requirements in 
accordance with FSC-STD-40-005; or 
ii. inform their customers about the 
presence of pre-consumer reclaimed 
wood in the product and support their 
due diligence 
system as  required by applicable timber 
legality legislation. 
NOTE: Organizations applying option c (i) above may apply 
the requirements for co-products outlined in FSC-STD-40-
005.” 

Footnote:  
“1Trade and Customs Laws, 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” 

600 

declaring quantities for sales, but there is no mention 
of legal requirements to verify that classification of 
material meets actual or legal status. 

Requirement 6.1 of the CoC standard requires the 
Certificate Holder to “ensure that its FSC-certified 
products conform to all applicable timber legality 
legislation”. It lists three “minimum” areas in which 
the Certificate Holder shall comply, covering trade 
and customs laws at import/export, the collection and 
provision of supply chain information and additional 
measures to aid due diligence on pre-consumer 
material being sold into countries where such timber 
legality legislation applies. A footnote to this 
requirement states that the relevant trade and 
customs laws include “but may not be restricted to… 
taxes and duties applying to timber product exports” 
but does not mention classification.  

Whilst the requirement has been made sufficiently 
broad by the terms “at a minimum” and “may not be 
restricted to” to encompass a whole range of 
legislation its focus is on ‘timber legality legislation’ 
which considers due diligence systems and the 
legality of timber purchases, rather than the legal 
compliance of the Certificate Holder itself, including 
with regards to product classification.  

Advice Note ADVICE-40-004-10 reinforces 
Requirement 6.1 regarding supply chain information 
and includes ‘Proof of compliance with relevant trade 
and customs laws’ but is no more explicit than the 
standard requirement.  

Justification  

The normative requirements applicable to supply-
chain certificate holders do not fully cover this 
indicator with regards to legislation regulating how 

 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

products are classified. It has been evaluated as 
Partially Covered. 

“Timber legality legislation: National or international 
legislation established to ban the illegal trade of forest 
products (e.g. EU Timber Regulation (EUTR), US Lacey 
Act, Australian Illegal Logging Prohibition Act).” 

“7.1 The organization shall establish product groups for the 
purpose of controlling FSC output claims and labelling. 
Product groups shall be formed by one or more output 
products that: 
a. belong to the same product type in accordance with FSC-
STD-40-004a;” 

“7.3 The organization shall maintain an up-to-date list of 
product groups specifying for each: 
a. the product type(s) of the output products in accordance 
with FSC-STD-40-004a;  
b. the applicable FSC claims for the outputs. The 
organization may also indicate products that are eligible to 
carry the FSC Small and Community Label if the 
organization wants this information to be public in the FSC 
certificate database; 
c. the species (including scientific and common names), 
where the species information designates the product 
characteristics.” 

FSC-STD-40-004a FSC Product Classification Standard  

FSC-DIR-40-004 COC DIRECTIVE 2020 
ADVICE-40-004-10 (although the normative reference is the 
older standard FSC-STD-40-004 V2-1 Clauses 1.4 and 
2.1.1) 

“1. Upon request, FSC certified suppliers shall provide 
customers with the following information about FSC certified 
and FSC Controlled Wood timber 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 FSCSTD- 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 
harvest shall be provided where the risk of illegal harvesting 

601 

 
 
 
 
 
 
 
 
A.2a.3.2 

Trade and 
transport 

A.2a.3.2.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
required trading 
permits as well 
as legally 
required 
transport 
documents that 
accompany 
transport of 
wood. 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

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.” 

FSC-STD-40-004 V3-0 Chain of Custody Certification 

Findings 

Partially Covered 

“6. Compliance w ith timber legality legislation 
6.1 The organization shall ensure that its FSC-certified 
products conform to all applicable timber legality legislation. 
At a minimum, the organization shall: 

a. have procedures in place to ensure the import 
and/or export of FSC certified products by the 
organization conform to all applicable trade and 
customs laws1 (if the organization exports and/or 
imports FSC products);” 

Footnote:  
“1Trade and Customs Laws, 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-DIR-40-004 COC DIRECTIVE 2020 
ADVICE-40-004-11 
“FSC certificate holders exporting and/or importing timber or 
timber products shall have procedures in place to ensure 
that the commercialization of FSC certified and FSC 
Controlled Wood products comply with all applicable trade 
and customs laws.” 

Requirement 6.1 of the CoC standard requires the 
Certificate Holder to “ensure that its FSC-certified 
products conform to all applicable timber legality 
legislation”. One of its three “minimum” areas in 
which the Certificate Holder shall comply refers to 
trade and customs laws at import/export. A footnote 
to this requirement states that the relevant trade and 
customs laws include “but may not be restricted to… 
taxes and duties applying to timber product exports”.  

Whilst the requirement has been made sufficiently 
broad by the terms “at a minimum” and “may not be 
restricted to” to encompass a whole range of 
legislation its examples are all focused on export, 
such that it is not clear that other trading permits as 
well as legally required transport documents that 
accompany transport of wood are to be considered, 
whether by the Certificate Holder itself, nor any other 
supply chain entity.   

Justification 

The normative requirements applicable to supply-
chain certificate holders do not fully cover this 
indicator. It has been evaluated as Partially Covered. 

A.2a.3.3 

Offshore 
trading and 
transfer 
pricing 

A.2a.3.3.1 The 
Scheme shall 
include 
requirements 
that ensure 

FSC-STD-40-004 V3-0 Chain of Custody Certification 

Findings 

Partially Covered 

“6. Compliance w ith timber legality legislation 
6.1 The organization shall ensure that its FSC-certified 
products conform to all applicable timber legality legislation. 
At a minimum, the organization shall: 

Requirement 6.1 of the CoC standard requires the 
Certificate Holder to “ensure that its FSC-certified 
products conform to all applicable timber legality 

602 

 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

compliance with 
legislation 
regulating 
offshore trading.  

a. have procedures in place to ensure the import 
and/or export of FSC certified products by the 
organization conform to all applicable trade and 
customs laws1 (if the organization exports and/or 
imports FSC products);” 

Footnote:  
“1Trade and Customs Laws, 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-DIR-40-004 COC DIRECTIVE 2020 
ADVICE-40-004-11 
“FSC certificate holders exporting and/or importing timber or 
timber products shall have procedures in place to ensure 
that the commercialization of FSC certified and FSC 
Controlled Wood products comply with all applicable trade 
and customs laws.” 
FSC-STD-40-004 V3-0 Chain of Custody Certification 

“6. Compliance w ith timber legality legislation 
6.1 The organization shall ensure that its FSC-certified 
products conform to all applicable timber legality legislation. 
At a minimum, the organization shall: 

a. have procedures in place to ensure the import 
and/or export of FSC certified products by the 
organization conform to all applicable trade and 
customs laws1 (if the organization exports and/or 
imports FSC products);” 

Footnote:  
“1Trade and Customs Laws, 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 

603 

A.2a.3.3.2 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
regulating 
transfer pricing. 

legislation”. One of its three “minimum” areas in 
which the Certificate Holder shall comply refers to 
trade and customs laws at import/export. A footnote 
to this requirement states that the relevant trade and 
customs laws include “but may not be restricted to… 
taxes and duties applying to timber product exports”.  

Whilst the requirement has been made sufficiently 
broad by the terms “at a minimum” and “may not be 
restricted to” to encompass a whole range of 
legislation it does not explicitly refer to offshore 
trading.   

Justification 

The normative requirements applicable to supply-
chain certificate holders do not fully cover this 
indicator. It has been evaluated as Partially Covered. 

Findings 

Partially Covered 

Requirement 6.1 of the CoC standard requires the 
Certificate Holder to “ensure that its FSC-certified 
products conform to all applicable timber legality 
legislation”. One of its three “minimum” areas in 
which the Certificate Holder shall comply refers to 
trade and customs laws at import/export. A footnote 
to this requirement states that the relevant trade and 
customs laws include “but may not be restricted to… 
taxes and duties applying to timber product exports”. 
Whilst the requirement has been made sufficiently 
broad by the terms “at a minimum” and “may not be 
restricted to” to encompass a whole range of 
legislation it does not explicitly refer to transfer 
pricing.   

 
 
 
 
 
 
 
 
 
A.2a.3.4 

Customs 
regulations 

A.2a.3.4.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
covering areas 
such as 
export/import 
licenses, and 
product 
classification 
related to 
customs 
(codes, 
quantities, 
qualities and 
species). 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

• Taxes and duties applying to timber product exports” 

Justification 

FSC-DIR-40-004 COC DIRECTIVE 2020 
ADVICE-40-004-11 
“FSC certificate holders exporting and/or importing timber or 
timber products shall have procedures in place to ensure 
that the commercialization of FSC certified and FSC 
Controlled Wood products comply with all applicable trade 
and customs laws.” 
FSC-STD-40-004 V3-0 Chain of Custody Certification 

Requirement 6.1 
“The organization shall ensure that its FSC-certified 
products conform to all applicable timber legality legislation . 
At a minimum, the organization shall: 

a. 

have procedures in place to ensure the import 
and/or export of FSC certified products by the 
organization conform to all applicable trade and 
customs laws1 (if the organization exports and/or 
imports FSC products);” 

Footnote: 
“1Trade and Customs Laws, 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” 

“7.1 The organization shall establish product groups for the 
purpose of controlling FSC output claims and labelling. 
Product groups shall be formed by one or more output 
products that: 
a. belong to the same product type in accordance with FSC-
STD-40-004a;” 

“7.3 The organization shall maintain an up-to-date list of 
product groups specifying for each: 
a. the product type(s) of the output products in accordance 
with FSC-STD-40-004a;  
b. the applicable FSC claims for the outputs. The 
organization may also indicate products that are eligible to 
carry the FSC Small and Community Label if the 

604 

The normative requirements applicable to supply-
chain certificate holders do not fully cover this 
indicator. It has been evaluated as Partially Covered. 

Findings 

Covered 

The CoC standard contains requirements for 
classifying products according to species and product 
type per FSC definitions (Requirements 7.1 and 7.3, 
also see FSC-STD-40-004a FSC Product 
Classification Standard), and for tracking and 
declaring quantities for sales. 

Requirement 6.1 states that the certification holder 
shall ensure that its FSC-certified products conform 
to all applicable timber legality legislati on. At a 
minimum, this includes having procedures in place to 
ensure the import and/or export of FSC certified 
products by the organization conform to all applicable 
trade and customs laws (if the organization exports 
and/or imports FSC products). A footnote states that 
“Trade and Customs Laws, 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 

It is deemed that the above also covers legal 

 
 
 
 
 
A.2a.3.5 

CITES 

A.2a.3.5.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
related to 
CITES permits 
(the Convention 
on International 
Trade in 
Endangered 
Species of Wild 
Fauna and 
Flora, also 
known as the 
Washington 
Convention). 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

organization wants this information to be public in the FSC 
certificate database; 
c. the species (including scientific and common names), 
where the species information designates the product 
characteristics.” 

FSC-STD-40-004a FSC Product Classification Standard 

requirements relevant to the classification of product 
classification related to customs. 

Justification 

It has been evaluated as Covered. The normative 
requirements applicable to supply-chain certificate 
holders cover this indicator.  

FSC-STD-40-004 V3-0 Chain of Custody Certification 

Findings 

Partially Covered 

The CoC standard does not explicitly reference 
CITES permits or legislation. It is possible that they 
would fall under the first two points of the Trade and 
Customs Laws in Requirement 6.1 but this is not 
clear, nor is it clear from ADVICE-40-004-11 and no 
further guidance is given in the Interpretations for 
CoC.   

Whilst forest material enters the FSC supply chain 
only through two routes (through FSC FM 
certification and as controlled material) which have 
requirements covering CITES, this indicator is 
concerned with the required permits at export from 
the country of harvest, where this is done by a 
different supply chain entity.  

Justification 

The normative requirements applicable to supply-
chain certificate holders do not fully cover this 
indicator. It has been evaluated as Partially Covered. 

Requirement 6.1 
“The organization shall ensure that its FSC-certified 
products conform to all applicable timber legality legislation. 
At a minimum, the organization shall: 

a. 

have procedures in place to ensure the import 
and/or export of FSC certified products by the 
organization conform to all applicable trade and 
customs laws1 (if the organization exports and/or 
imports FSC products);” 

Footnote: 
“1Trade and Customs Laws, 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-DIR-40-004 FSC Directive on Chain of 
Custody Certification - Last Updated: 12 August 2020 
ADVICE-40-004-11 
“FSC certificate holders exporting and/or importing timber or 
timber products shall have procedures in place to ensure 
that the commercialization of FSC certified and FSC 
Controlled Wood products comply with all applicable trade 
and customs laws.” 

Interpretations of the normative framework: Chain of 
Custody – 30 June 2020 

605 

 
 
 
 
 
 
 
A.2a.3.6 

Legislation 
requiring due 
diligence / due 
care 
procedures 

A.2a.3.6.1 The 
scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
covering due 
diligence/due 
care 
procedures, 
including e.g. 
due 
diligence/due 
care systems, 
declaration 
obligations, and 
/or the keeping 
of trade related 
documents, 
legislation 
establishing 
procedures to 
prevent trade in 
illegally 
harvested 
timber and 
products 
derived from 
such timber, 
etc. 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

FSC-STD-40-004 V3-0 Chain of Custody Certification 

Findings 

Partially Covered 

Requirement 6.1 seeks to address compliance with 
timber legality legislation.  

6.1 a (see A.2a.3.4.1 on Customs regulations above) 
requires Certificate Holders to have procedures to 
comply with all trade and customs laws, however, it 
(nor the associated footnote) does not make explicit 
reference to legislation covering due diligence/due 
care procedures. It doesn’t give any detail, nor does 
it reference due diligence/care legislation in its 
examples. 

6.1 b does refer to timber legality legislation in 
reference to collecting and passing on information on 
species and country of harvest. This requirement is 
aimed at Certificate Holders who are not EU 
Operators, specifying that this information shall be 
collected only “upon request”, not systematically. 

The EUTR is only referenced in Annex C – Terms 
and definitions, under Timber Legality Legislation.  

Justification 

The normative requirements applicable to supply-
chain certificate holders do not fully cover this 
indicator. It has been evaluated as Partially Covered. 

“6. Compliance with timber legality legislation 
6.1 The organization shall ensure that its FSC-certified 
products conform to all applicable timber legality legislation. 
At a minimum, the organization shall: 
a. have procedures in place to ensure the import and/or 
export of FSC certified products by the organization 
conform to all applicable trade and customs laws1 (if the 
organization exports and/or imports FSC products); 
b. upon request, collect and provide information on species 
(common and scientific name) and country of harvest (or 
more specific location details if required by legislation) to 
direct customers and/or any FSC-certified organizations 
further down the supply chain that need this information to 
comply with timber legality legislation. The form and 
frequency of providing this information may be agreed upon 
between the organization and the requester; 

NOTE: If the organization does not possess  the requested 
information on species and country of origin, the request 
shall be passed on to the upstream suppliers until the 
information can be obtained. 

c. ensure that FSC-certified products containing pre-
consumer reclaimed wood (except reclaimed paper) being 
sold to companies located in countries where timber legality 
legislation applies either: 
i. only include pre-consumer reclaimed wood materials that 
conform to FSC Controlled Wood requirements in 
accordance with FSC-STD-40-005; or 
ii. inform their customers about the presence of pre-
consumer reclaimed wood in the product and support their 
due diligence system as required by applicable timber 
legality legislation. 

NOTE: Organizations applying option c (i) above may apply 
the requirements for co-products outlined in FSC-STD-40-
005. 

1 Trade and Customs Laws, 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 

606 

 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

• Official authorisation that entities exporting timber and 
timber products may require 
• Taxes and duties applying to timber product exports” 

A.2b Legal requirements for supply chain entities – Non-certified supply chains 

Trade and customs, in so far as the forest sector is concerned. 
This section shall apply to Certificate Holders - or other entities subject to the normative requirements of the Scheme (e.g. included within the scope of a certified due dili gence system) - within the 
Country of Harvest. 

Due to the size and complexity of the scheme the findings for this section have been split up and reported in two sections. This section (A.2 b) covers non-certified material entering the FSC system via 
the Controlled Wood due diligence system implemented by CoC certificate holders (FSC-STD-40-005 and associated documents) and refers to the non-certified supply chain entities between the forest 
gate and the point of export in the country of harvest. The previous section (A.2 a) focuses on Certificate Holders directly, covering the CoC standa rd, which is applicable to all supply chain entities within 
the FSC system  (FSC-STD-40-004 and associated documents).  

A.2b.1. Legal registration 

A.2b.1.1 

Legal 
Registration 

A.2b.1.1.1 The 
scheme shall 
include 
requirements 
that ensure the 
existence of 
legal business 
registration, and 
other relevant 
legally required 
licenses. 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood,  

Findings 

Not Covered 

“2.3 The organization shall have access to information on 
its supply chains (including sub-suppliers) to a level that 
allows it to confirm and document: 
a) The origin of the material; 
b) The risk related to the origin, and the risk related to 
mixing with non-eligible inputs in the supply chain 
(according to Section 3); and 
c) The mitigation of risk (according to Section 4).” 

“3.1 The organization shall use the applicable FSC risk 
assessment  to determine the risk related to the origin of the 
material for each controlled wood category.” 

“3.4 The organization shall assess  and document the risk of 
mixing material with non-eligible inputs in its supply chains 
during transport, processing, and storage.” 

“3.5 The organization may use material as controlled 
material and/or sell it with the FSC Controlled Wood claim if 
it has been confirmed as low risk for all indicators in the 
applicable risk assessment,  and there is no risk  of mixing 
with non-eligible 

607 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood Category 
1). There are requirements for addressing two types 
of risk: 

 

 

Risks  associated with the origin of the material 
(Clause 3.1); and 
The risk of mixing material with non-eligible 
inputs (Clause 3.4). 

The standard does not include requirements for the 
Certificate Holder’s due diligence system to cover the 
legal compliance of supply chain entities (suppliers 
and sub-suppliers). Consequently, it is possible that 
timber that has been l egally harvested and traded at 
the forest level but is subsequently processed and/or 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
A.2b.2 Taxes and fees  

A.2b.2.1 

Payment of 
taxes, 
royalties and 
fees 

A.2b.2.1.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
covering 
payment of all 
legally required 
taxes, royalties 
and fees. 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

inputs in the supply chains.” 

“3.7 Whenever specified or unspecified risk related to origin 
and/or risk related to mixing with non-eligible inputs in the 
supply chain is determined, the organization shall 
implement the requirements of Section 4 before material 
can be used as  controlled material or sold with the FSC 
Controlled Wood claim.” 

Box 3: Where is the risk? 

traded by a supply chain entity that is not legally 
compliant, enters the FSC system as FSC Controlled 
Wood.  

Justification 

The normative requirements applicable to supply-
chain entities (within the country of harvest) included 
within a due diligence system, certified according to 
the Controlled Wood standard FSC-STD-40-005, do 
not cover this indicator. 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood,  

Findings 

Not Covered 

“2.3 The organization shall have access to information on 
its supply chains (including sub-suppliers) to a level that 
allows it to confirm and document: 
a) The origin of the material; 
b) The risk related to the origin, and the risk related to 
mixing with non-eligible inputs in the supply chain 
(according to Section 3); and 
c) The mitigation of risk (according to Section 4).” 

“3.1 The organization shall use the applicable FSC risk 
assessment  to determine the risk related to the origin of the 
material for each controlled wood category.” 

“3.4 The organization shall assess  and document the risk of 
mixing material with non-eligible inputs in its supply chains 
during transport, processing, and storage.” 

“3.5 The organization may use material as controlled 
material and/or sell it with the FSC Controlled Wood claim if 
it has been confirmed as low risk for all indicators in the 
applicable risk assessment,  and there is no risk  of mixing 
with non-eligible 
inputs in the supply chains.” 

“3.7 Whenever specified or unspecified risk related to origin 

608 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood Category 
1). There are requirements for addressing two types 
of risk: 

 

 

Risks  associated with the origin of the material 
(Clause 3.1); and 
The risk of mixing material with non-eligible 
inputs (Clause 3.4). 

The standard does not include requirements for the 
Certificate Holder’s due diligence system to cover the 
legal compliance of supply chain entities (suppliers 
and sub-suppliers). Consequently, it is possible that 
timber that has been legally harvested and traded at 
the forest level but is subsequently processed and/or 
traded by a supply chain entity that is not legally 
compliant, enters the FSC system as FSC Controlled 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
A.2b.2.2 

Value-added 
taxes and 
other sales 
taxes 

A2.2.2.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
covering 
different types of 
sales taxes that 
apply to the 
material being 
sold, including 
selling material 
as growing 
forest (standing 
stock  sales). 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

and/or risk related to mixing with non-eligible inputs in the 
supply chain is determined, the organization shall 
implement the requirements of Section 4 before material 
can be used as  controlled material or sold with the FSC 
Controlled Wood claim.” 

Wood.  

Justification 

Box 3: Where is the risk? 

The normative requirements applicable to supply-
chain entities (within the country of harvest) included 
within a due diligence system, certified according to 
the Controlled Wood standard FSC-STD-40-005, do 
not cover this indicator. 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood,  

Findings 

Not Covered 

“2.3 The organization shall have access to information on 
its supply chains (including sub-suppliers) to a level that 
allows it to confirm and document: 
a) The origin of the material; 
b) The risk related to the origin, and the risk related to 
mixing with non-eligible inputs in the supply chain 
(according to Section 3); and 
c) The mitigation of risk (according to Section 4).” 

“3.1 The organization shall use the applicable FSC risk 
assessment  to determine the risk related to the origin of the 
material for each controlled wood category.” 

“3.4 The organization shall assess  and document the risk of 
mixing material with non-eligible inputs in its supply chains 
during transport, processing, and storage.” 

“3.5 The organization may use material as controlled 
material and/or sell it with the FSC Controlled Wood claim if 
it has been confirmed as low risk for all indicators in the 
applicable risk assessment,  and there is no risk  of mixing 
with non-eligible 
inputs in the supply chains.” 

“3.7 Whenever specified or unspecified risk related to origin 
and/or risk related to mixing with non-eligible inputs in the 
supply chain is determined, the organization shall 
implement the requirements of Section 4 before material 
can be used as  controlled material or sold with the FSC 
Controlled Wood claim.” 

609 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood Category 
1). There are requirements for addressing two types 
of risk: 

 

 

Risks  associated with the origin of the material 
(Clause 3.1); and 
The risk of mixing material with non-eligible 
inputs (Clause 3.4). 

The standard does not include requirements for the 
Certificate Holder’s due diligence system to cover the 
legal compliance of supply chain entities (suppliers 
and sub-suppliers). Consequently, it is possible that 
timber that has been legally harvested and traded at 
the forest level but is subsequently processed and/or 
traded by a supply chain entity that is not legally 
compliant, enters the FSC system as FSC Controlled 
Wood.  

Justification 

 
 
 
 
 
 
 
 
 
 
 
 
A.2b.3 Trade and transport 

A.2b.3.1 

Classification 
of species, 
quantities, 
qualities 

A.2b.3.1.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
regulating how 
products are 
classified in 
terms of 
species, 
volumes and 
qualities in 
connection with 
trade and 
transport.  

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

Box 3: Where is the risk? 

The normative requirements applicable to supply-
chain entities (within the country of harvest) included 
within a due diligence system, certified according to 
the Controlled Wood standard FSC-STD-40-005, do 
not cover this indicator. 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood,  

Findings 

Not Covered 

“2.3 The organization shall have access to information on 
its supply chains (including sub-suppliers) to a level that 
allows it to confirm and document: 
a) The origin of the material; 
b) The risk related to the origin, and the risk related to 
mixing with non-eligible inputs in the supply chain 
(according to Section 3); and 
c) The mitigation of risk (according to Section 4).” 

“3.1 The organization shall use the applicable FSC risk 
assessment  to determine the risk related to the origin of the 
material for each controlled wood category.” 

“3.4 The organization shall assess  and document the risk of 
mixing material with non-eligible inputs in its supply chains 
during transport, processing, and storage.” 

“3.5 The organization may use material as controlled 
material and/or sell it with the FSC Controlled Wood claim if 
it has been confirmed as low risk for all indicators in the 
applicable risk assessment,  and there is no risk  of mixing 
with non-eligible 
inputs in the supply chains.” 

“3.7 Whenever specified or unspecified risk related to origin 
and/or risk related to mixing with non-eligible inputs in the 
supply chain is determined, the organization shall 
implement the requirements of Section 4 before material 
can be used as  controlled material or sold with the FSC 
Controlled Wood claim.” 

Box 3: Where is the risk? 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood Category 
1). There are requirements for addressing two types 
of risk: 

 

 

Risks  associated with the origin of the material 
(Clause 3.1); and 
The risk of mixing material with non-eligible 
inputs (Clause 3.4). 

The standard does not include requirements for the 
Certificate Holder’s due diligence system  to cover the 
legal compliance of supply chain entities (suppliers 
and sub-suppliers). Consequently, it is possible that 
timber that has been legally harvested and traded at 
the forest level but is subsequently processed and/or 
traded by a supply chain entity that is not legally 
compliant, enters the FSC system as FSC Controlled 
Wood.  

Justification 

The normative requirements applicable to supply-
chain entities (within the country of harvest) included 
within a due diligence system, certified according to 

610 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
A.2b.3.2 

Trade and 
transport 

A.2b.3.2.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
required trading 
permits as well 
as legally 
required 
transport 
documents that 
accompany 
transport of 
wood. 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood,  

Findings 

Not Covered 

the Controlled Wood standard FSC-STD-40-005, do 
not cover this indicator. 

“2.3 The organization shall have access to information on 
its supply chains (including sub-suppliers) to a level that 
allows it to confirm and document: 
a) The origin of the material; 
b) The risk related to the origin, and the risk related to 
mixing with non-eligible inputs in the supply chain 
(according to Section 3); and 
c) The mitigation of risk (according to Section 4).” 

“3.1 The organization shall use the applicable FSC risk 
assessment  to determine the risk related to the origin of the 
material for each controlled wood category.” 

“3.4 The organization shall assess  and document the risk of 
mixing material with non-eligible inputs in its supply chains 
during transport, processing, and storage.” 

“3.5 The organization may use material as controlled 
material and/or sell it with the FSC Controlled Wood claim if 
it has been confirmed as low risk for all indicators in the 
applicable risk assessment,  and there is no risk  of mixing 
with non-eligible 
inputs in the supply chains.” 

“3.7 Whenever specified or unspecified risk related to origin 
and/or risk related to mixing with non-eligible inputs in the 
supply chain is determined, the organization shall 
implement the requirements of Section 4 before material 
can be used as  controlled material or sold with the FSC 
Controlled Wood claim.” 

Box 3: Where is the risk? 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood Category 
1). There are requirements for addressing two types 
of risk: 

 

 

Risks  associated with the origin of the material 
(Clause 3.1); and 

The risk of mixing material with non-eligible 
inputs (Clause 3.4). 

The standard does not include requirements for the 
Certificate Holder’s due diligence system to cover the 
legal compliance of supply chain entities (suppli ers 
and sub-suppliers). Consequently, it is possible that 
timber that has been legally harvested and traded at 
the forest level but is subsequently processed and/or 
traded by a supply chain entity that is not legally 
compliant, enters the FSC system as FSC Controlled 
Wood.  

Justification 

The normative requirements applicable to supply-
chain entities (within the country of harvest) included 
within a due diligence system, certified according to 
the Controlled Wood standard FSC-STD-40-005, do 
not cover this indicator. 

A.2b.3.3 

Offshore 
trading and 
transfer 

A.2b.3.3.1 The 
Scheme shall 
include 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood,  

Findings 

Not Covered 

“2.3 The organization shall have access to information on 

The standard ‘Requirements for Sourcing FSC 

611 

 
 
 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

pricing 

requirements 
that ensure 
compliance with 
legislation 
regulating 
offshore trading.  

its supply chains (including sub-suppliers) to a level that 
allows it to confirm and document: 
a) The origin of the material; 
b) The risk related to the origin, and the risk related to 
mixing with non-eligible inputs in the supply chain 
(according to Section 3); and 
c) The mitigation of risk (according to Section 4).” 

“3.1 The organization shall use the applicable FSC risk 
assessment  to determine the risk related to the origin of the 
material for each controlled wood category.” 

“3.4 The organization shall assess  and document the risk of 
mixing material with non-eligible inputs in its supply chains 
during transport, processing, and storage.” 

“3.5 The organization may use material as controlled 
material and/or sell it with the FSC Controlled Wood claim if 
it has been confirmed as low risk for all indicators in the 
applicable risk assessment,  and there is no risk  of mixing 
with non-eligible 
inputs in the supply chains.” 

“3.7 Whenever specified or unspecified risk related to origin 
and/or risk related to mixing with non-eligible inputs in the 
supply chain is determined, the organization shall 
implement the requirements of Section 4 before material 
can be used as  controlled material or sold with the FSC 
Controlled Wood claim.” 

Box 3: Where is the risk? 

Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood Category 
1). There are requirements for addressing two types 
of risk: 

 

 

Risks  associated with the origin of the material 
(Clause 3.1); and 
The risk of mixing material with non-eligible 
inputs (Clause 3.4). 

The standard does not include requirements for the 
Certificate Holder’s due diligence system to cover the 
legal compliance of supply chain entities (suppliers 
and sub-suppliers). Consequently, it is possible that 
timber that has been legally harvested and traded at 
the forest level but is subsequently processed and/or 
traded by a supply chain entity that is not legally 
compliant, enters the FSC system as FSC Controlled 
Wood.  

Justification 

The normative requirements applicable to supply-
chain entities (within the country of harvest) included 
within a due diligence system, certified according to 
the Controlled Wood standard FSC-STD-40-005, do 
not cover this indicator. 

A.2b.3.3.2 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
regulating 
transfer pricing. 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood,  

Findings 

Not Covered 

“2.3 The organization shall have access to information on 
its supply chains (including sub-suppliers) to a level that 
allows it to confirm and document: 
a) The origin of the material; 
b) The risk related to the origin, and the risk related to 
mixing with non-eligible inputs in the supply chain 
(according to Section 3); and 
c) The mitigation of risk (according to Section 4).” 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood Category 
1). There are requirements for addressing two types 

612 

 
 
 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

“3.1 The organization shall use the applicable FSC risk 
assessment  to determine the risk related to the origin of the 
material for each controlled wood category.” 

“3.4 The organization shall assess  and document the risk of 
mixing material with non-eligible inputs in its supply chains 
during transport, processing, and storage.” 

“3.5 The organization may use material as controlled 
material and/or sell it with the FSC Controlled Wood claim if 
it has been confirmed as low risk for all indicators in the 
applicable risk assessment,  and there is no risk  of mixing 
with non-eligible 
inputs in the supply chains.” 

“3.7 Whenever specified or unspecified risk related to origin 
and/or risk related to mixing with non-eligible inputs in the 
supply chain is determined, the organization shall 
implement the requirements of Section 4 before material 
can be used as  controlled material or sold with the FSC 
Controlled Wood claim.” 

Box 3: Where is the risk? 

of risk: 

 

 

Risks  associated with the origin of the material 
(Clause 3.1); and 

The risk of mixing material with non-eligible 
inputs (Clause 3.4). 

The standard does not include requirements for the 
Certificate Holder’s due diligence system to cover the 
legal compliance of supply chain entities (suppliers 
and sub-suppliers). Consequently, it is possible that 
timber that has been legally harvested and traded at 
the forest level but is subsequently processed and/or 
traded by a supply chain entity that is not legally 
compliant, enters the FSC system as FSC Controlled 
Wood.  

Justification 

The normative requirements applicable to supply-
chain entities (within the country of harvest) included 
within a due diligence system, certified according to 
the Controlled Wood standard FSC-STD-40-005, do 
not cover this indicator. 

A.2b.3.4 

Customs 
regulations 

A.2b.3.4.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
covering areas 
such as 
export/import 
licenses, and 
product 
classification 
related to 
customs (codes, 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood,  

Findings 

Not Covered 

“2.3 The organization shall have access to information on 
its supply chains (including sub-suppliers) to a level that 
allows it to confirm and document: 
a) The origin of the material; 
b) The risk related to the origin, and the risk related to 
mixing with non-eligible inputs in the supply chain 
(according to Section 3); and 
c) The mitigation of risk (according to Section 4).” 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood Category 
1). There are requirements for addressing two types 
of risk: 

“3.1 The organization shall use the applicable FSC risk 
assessment  to determine the risk related to the origin of the 
material for each controlled wood category.” 

“3.4 The organization shall assess  and document the risk of 

 

 

Risks  associated with the origin of the material 
(Clause 3.1); and 
The risk of mixing material with non-eligible 
inputs (Clause 3.4). 

613 

 
 
 
 
 
 
 
 
 
 
 
A.2b.3.5 

CITES 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

quantities, 
qualities and 
species). 

A.2b.3.5.1 The 
Scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
related to CITES 
permits (the 
Convention on 
International 
Trade in 
Endangered 
Species of Wild 
Fauna and 
Flora, also 
known as the 
Washington 
Convention). 

mixing material with non-eligible inputs in its supply chains 
during transport, processing, and storage.” 

“3.5 The organization may use material as controlled 
material and/or sell it with the FSC Controlled Wood claim if 
it has been confirmed as low risk for all indicators in the 
applicable risk assessment,  and there is no risk  of mixing 
with non-eligible 
inputs in the supply chains.” 

“3.7 Whenever specified or unspecified risk related to origin 
and/or risk related to mixing with non-eligible inputs in the 
supply chain is determined, the organization shall 
implement the requirements of Section 4 before material 
can be used as  controlled material or sold with the FSC 
Controlled Wood claim.” 

Box 3: Where is the risk? 

The standard does not include requirements for the 
Certificate Holder’s due diligence system to cover the 
legal compliance of supply chain entities (suppliers 
and sub-suppliers). Consequently, it is possible that 
timber that has been legally harvested and traded at 
the forest level but is subsequently processed and/or 
traded by a supply chain entity that is not legally 
compliant, enters the FSC system as FSC Controlled 
Wood. 

Justification 

The normative requirements applicable to supply-
chain entities (within the country of harvest) included 
within a due diligence system, certified according to 
the Controlled Wood standard FSC-STD-40-005, do 
not cover this indicator. 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood,  

Findings 

Not Covered 

“2.3 The organization shall have access to information on 
its supply chains (including sub-suppliers) to a level that 
allows it to confirm and document: 
a) The origin of the material; 
b) The risk related to the origin, and the risk related to 
mixing with non-eligible inputs in the supply chain 
(according to Section 3); and 
c) The mitigation of risk (according to Section 4).” 

“3.1 The organization shall use the applicable FSC risk 
assessment  to determine the risk related to the origin of the 
material for each controlled wood category.” 

“3.4 The organization shall assess  and document the risk of 
mixing material with non-eligible inputs in its supply chains 
during transport, processing, and storage.” 

“3.5 The organization may use material as controlled 
material and/or sell it with the FSC Controlled Wood claim if 
it has been confirmed as low risk for all indicators in the 
applicable risk assessment,  and there is no risk  of mixing 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood Category 
1). There are requirements for addressing two types 
of risk: 

 

 

Risks  associated with the origin of the material 
(Clause 3.1); and 
The risk of mixing material with non-eligible 
inputs (Clause 3.4). 

The standard does not include requirements for the 
Certificate Holder’s due diligence system to cover the 
legal compliance of supply chain entities (suppliers 
and sub-suppliers). Consequently, it is possible that 
timber that has been legally harvested and traded at 
the forest level but is subsequently processed and/or 

614 

 
 
 
 
 
 
 
 
 
A.2b.3.6 

Legislation 
requiring due 
diligence / due 
care 
procedures 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

with non-eligible 
inputs in the supply chains.” 

“3.7 Whenever specified or unspecified risk related to origin 
and/or risk related to mixing with non-eligible inputs in the 
supply chain is determined, the organization shall 
implement the requirements of Section 4 before material 
can be used as  controlled material or sold with the FSC 
Controlled Wood claim.” 

Box 3: Where is the risk? 

traded by a supply chain entity that is not legally 
compliant, enters the FSC system as FSC Controlled 
Wood. 

Justification 

The normative requirements applicable to supply-
chain entities (within the country of harvest) included 
within a due diligence system, certified according to 
the Controlled Wood standard FSC-STD-40-005, do 
not cover this indicator. 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood,  

Findings 

Not Covered 

“2.3 The organization shall have access to information on 
its supply chains (including sub-suppliers) to a level that 
allows it to confirm and document: 
a) The origin of the material; 
b) The risk related to the origin, and the risk related to 
mixing with non-eligible inputs in the supply chain 
(according to Section 3); and 
c) The mitigation of risk (according to Section 4).” 

“3.1 The organization shall use the applicable FSC risk 
assessment  to determine the risk related to the origin of the 
material for each controlled wood category.” 

“3.4 The organization shall assess  and document the risk of 
mixing material with non-eligible inputs in its supply chains 
during transport, processing, and storage.” 

“3.5 The organization may use material as controlled 
material and/or sell it with the FSC Controlled Wood claim if 
it has been confirmed as low risk for all indicators in the 
applicable risk assessment,  and there is no risk  of mixing 
with non-eligible 
inputs in the supply chains.” 

“3.7 Whenever specified or unspecified risk related to origin 
and/or risk related to mixing with non-eligible inputs in the 
supply chain is determined, the organization shall 
implement the requirements of Section 4 before material 

615 

The standard ‘Requirements for Sourcing FSC 
Controlled Wood’ (FSC-STD-40-005) outlines the 
requirements for a due diligence system for FSC 
Chain of Custody certified organisations to avoid 
material from unacceptable sources, including 
illegally harvested wood (Controlled Wood Category 
1). There are requirements for addressing two types 
of risk: 

 

 

Risks  associated with the origin of the material 
(Clause 3.1); and 
The risk of mixing material with non-eligible 
inputs (Clause 3.4). 

The standard does not include requirements for the 
Certificate Holder’s due diligence system to cover the 
legal compliance of supply chain entities (suppliers 
and sub-suppliers). Consequently, it is possible that 
timber that has been legally harvested and traded at 
the forest level but is subsequently processed and/or 
traded by a supply chain entity that is not legally 
compliant, enters the FSC system as FSC Controlled 
Wood.  

A.2b.3.6.1 The 
scheme shall 
include 
requirements 
that ensure 
compliance with 
legislation 
covering due 
diligence/due 
care procedures, 
including e.g. 
due 
diligence/due 
care systems, 
declaration 
obligations, and 
/or the keeping 
of trade related 
documents, 
legislation 
establishing 
procedures to 
prevent trade in 
illegally 
harvested timber 
and products 
derived from 

 
 
 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

such timber, etc. 

can be used as  controlled material or sold with the FSC 
Controlled Wood claim.” 

Justification 

Box 3: Where is the risk? 

The normative requirements applicable to supply-chain 
entities (within the country of harvest) included within a 
due diligence system, certified according to the 
Controlled Wood standard FSC-STD-40-005, do not 
cover this indicator.  

A.3 Requirements for material control 

A.3.1 Material control  

A.3.1.1 

Material origin 
and identification 

A.3.1.1.1 The Scheme shall 
require systematic 
processes  to enable the 
identification of the country 
of harvest of the material, 
and where applicable to a 
higher level of detail, such 
as the sub-national region 
or concession level.  

FSC-STD-40-004 V3-0 
Chain of Custody Certification 

“6. Compliance with timber legality legislation 
6.1 The organization shall ensure that its FSC-certified 
products conform to all applicable timber legality 
legislation. At a minimum, the organization shall: 
b. upon request, collect and provide information on 
species (common and scientific name) and country of 
harvest (or more specific location details if required by 
legislation) to direct customers and/or any FSC-certified 
organizations further down the supply chain that need this 
information to comply with timber legality legislation. The 
form and frequency of providing this information may be 
agreed upon between the organization and the requester; 

NOTE: If the organization does not possess  the requested 
information on species and country of origin, the request 
shall be passed on to the upstream suppliers until the 
information can be obtained.” 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood, Clauses 2.1 – 2.3 

“2.1 The organization shall obtain, document and maintain 
the following up-to-date 
information on material: 
a) Names and addresses  of suppliers; 
b) Description of the material; 
c) Quantity of the material purchased by volume or weight; 

616 

Findings 

Covered 

Requirement 6.1, clause b, of the CoC 
standard requires Certificate Holders to collect 
information country of harvest, or “more 
specific location details if required by 
legislation”. It is only required “upon request”, 
systematic processes  to do so  proacti vely 
(rather than respond to customer requests) and 
always have the information on hand are not 
required, but the requirement to have such a 
system in place is deemed sufficient to cover 
the requirement.    

The FSC CoC Controlled Wood standard 
(FSC-STD-40-005) requires Certificate Holders 
to trace material back to the country of origin, 
or depending on the risk, to a smaller area with 
a homogenous risk designation, so that the risk 
related to the origin of the material can be 
known. 

Justification 

Based on the normative requirements – 

 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

d) The species (including scientific and common name), 
where the species information designates the product 
characteristics and/or where required by appl icable timber 
legality legislation; 

applicable to certificate holders and to material 
from supply-chain entities subject to a due 
diligence system - this indicator has been 
evaluated as Covered. 

NOTE: A list of possible species is acceptable for material 
used in paper, composite board, and other products that 
usually contain many species. 

e) Purchase documentation; 
f) Applicable risk assessment; 
g) The country of harvest, where required by applicable 
timber legality legislation; 
h) Evidence of origin, according to 2.2; and 
i) Information about supply chains, according to 2.3.” 

“2.3 The organization shall have access to information on 
its supply chains (including sub-suppliers) to a level that 
allows it to confirm and document: 
a) The origin of the material; 
b) The risk related to the origin, and the risk related to 
mixing with non-eligible inputs in the supply chain 
(according to Section 3); and 
c) The mitigation of risk (according to Section 4). 

NOTE: Access to information is to be understood as 
having copies of said information on hand during the audit, 
or being able to ensure that, upon request, the certification 
body or Accreditation Services International can obtain 
copies before the close of the audit.” 

A.3.1.1.2 The Scheme shall 
require systematic 
processes  to enable the 
identification of the species 
included in materials or 
products included in the 
scope of certification. 

FSC-STD-40-004 V3-0 
Chain of Custody Certification 

Findings 

Covered 

“6. Compliance with timber legality legislation 
6.1 The organization shall ensure that its FSC-certified 
products conform to all applicable timber legality 
legislation. At a minimum, the organization shall: 
b. upon request, collect and provide information on 
species (common and scientific name) and country of 
harvest (or more specific location details if required by 
legislation) to direct customers and/or any FSC-certified 
organizations further down the supply chain that need this 
information to comply with timber legality legislation. The 
form and frequency of providing this information may be 
agreed upon between the organization and the requester; 

Requirement 6.1, clause b, of the CoC 
standard requires Certificate Holders to collect 
information on species (common and scientific 
name). It is only required “upon request”, 
systematic processes  to do so  proactively 
(rather than respond to customer requests) and 
always have the information on hand are not 
required, but the requirement to have such a 
system in place is deemed sufficient to cover 
the requirement.    

In the FSC CoC Controlled Wood standard 

617 

 
 
 
 
 
 
  
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

(FSC-STD-40-005), information on species is 
only required when the species designates the 
product characteristics and/or when required by 
timber legality legislation. It shall be noted that 
Certificate Holders can only be certified against 
CW when also certified against the CoC 
standard, thus, in practice the requirement is 
captured for both standards by the CoC 
standard. 

Justification 

Based on the normative requirements – 
applicable to certificate holders and to material 
from supply-chain entities subject to a due 
diligence system - this indicator has been 
evaluated as Covered. 

NOTE: If the organization does not possess  the requested 
information on species and country of origin, the request 
shall be passed on to the upstream suppliers until the 
information can be obtained.” 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood, Clause 2.1 

“2.1 The organization shall obtain, document and maintain 
the following up-to-date 
information on material: 
a) Names and addresses  of suppliers; 
b) Description of the material; 
c) Quantity of the material purchased by volume or weight; 
d) The species (including scientific and common name), 
where the species information designates the product 
characteristics and/or where required by applicable timber 
legality legislation; 

NOTE: A list of possible species is acceptable for material 
used in paper, composite board, and other products that 
usually contain many species. 

e) Purchase documentation; 
f) Applicable risk assessment; 
g) The country of harvest, where required by applicable 
timber legality legislation; 
h) Evidence of origin, according to 2.2; and 
i) Information about supply chains, according to 2.3.” 

A.3.1.1.3 The Scheme shall 
include clear and effective 
measures to prevent 
material from non-negligible 
risk,  unverified or 
potentially illegal sources 
from entering the supply 
chain and mixed with 
conforming material. 

FSC-STD-40-004 V3-0 
Chain of Custody Certification Requirements 1.7, 2.4 – 2.6 
and 3.1 

“1.7 The organization shall support transaction 
verification conducted by its certification body and 
Accreditation Services International (ASI), by providing 
samples of FSC transaction data as requested by the 
certification body.” 

“2.4 The organization shall ensure that only eligible inputs 
and the correct material categories are used in FSC 
product groups as defined in Table B. 

Findings  

Covered 

The CoC standard specifies three possible 
control systems for tracking and tracing 
material with an FSC claim and contains 
requirements for each. 

The Requirements for Sourcing FSC Controlled 
Wood standard (FSC-STD-40-005 V3-1) 
includes requirements for a due diligence 
system which include an assessment of the risk 
of material being mixed with that of 
uncontrolled / unknown origin, and requires any 
risk  to be mitigated before material can be 

618 

 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

2.5 Organizations sourcing non-FSC-certified reclaimed 
material for use in FSC product groups shall conform to 
the requirements of FSC-STD-40-007. 

2.6 Organizations sourcing non-FSC-certified virgin 
material for use in FSC product groups as controlled 
material shall conform to the requirements of FSC-STD-
40-005.” 

““3. Material handling 
3.1 In cases  where there is risk  of non-eligible inputs 
entering FSC product groups, the organization shall 
implement one or more of the following segregation 
methods: 
a. physical separation of materials; 
b. temporal separation of materials; 
c. identification of materials” 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood, Clauses 1.1, 1.10, 3.4, 3.5 and 4.1 

“1.1 The organization shall have, implement, and maintain 
a documented due diligence system (DDS) for material 
supplied without an FSC claim to be used as controlled 
material or to be sold with the FSC Controlled Wood 
claim.” 

considered as controlled.  

At the forest level Certificate Holders supplying 
Controlled Wood (as per standard FSC-STD-
30—01) are required implement a tracking 
system when they also manage FMUs outside 
the scope of their Controlled Wood certificate 
(Requirement 2.3).  

The reclaimed standard (FSC-STD-40-007 V2-
0) requires checks on material and evidence of 
reclaimed status upon receipt of materials. 
When such evidence is not provided Clause 
3.3 requires the Certificate Holder to include 
the supplier of that material in their ‘Supplier 
Audit Program’ (Clauses 4.1-4.4). Nowhere 
does the standard explicitly require that such 
material is excluded from FSC product groups 
before evidence is provided. However, the 
reclaimed standard is an accompanying 
standard, all Certificate Holders would also be 
certified to the CoC standard, where 
Requirement 2.4 requires all inputs into FSC 
product groups to be eligible.  

“1.10 The organization shall not use material from supply 
chains where ineffectiveness of the DDS leads to, or might 
lead to, non-eligible inputs entering the production.” 

Justification 

Based on the normative requirements – 
applicable to certificate holders and to material 
from supply-chain entities subject to a due 
diligence system (FSC-STD-40-005) or the 
reclaimed wood standard (FSC-STD-40-007) - 
this indicator has been evaluated as Covered.  

“3.4 The organization shall include at least the following 
sources  of information in 
the risk  assessment,  if available: 
a) Risk  designations provided on the FSC Global Forest 
Registry as  a base for the risk  assessment.  The 
organization may further verify risk designations for its 
supply area, according to the requirements of this section; 
b) A list of applicable laws for countries not undergoing 
FSC risk  assessment  processes,  as  provided on the FSC 
Global Forest Registry; 
c) Known and available sources of information in addition 
to those provided in this section; and 
d) Any information provided by the relevant FSC network 
partner or regional office.” 

619 

 
 
 
 
 
 
 
 
 
  
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

“3.5 General requirements for risk assessment: 
a) An area shall be considered unspecified risk when 
illegal harvesting is a threat to the forest, people, or 
communities. Minor infractions and issues such as  minor 
geographical deviations from the allotted area of 
harvesting, late filing of paperwork, or small infractions 
related to transport should not result in a designation of 
unspecified risk. 
b) The evaluation of risk for illegal harvesting shall include 
consideration of at least the following: 
- The perceived level of corruption related to forest 
activities; 
- The degree of transparency about information that is 
likely to reveal or reduce illegal harvesting if made public; 
- The degree to which key data and documents relevant to 
illegal harvesting exist and are of satisfactory quality; and  
- Independent reports about illegal harvesting.” 

“4.1 The organization shall have and implement adequate 
control measures to either avoid or to mitigate specified 
or unspecified risk related to origin and/or risk related to 
mixing with non-eligible inputs in the supply chain. When 
control measures are to mitigate risk, then the rest of 
Section 4 applies.” 

FSC-STD-40-007 V2-0 
Clauses 3.3 and 4.1-4.4 

““3.3 In cases  where the classification of reclaimed 
materials as pre-consumer and/or postconsumer cannot 
be demonstrated through objective evidence upon 
receipt, the organization shall include the supplier in a 
“Supplier Audit Program” as described in Clause 4 
below.” 

“4 Supplier Audit Program 
4.1 The organization shall perform regular (at least 
annual) on-site audits of the suppliers included in the 
Supplier Audit Program (including overseas suppliers) 
based on a sampling 
approach. The minimum number of suppliers to be 
audited per year is as follows: the size of the sample shall 

620 

 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

be the square root’s number of suppliers (x) with 0.8 as a 
coefficient (y= 0.8√x, where ‘y’ is the number of suppliers 
to be audited), rounded to the upper whole 
number. The organization shall ensure that the selected 
sample is alternating and representative in terms of their: 
a) Geographic distribution; 
b) Activities and/or products; 
c) Size and/or annual production. 
NOTE: Traders or sales offices that do not take physical 
possession  of reclaimed materials, and will not alter, 
store or re-package the reclaimed materials may be 
verified through desk audits (remote audits). 
4.2 The organization may contract an accredited 
certification body or other external qualified party to carry 
out the supplier audits. 
4.3 In cases  where the supplier selected for sampling 
sells reclaimed materials that were previously collected, 
classified and traded by other companies or sites, the 
complete supply chain of these materials shall be audited 
back to the point where the classification as preconsumer 
and/or post consumer can be demonstrated through 
objective evidences. 
4.4 The organization shall eval uate and verify the 
documents and other evidence regarding the supplied 
material quantity, quality and compliance with FSC 
definitions of pre-consumer and post-consumer material, 
which includes:  
a) Supplier’s instructions or procedures in place to control  
and classify the reclaimed 
materials; 
b) When applicable, trainings or instructions provided to 
the supplier’s personnel in relation to classification and 
control of reclaimed materials; 
c) Registers that demonstrates the origin of the materials 
(e.g. pictures, address of the demolished house, invoices, 
etc). 
NOTE: A declaration from the supplier, even if part of the 
contractual agreement, is not considered sufficient proof 
of the origin and material category. However, it can be 
used as  additional evidence to demonstrate the material 
compliance with FSC definitions.” 

621 

 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

FSC-STD-30-010 V2-0 FSC Controlled Wood Standard 
for Forest  Management Enterprises 
“2.3. Any FMU under the control of the Forest 
Management Enterprise is not included in the scope of 
evaluation for compliance with this standard, then the 
Forest Management Enterprise shall implement a 
tracking system to ensure wood from FMUs included in 
the scope of the standard to be reli ably identified as 
such.” 

https://fsc.org/en/innovation/blockchain 

A.3.1.1.4 Where applicable, 
the Scheme shall require 
the segregation and 
tracking of certified 
(according to each 
individual claim type) or 
verified legal wood along 
the supply chain, using 
appropriate inventory 
methods and documented 
controls where necessary 
to ensure that risks  of 
mixing are identified, 
managed and mitigated. 

FSC-STD-40-004 V3-0 
Chain of Custody Certification Requirements 1.7, 4.2 

Findings 

Partially Covered 

“1.7 The organization shall support transaction 
verification conducted by its certification body and 
Accreditation Services International (ASI), by providing 
samples of FSC transaction data as requested by the 
certification body.” 

“4.1 For each product group or job order, the organization 
shall identify the main processing steps involving a change 
of material volume or weight and specify the conversion 
factor(s) for each 
processing step or, if not feasible, for the total processing 
steps. The organization shall have a consistent 
methodology for calculating conversion factor(s) and shall 
keep them up to date. 
NOTE: Organizations that produce custom manufactured 
products are not required to specify conversion factors 
before manufacturing, but they shall maintain production 
records that enable conversion factors to be calculated.” 

“4.4 The organization shall prepare reports of annual 
volume summaries (in the measurement unit commonly 
used by the organization), covering the period since the 
previous reporting period, demonstrating that the 
quantities of output products sold with FSC claims are 
compatible with the quantities of inputs, any existing 
inventory, their associated output claims, and the 
conversion factor(s) by product group.” 

The CoC standard requires the Certificate 
Holder to ensure that inputs used for FSC 
product groups remain clearly identifiable and 
segregated by product group or, if identical 
inputs are used for more than one FSC product 
group, by their associated FSC claim. 

Requirement 4.1 requires any change in 
weight, volume or number of units to be 
accounted for with clear description and 
calculations. Requirement 4.4 requires 
Certificate Holders to produce annual volume 
summaries, demonstrating the compatibility of 
inputs, outputs and stock for products sold with 
an FSC claim, considering the relevant 
conversion factors. These summaries are 
audited annually by the Certification Body. In 
case of suspicion of false claims, fraud or 
incorrectly declared FSC volumes, Certification 
Bodies are required to verify records for non 
FSC sales (INT -STD-20-011_28).  

Where there is suspicion or concerns regarding 
inaccuracy of volumes, FSC conducts 
transaction verification investigations (FSC-
STD-40-004 V3-0, Requirement 1.7 and FSC-

622 

 
 
 
  
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

Interpretations of the normative framework, Chain of 
Custody -  INT-STD-20-011_28 

PRO-10-201 V1-0, Clause 1.1). 

“Does FSC require CoC auditors to systematically verify in 
every evaluation the FSC certified organization‘s 
accounting records for non-FSC sales for the purpose of 
confirming the information contained in annual volume 
summaries? 
No, FSC does not require COC auditors to systematically 
verify records for non-FSC sales in every evaluation. This 
should be limited to situations where either: 
• The CB received a complaint that leads to the suspicion 
of false claims, fraud or incorrectly declared FSC volumes; 
• The CoC auditor comes across evidence that leads to 
the suspicion of false claims, fraud or incorrectly declared 
FSC volumes (including at critical control  points); 
• The CB is required to cooperate and support ASI in 
transaction verification (TV); 
• The FSC-certified organization declared that no FSC 
sales were made since the last audit. 
NOTE: Normative basis for requiring access to records of 
non-FSC sales: FSC-STD-20-001 V4-0 Clause 1.2.3 q)” 

FSC-PRO-10-201 V1-0, Transaction Verification 
Procedure, Requirement 1.1 
“1.1 The selection of a specific supply chain for 
Transaction Verification (TV) loops by the FSC Supply 
Chain Steering Group for the purpose of transaction 
verification is based on the following criteria which 
determine the risk of false claims (list not exhaustive):  
a. Complaints submitted to the FSC, certification bodies 
(CBs)  and/or ASI;  
b. Wood Identification testing results; 
c. False claims identified during annual audits;  
d. Certification bodies’ reporting of fraud to the FSC 
database;  
e. ASI or certification bodies’ evaluation reports;  
f. Publicly available information on fraud risks and 
incidents of fraud;  
g. Analysis of the FSC database; and/or  
h. ASI or FSC incident reports and incident trend data.” 

FSC-ADV-60-004 V1-0 Advice Note on Transaction 

623 

However, the CoC system  does not include – 
under ordinary circumstances – any validation 
of volumes transferred from seller to purchaser, 
vertically along supply chains, which is 
considered as a major gap in the system. 
Requirement 1.7 states that “the organization 
shall support transaction verification conducted 
by its certification body and Accreditation 
Services International (ASI), by providing 
samples of FSC transaction data as requested 
by the certification body”, however, this is not 
systematically required of all Certificate 
Holders. 

Transaction verification also includes the 
requirement for certificate holders to support 
fibre testing by surrendering samples and 
specimens of materials and information about 
species composition. Such requirements are 
included within two advice notes. Additionally, 
during the development of this report, FSC 
published a new version of the CoC standard, 
Version 3-1, which also includes the 
requirement to support fibre testing. 

FSC are exploring other ways of improving 
supply chain integrity, including the use of 
Blockchain technology.  

Justification 

Based on the normative requirements this 
indicator has been evaluated as Partially 
Covered only. It is noted that the FSC system 
includes mechanisms such as  transaction 
verifications - conducted by its certification 
body and Accreditation Services International – 

 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

where there is suspicion or concerns regarding 
inaccuracy of volumes. This comprises a 
number of activities, including volume data 
analysis and fibre testing. However, despite 
these efforts, FSC CoC certification does not 
include systematic validation of volumes 
transferred from seller to purchaser, which is 
considered as a major gap in the system.  

Verification for FM/CoC Certificate Holders    

2. The Organization shall support fibre testing by 
surrendering samples and specimens of materials and 
information about species composition and the location 
where the sample originated for verification, as requested 
by its certification body, ASI or FSC. 

FSC-DIR-40-004 FSC Directive on Chain of Custody 
Certification 

ADVICE-40-004-14 Supply chain integrity 
1. The organization shall support transaction verification 
conducted by its certification body and ASI, by providing 
samples of FSC transaction data as requested by the 
certification body. 
2. The organization shall support fibre testing conducted 
by its certification body and ASI, by upon request 
surrendering samples and specimens of materials and 
products, and information about species composition for 
verification. 

https://fsc.org/en/innovation/blockchain 
https://fsc.org/en/supply-chains 
https://fsc.org/en/unacceptable-activities  

FSC-STD-01-002 

Findings 

Partially Covered 

“Post-consumer reclaimed material: Material that is reclaimed 
from a consumer or commercial product that has been used 
for its intended purpose by individuals, households or by 
commercial, industrial and institutional facilities in their role as 
end users  of the product.” 

“Pre-consumer reclaimed material: Material that is reclaimed 
from a process  of 
secondary manufacture or further downstream industry, in 
which the material has not 
been intentionally produced, is unfit for end use and not 
capable of being re-used onsite 
in the same manufacturing process that generated it.” 

The following resources are available from the 
European Commission in relation to reclaimed 
material: 
 
 

EU Timber Regulation (995/2010) 
EUTR Guidance document on Recycled 
timber and timber products 

The EUTR exempts material which has i) 
completed its lifecycle and; ii) would otherwise be 
disposed of as waste, fitting a definition close to 
post-consumer waste. This is demonstrated in the 
EUTR definition of timber and timber products, 
which excludes “timber products or components of 
such products manufactured from timber or timber 
products that have completed their lifecycle and 

624 

A.3.2.1 

A.3.2 Recycled m aterial  
Waste material 

A.3.2.1.1 The Scheme shall 
have a definition of waste 
material which at least 
covers the definition of 
waste material as 
described by the EUTR 
Guidance document.  

 
 
 
 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

FSC-STD-40-007 V2-0 

“Reclaimed material: Material that demonstrably would have 
otherwise been 
disposed of as waste or used for energy recovery, but has 
instead been collected 
and reclaimed as input material, in lieu of virgin material, for 
re-use, recycling, remilling 
in a manufacturing process or other commercial application. 
Inputs of the following material categories are classified as 
reclaimed material: 
a) FSC Recycled material; 
b) Post-consumer reclaimed material; 
c) Pre-consumer reclaimed material.” 

ANNEX I: Examples of reclaimed WOOD material 

Post-consumer wood sources 
  Municipal Sources Commercial (Retail, Office, Small 

Business); 
Construction and Demolition Debris; 
Defibrillated and solid wood recovered from 
landfills, transfer stations, and Material Recovery 
Facilities (MRFs); 
Industrial Packaging and Administrative wastes (does 
not include process wastes); 
Institutional (schools); 
Residential 

 
 
 

 

 
 

Post-consumer wood material 
 

Commercial Transport Packaging including pallets, 
crates, cases, cable drums at the end of their useful life; 

would otherwise be disposed of as waste”[1].  

The EUTR Guidance document on Recycled 
timber and timber products reinforces the EUTR’s 
exemption for post-consumer reclaimed material, 
by describing that this exemption: 

 

 

applies to timber products of a kind 
covered by the Annex, produced from 
material that has completed its 
lifecycle and w ould otherw ise have 
been disposed of as w aste (e.g. 
recycled paper, timber retrieved from 
dismantled buildings, or products made 
from waste wood).  
does not apply to by-products  of a 
manufacturing process that involves 
material which has not completed its 
lifecycle and w ould otherw ise have 
been discarded[2]. 

Material deemed a by-product of a manufacturing 
process,  fitting a definition closer to pre-consumer 
waste, is not exempt from the EUTR. The EUTR 
Guidance document on Recycled timber and 
timber products describes that: By-products “from 
another production are not waste but “are to be 
regarded as a raw material in the production. 
Material in a regulated timber product is not 
recycled material if the material is the by-product 
of a manufacturing process. Example: Sawdust or 
off-cuts from sawn timber used to make particle 
board or medium density fibreboard”2. 

[1] Directive 2008/98/EC Article 3(1) defines 'waste ' as “any substance or object which the holder discards or intends or is required to discard ” 

[2] EUTR Guidance document on Recycled timber and timber products: “By-products” from another production are not waste but are to be regarded as a raw material in the production. Material in a reg ulated 
timber product is not recycled material if the material is the by-product of a manufacturing process. Example: Sawdust or off-cuts from sawn timber used to make particle board or medium density fibreboard.  

625 

 
 
 
 
 
 
 
                                              
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

 

 

 

Construction and Demolition Debris4 including doors, 
flooring, old cabinets, mouldings, and dimensional 
lumber, discarded wood packaging e.g. pallets and 
cable drums. Wood reclaimed through 'Deconstruction" 
e.g. salvaged dimensional lumber and architectural 
elements; 
Damaged Stock and Rejected Products manufactured 
from post-consumer wood products, including 
deconstructed building materials, or wood reclaimed 
from construction and demolition (C&D) debris; 
Used telephone poles, railroad ties, building materials, 
furnishings, cabinets, shop fittings, shelving etc. that 
have been used for their intended purpose by 
residential, commercial, or industrial consumers; 

  Off-cuts, shavings, sawdust and the like generated 

during the re-milling of postconsumer wood products, 
deconstructed building materials, or wood reclaimed 
from 

 

C&D debris. 

Pre-consumer wood sources 
  Municipal Sources: Commercial / Institutional  
 

Industrial Sources: Process waste from converters and 
secondary manufacturing onwards 

Pre-consumer wood material 
 

Damaged stock, rejected products, overstock, 
discontinued items not used for their intended purpose; 

  Offcuts, shavings, sawdust, and the like, generated 

during secondary manufacture or subsequent steps in 
manufacturing an end product. 

ANNEX II: Examples of reclaimed PAPER material  

Post-consumer paper sources 
 
 

Domestic; 
Distribution, retail and industrial; 

Post-consumer paper material 
 

Commercial transport packaging 

626 

The FSC scheme’s definition of post-consumer 
reclaimed material – and the examples given in 
Annexes I and II –  appears to overlap with the 
definition described in the EUTR. Annexes I 
and II of the Reclaimed Standard (FSC-STD-
40-007) give examples of wood and paper 
materials that would also be excluded from the 
EUTR as a result of their post-consumer 
nature: the materials would have i) completed 
its lifecycle AND ii) would otherwise be 
disposed of as waste 

However, FSC descriptions of pre-consumer 
reclaimed material described in Annexes I and 
II (pages 10/11) are more nuanced and the 
study concludes that such materials are 
included within the scope of the EUTR, based 
on the assumption that while the materials 
would have may be disposed of as waste, they 
may not have completed their lifecycles. The 
following provide two examples: 

  …discontinued items not used for their 

intended purpose 

  Offcuts, shavings, sawdust, and the like, 

generated during secondary manufacture…. 

 

Some of the paper scrap example materials 
for Annex II 

Justification 

Based on the normative requirements, this 
indicator has been evaluated as Partially Covered 
only. FSC descriptions of pre-consumer material 
described in Annexes I and II of the FSC 
reclaimed materials standard FSC-STD-40-007, 
may not entirely align with the definition of waste 
material as described by the EUTR and 
associated guidance document. 

 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

Computer print-outs 

 
  Magazines, direct mail, home office materials, and 

boxes 

  Old magazines from residential or office collections 
  Old newspapers from residential or office collections 
 

Reclaimed household scrap paper and packaging, 
including old newspapers 
Reclaimed office wastepaper 
Used corrugated boxes 
Used tabulating cards 

 
 
 

Pre-consumer paper sources 
Secondary and subsequent manufacture; 
 
Distributors 
 
  Merchants 

Pre-consumer paper material 
 

All scrap generated during the intermediate steps in 
producing an end product following primary 
manufacturing (i.e. post-mill); 
Bindery trim and scrap; 
Forms conversion scrap; 

 
 
  Merchant return stock; 
  Obsolete inventories from distributors, printers, 

converters and others beyond the original manufacturer; 

  Over-issue publications; 
 

 
 

 

Printers’ scraps,  pre-printing, make-ready, overruns, 
errors,  rejections; 
Publisher overruns and returns; 
Scrap from product manufacturing, including bag, box 
and carton manufacturing; 
Scraps from converters, mail order houses, others in 
value-added chain; 
Sheeting scrap from converters 

 
FSC-STD-40-007 V2-0, Requirements 1.1, 3.1 – 3.3 and 
4.1 – 4.5 

Findings 

Covered 

“1.1 The organization that purchases reclaimed forest-
based materials (including materials such as bamboo and 
cork)  without FSC claims shall demonstrate that its 

FSC’s  reclaimed material standard provides a 
comprehensive set of requi rements and 
guidance for ensuring the identification and 
differentiation of post-consumer reclaimed input 

627 

A.3.2.1.2 The Scheme shall 
require systematic 
processes  to enable the 
identification of waste 
material that has completed 
its life cycle and to 

 
 
 
 
 
 
differentiate this material 
from virgin or material that 
are by-products of a 
manufacturing process 
which has not completed its 
lifecycle as defined by the 
EUTR. 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

material.  

The standard requires Certificate Holders to 
inspect material inputs and provide objective 
evidence to demonstrate that only material that 
meets its definition of post-consumer reclaimed 
enters the FSC system as  such. It also includes 
examples of objective evidence.  

Where material classification cannot be 
demonstrated through objective evidence then 
the Certificate Holder is required to include the 
supplier in a ‘Supplier Audit Program’. This 
Program requires regular, onsite audits of a 
sample of suppliers, going back to “the point 
where the classification as pre-consumer 
and/or post-consumer can be demonstrated 
through objective evidences”. The details of the 
audit records are also specified in the standard. 

Justification 

Based on the normative requirements of the 
FSC reclaimed materials standard FSC-STD-
40-007, this indicator has been evaluated as 
Covered.  

reclaimed inputs 
for use in FSC Product Groups or FSC Projects comply 
with FSC definitions for pre-consumer and/or post-
consumer reclaimed material (see Section D “Terms and 
Definitions”).” 

“3.1 Upon receipt, all reclaimed materials shall be verified 
through visual inspection and classified into pre-
consumer and/or post-consumer reclaimed material.”   

“3.2 The organization shall retain objective evidence for 
each supply confirming that the reclaimed materials 
comply with FSC definitions for pre-consumer and post-
consumer.” 

“3.3 In cases  where the classification of reclaimed 
materials as pre-consumer and/or postconsumer cannot 
be demonstrated through objective evidence upon 
receipt, the organization shall include the supplier in a 
“Supplier Audit Program” as described in Clause 4 
below.” 

4 Supplier Audit Program 
4.1 The organization shall perform regular (at least 
annual) on-site audits of the suppliers included in the 
Supplier Audit Program (including overseas suppliers) 
based on a sampling 
approach. The minimum number of suppliers to be 
audited per year is as follows: the size of the sample shall  
be the square root’s number of suppliers (x) with 0.8 as a 
coefficient (y= 0.8√x, where ‘y’ is the number of suppliers 
to be audited), rounded to the upper whole 
number. The organization shall ensure that the selected 
sample is alternating and representative in terms of their: 
a) Geographic distribution; 
b) Activities and/or products; 
c) Size and/or annual production. 
NOTE: Traders or sales offices that do not take physical 
possession  of reclaimed materials, and will not alter, 
store or re-package the reclaimed materials may be 
verified through desk audits (remote audits). 

628 

 
 
 
 
 
 
 
 
  
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

4.2 The organization may contract an accredited 
certification body or other external qualified party to carry 
out the supplier audits. 
4.3 In cases  where the supplier selected for sampling 
sells reclaimed materials that were previously collected, 
classified and traded by other companies or sites, the 
complete supply chain of these materials shall be audited 
back to the point where the classification as pre 
consumer and/or post consumer can be demonstrated 
through objective evidences. 
4.4 The organization shall evaluate and verify the 
documents and other evidence regarding the supplied 
material quantity, quality and compliance with FSC 
definitions of pre-consumer and post-consumer material, 
which includes:  
a) Supplier’s instructions or procedures in place to control 
and classify the reclaimed 
materials; 
b) When applicable, trainings or instructions provided to 
the supplier’s personnel in relation to classification and 
control of reclaimed materials; 
c) Registers that demonstrates the origin of the materials 
(e.g. pictures, address of the demolished house, invoices, 
etc). 
NOTE: A declaration from the supplier, even if part of the 
contractual agreement, is not considered sufficient proof 
of the origin and material category. However, it can be 
used as  additional evidence to demonstrate the material 
compliance with FSC definitions. 
4.5 The organization shall document the supplier audits, 
including a record of the audit date, the audit findings in 
relation to the requirements in Clause 4.4, the names and 
qualifications of the auditors and examples of any 
evidence collected to verify the classification of the 
materials.” 
FSC-STD-40-007 V2-0, Requirement 3.5 

Findings 

Covered 

“3.5 In cases  where the material received contains a mix 
of pre-consumer and post-consumer reclaimed material 
in its composition, the organization shall apply one of the 
following 

Where a Certificate Holder receives a mix of 
pre and post-consumer reclaimed material the 
reclaimed material standard requires it to either 
be entirely classified as pre-consumer, or that 

629 

A.3.2.1.3 The Scheme shall 
include clear and effective 
measures to prevent “timber 
products of a kind covered by 
the Annex of the EUTR”, 
produced from  

 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

i) reclaimed material that has 
NOT completed its lifecycle 
and would otherwise have 
been discarded as waste”,  
ii) unverified or  
iii) virgin material (as defined 
by the EUTR) from, entering 
the supply chain.  

measures: 
a) Classify the full amount of material as pre-consumer 
reclaimed, or 
b) Analyse and confirm the quantities of pre-consumer 
and post-consumer material in the mix received. In this 
case, the supplier shall: 
- declare in writing the quantities of pre-consumer and 
post-consumer reclaimed material in each material mix 
supplied, and 
- be included in the “Supplier Audit Program”. 

FSC-STD-40-004 V3-0 Chain of Custody Certification 
Requirements 2.4 – 2.6, 3.1 and 6.1 c 

only the appropriate quantity is. Thus, pre-
consumer material may be sold on as post-
consumer (although post-consumer would be 
classified as pre-consumer to balance this out).  

However, Certificate Holders certified to the 
reclaimed standard are also subject to the CoC 
standard where point c of Requirement 6.1 
provides for additional measures when such 
material is being sold into countries with timber 
legality legislation, such as the EUTR. The CoC 
standard also has controls in place for the 
prevention of mixing, see A.3.1.1.3 above.  

“2.4 The organization shall ensure that only eligible inputs 
and the correct material categories are used in FSC 
product groups as defined in Table B. 

Justification 

2.5 Organizations sourcing non-FSC-certified reclaimed 
material for use in FSC product groups shall conform to 
the requirements of FSC-STD-40-007. 

Based on the normative requirements this 
indicator has been evaluated as Covered.  

2.6 Organizations sourcing non-FSC-certified virgin 
material for use in FSC product groups as controlled 
material shall conform to the requirements of FSC-STD-
40-005.” 

“3. Material handling 
3.1 In cases  where there is risk  of non-eligible inputs 
entering FSC product groups, the organization shall 
implement one or more of the following segregation 
methods: 
a. physical separation of materials; 
b. temporal separation of materials; 
c. identification of materials” 

“6. Compliance w ith timber legality legislation 
6.1 The organization shall ensure that its FSC-certified 
products conform to all applicable timber legality 
legislation. At a minimum, the organization shall: 

c. ensure that FSC-certified products containing 
pre-consumer reclaimed wood (except 

630 

 
 
 
 
 
 
 
 
 
 
  
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

reclaimed paper) being sold to com panies 
located in countries where timber legality 
legislation applies either: 

i. only include pre-consumer 
reclaimed wood materials that 
conform to FSC Controlled Wood 
requirements in accordance with FSC-
STD-40-005; or 
ii. inform their customers about the 
presence of pre-consumer reclaimed 
wood in the product and support their 
due diligence 
system as  required by applicable 
timber legality legislation. 

NOTE: Organizations applying option c (i) above may 
apply the requirements for co-products outlined in FSC-
STD-40-005.” 

A.4 General requirements for Certificate Holders 

A.4.1 

Conflict 
resolution 

A.4.1.1 The Scheme shall 
include requirements that 
ensure that disputes are 
identified, recorded and 
managed, in a way that: 

i) ensures  there is a 
transparent ongoing 
process  to address the 
issue 
ii) requires for the exclusion 
from the scope of the 
certificate situations or 
areas or forest where the 
legality of tenure or 
management/harvesting is 
not defined or is unclear 
and disputed. 
iii) ensures respect for 
legally-enshrined 
customary tenure rights of 
local communities. 

FSC-STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

“1.6 The Organization* shall* identify, prevent and resolve 
disputes* over issues  of statutory or customary law*, which 
can be settled out of court in a timely manner*, through 
engagement with affected stakeholders*. 

“1.6.3 Up to date records of disputes related to issues of 
applicable laws* or customary law, are held including: 
1) Steps taken to resolve disputes*; 
2) Outcomes of all dispute* resolution processes; and 
3) Unresolved disputes*, the reasons they are not 
resolved, and how they will be resolved.” 

“1.6.4 Operations cease in areas where disputes* exist: 
1) Of substantial magnitude*; or 
2) Of substantial duration*; or 
3) Involving a significant* number of interests.” 
(4.6.4 has identical text) 

“2.6 The Organization* through engagement* with 
workers*  shall* have mechanisms for resolving grievances 
and for providing fair compensation* to workers* for loss  or 

631 

Findings 

Covered 

i) Dispute resolution is covered in three Criteria 
in the FM standard: Criterion 1.6 related to 
legal tenure; 2.6 related to workers grievances; 
and in 4.6 related to local communities and 
individuals, with regards to the impacts of 
management activities. The Instructions for 
Standard Developers and IGIs set out clear 
requirements for how disputes shall be 
identified, recorded and managed. It is clearly 
stated that the process shall be publicly 
available.  

There is no dispute resolution Criteria under 
Principle 10 on the Implementation of 
Management Activities but a complaint against 
a Certificate Holder because of non-compliant 
management activities can be taken to the 
Certification Body in charge (Clause 2.3 from 
FSC-PRO-01-008 Processing Complaints in 
the FSC Certification Scheme).  

 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

damage to property, occupational diseases*, or 
occupational injuries* sustained while working for The 
Organization*.” 

ii) IGIs 1.6.4 and 4.6. provide for the cessation 
of operations whilst disputes are being 
resolved.    

iii) IGI 1.6 explicitly includes customary law. 

Supply chain entities are required to implement 
a complaint handling system (FSC-STD-40-
004, Requirement 1.5). Section 7 of the FSC 
CoC Controlled Wood standard (FSC-STD-40-
005) details requirements for stakeholder 
inputs and complaints and requirement 6.1 
specifies that the complaint mechanism shall 
be incorporated in the summary of the due 
diligence system required to be publicly 
available. 

Justification 

Based on the normative requirements this 
indicator has been evaluated as Covered.  

“4.6 The Organization*, through engagement* with local 
communities*, shall* have mechanisms for resolving 
grievances and providing fair compensation* to local 
communities* and individuals with regard to the impacts of 
management activities of The Organization*.” 

FSC-POL-20-003 

FSC-STD-40-004 V3-0 
Chain of Custody Certification Requirement 1.5 

“1.5 The organization shall ensure that complaints 
received regarding the organization’s conformity to the 
requirements applicable to the scope of the organization’s 
CoC certificate are adequately considered, including the 
following: 
a. acknowledge receipt of the complaint to the 
complainant 
within two (2) weeks  of receiving the complaint; 
b. investigate the complaint and specify its proposed 
actions in response to the complaint within three (3) 
months. If more time is needed to complete the 
investigation, the complainant and the organization’s 
certification body shall be notified; 
c. take appropriate actions with respect to complaints and 
any deficiencies found in processes that affect conformity 
to the certification requirements; 
d. notify the complainant and the organization’s 
certification body when the complaint is considered to be 
successfully addressed and closed.” 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood, Clause 6.1 and Section 7  

“6.1 The organization shall provide a written summary of 
its DDS to the certification body. The written summary 
shall include the following information: 

632 

 
 
 
 
 
 
 
 
 
 
  
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

… 
d) The procedure for filing complaints; 
… 
NOTE 1: This information will be included in the public 
summary of the certification report by the certification body 
on the FSC database.” 

“7 Stakeholder input and complaints 
7.1 The organization shall develop and implement a 
documented procedure to handle comments and 
complaints from stakeholders that are related to its DDS. 
NOTE: The procedure may consist of relevant existing 
organizational policies, mechanisms, etc. 
7.2 The procedure shall include mechanisms (unless 
otherwise stated in the applicable NRA) for: 
a) Acknowledging receipt of complaints; 
b) Informing stakeholders of the complaint procedure, and 
providing an initial response to complainants within a time 
period of two (2) weeks; 
c) Forwarding complaints related to risk designations in 
the relevant FSC risk assessment  to the responsible body 
(for an NRA: as  indicated in the NRA; for a CNRA: FSC); 
NOTE: When a complaint is forwarded to a responsible 
body, Clauses 7.2. d) - k)  do not apply. 
d) Conducting a preliminary assessment to determine 
whether evidence provided in a complaint is or is not 
substantial, by assessing the evidence provided against 
the risk  of using material from unacceptable sources; 
e) Dialogue with complainants that aims to solve 
complaints assessed  as substantial before further actions 
are taken; 
f) Forwarding substantial complaints to the certification 
body and relevant FSC National Office for the supply area 
within two (2) weeks  of receipt of the complaint. 
Information on the steps to be taken by the organization in 
order to resolve the complaint, as well as how a 
precautionary approach will be used, shall be included 
with the complaint; 
g) Employing a precautionary approach towards the 
continued sourcing of the relevant material while a 
complaint is pending; 

633 

 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

NOTE: This includes a description of how the 
precautionary approach is employed by the organization 
when a complaint is active. 
NOTE: A complaint is pending if it has been considered to 
be substantial (according to Clause 7.2 d), and no 
effective corrective action (according to Clauses 7.2 h) - k) 
has been taken yet. 
h) Implementing a process (e.g. field verification and/or 
desk  verification) to verify a complaint assessed as 
substantial by the organization, within two (2) months of its 
receipt; 
i) Determining the corrective action to be taken by 
suppliers and the means to enforce its implementation by 
a supplier if a complaint has been assessed and verified 
as substantial. If a corrective action cannot be determined 
and/or enforced, the relevant material and/or suppliers 
shall be excluded by the 
organization; 
j) Verifying whether corrective action has been taken by 
suppliers and whether it is effective; 
k)  Excluding the relevant material and suppliers from the 
organization’s supply chain if no corrective action is taken; 
l) Informing the complainant, the certification body, and the 
relevant FSC National Office of the results of the complaint 
and any actions taken towards its resolution, and for 
maintaining copies of relevant correspondence; and 
m) Recording and filing all complaints received and 
actions taken.” 

FSC-PRO-01-008 V2-0 
“2.3 Complaints against FSC certified organizations about 
their compliance with the FSC certification requirements 
are dealt with by the Certification Body who issued the 
certificate and processed according to the Certification 
Body’s own complaint procedure.” 

FSC-STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

Findings 

Covered 

1.7: ““The Organization* shall* publicize a commitment not 
to offer or receive bribes in money or any other form of 
corruption, and shall* comply with anti-corruption 
legislation where this exists. In the absence of 
anticorruption legislation, The Organization* shall* 

Criterion 1.7 in the International FM standard 
explicitly addresses the potential for corrupt 
practices and includes requirements to exclude 
corruption. The instructions for Standard 

634 

Corruption 

A.4.1.2 The scheme shall 
include requirements to 
ensure that certificate holders 
do not engage in corrupt 
practices related to illegal 
harvesting. 

 
 
 
 
  
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

implement other anticorruption measures proportionate to 
the scale* and intensity* of management activities and the 
risk*  of corruption.” 

Developers also give guidance on how this can 
be addressed where anti -corruption laws and 
regulations are ineffective or do not exist. 

Within the Controlled Wood system at the FM 
level corruption is not mentioned in the 
standard itself. However, the normative Advice 
Note (FSC-ADV-30-010 V1-0 DATED 10 JULY 
2014) specifies legal methods of obtaining 
concession licenses and harvesting permits, 
noting how corruption is a well -known issue 
associated with such licenses. 

CoC Certificate Holders are required to 
“commit to the FSC values as defined in FSC-
POL-01-004 by signing a self-declaration that 
the organization is not directly or indirectly 
involved” in six activities, the first being “illegal 
logging or the trade in illegal wood or forest 
products” (Requirement 1.3).  

Justification 

Based on the normative requirements, this 
indicator has been evaluated as Covered.  

FSC-STD-60-004 V2-0 

1.7 Instructions for Standard Developers:  

“This Criterion* recognizes that corruption is generally 
regarded as illegal but that not all countries have or 
implement anti-corruption laws and regulations. 

Where anti-corruption laws and regulations are ineffective 
or do not exist, Standard Developers shall* include other 
anti-corruption measures that may include for example, 
The Organization* develops or participates in formal 
integrity pacts with other organizations in the public and 
private sectors, such that each participant agrees in well 
publicized statements not to engage in corruption by 
offering or receiving bribes, whether in money or in any 
other forms (Indicator 1.7.4). 

An independent third party with expertise in such matters 
should then monitor* performance related to such 
statements.” 

FSC-ADV-30-010 V1-0 DATED 10 JULY 2014 

FSC-POL-01-004  V2-0 Policy for the Association of 
Organizations with FSC 

“1 FSC will only allow its association with organizations 
that are not directly or indirectly involved in the following 
unacceptable activities: 
a) Illegal logging or the trade in illegal wood or forest 
products 
b) Violation of traditional and human rights in forestry 
operations 
c) Destruction of high conservation values in forestry 
operations 
d) Significant conversion of forests to plantations or non-
forest use 
e) Introduction of genetically modified organisms in 

635 

 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

forestry operations 
f) Violation of any of the ILO Core Conventions” 

FSC-STD-40-004 V3-0 
Chain of Custody Certification 
“1.3 The organization shall commit to the FSC values as 
defined in FSC-POL-01-004 by signing a self-declaration 
that the organization is not directly or indirectly involved in 
the following activities: 
a. illegal logging or the trade in illegal wood or forest 
products;” 

A.5 Quality and procedural requirements for Certificate Holders 

A.5.1 

Internal 
procedures for 
Certificate 
Holders 

A.5.1.1 The Scheme shall 
include requirements for 
the Certificate Holders to 
have in place - and 
implement - systems and 
procedures covering all 
requirements of the 
Scheme. 

FSC-STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

“Principle 7: Management Planning 
The Organization* shall* have a management plan* 
consistent with its policies and objectives* and 
proportionate to scale, intensity and risks* of its 
management activities. The management plan* shall* be 
implemented and kept up to date based on monitoring 
information in order to promote adaptive management*. 
The associated planning and procedural documentation 
shall* be sufficient to guide staff, inform affected 
stakeholders* and interested stakeholders* and to justify 
management decisions.” 

“7.4 The Organization* shall* update and revise 
periodically the management planning and procedural 
documentation to incorporate the results of monitoring and 
evaluation, stakeholder engagement* or new scientific and 
technical information, as well as to respond to changing 
environmental, social and economic circumstances.” 

Findings 

Covered 

At the forest level Criterion 7.4 requires 
Certificate Holders’ management plans to be 
revised and updated periodically to incorporate 
monitoring results, including results of 
certification audits, evaluation results, 
stakeholder engagement results, new scientific 
and technical information, and changing 
environmental, social, or economic 
circumstances. The frequency of revision 
should be based on existing planning cycles 
and the source and significance of the 
information received from monitoring, 
evaluation and engagement. 

It is explicitly required for Certificate Holders 
implementing the CW standard at the forest 
level to implement procedures covering all 
applicable element of the standard.  

FSC-STD-30-010 V2-0 
“1.1. The Forest Management Enterprise shall have 
procedures and/or work instructions covering all the 
applicable elements specified in this standard.” 

It is also explicitly required for Certificate 
Holders in the supply chain to have systems 
and procedures covering all applicable aspects 
of the CoC and CW standards.  

FSC-STD-40-004 V3-0 

636 

 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

Chain of Custody Certification  
“1.1 The organization shall implement and maintain a CoC 
management system adequate to its size and complexity 
to ensure its continuous conformity to all applicable 
certification requirements, including the following: 
a. appoint a management representative who has overall 
responsibility and authority for the organization’s 
conformity to all applicable certification requirements; 
b. implement and maintain up-to-date documented 
procedures covering the certification requirements 
applicable to the scope of the certificate; 
c. define the key personnel responsible for the 
implementation of each procedure; 
d. train staff on the up-to-date version of the organization’s 
procedures to ensure their competence in implementing 
the CoC management system; 
e. maintain complete and up-to-date records of the 
documents that are relevant to demonstrate the 
organization’s conformity with all applicable certification 
requirements 
which shall be retained for a minimum period of five (5) 
years. At a minimum, the organization shall keep records 
of the following documents as applicable to the certificate 
scope: procedures, product group lists; training records; 
purchase and sales documents; material accounting 
records; annual volume summaries; trademark approvals; 
records of suppliers, complaints, and outsourcing; control 
of nonconforming products; verification program records 
for reclaimed material, and records 
related to a due diligence program for controlled material 
and FSC Controlled Wood.” 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood 
“5.3 The organization shall implement documented 
procedures covering all applicable requirements of this 
standard.” 

FSC-STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

Justification 

Based on the normative requirements, this 
indicator has been evaluated as Covered. The 
Scheme includes requirements for the 
Certificate Holders to have in place - and 
implement - systems and procedures covering 
all requirements of the Scheme. 

Findings 

Partially Covered 

“Principle 7: Management Planning 
The Organization* shall* have a management plan* 

Principle 7 of the International FM standard 
itself refers to promoting adaptive 

637 

A.5.1.2 The Scheme shall 
include requirements for 
the Certificate Holders to 
regularly review the proper 

 
 
 
 
 
 
 
functioning of their own 
procedures. 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

consistent with its policies and objectives* and 
proportionate to scale, intensity and risks* of its 
management activities. The management plan* shall* be 
implemented and kept up to date based on monitoring 
information in order to promote adaptive management*. 
The associated planning and procedural documentation 
shall* be sufficient to guide staff, inform affected 
stakeholders* and interested stakeholders* and to justify 
management decisions.” 

“7.4 The Organization* shall* update and revise 
periodically the management planning and procedural 
documentation to incorporate the results of monitoring and 
evaluation, stakeholder engagement* or new scientific and 
technical information, as well as to respond to changing 
environmental, social and economic circumstances.” 

FSC-STD-40-004 V3-0 
Chain of Custody Certification  
“1.1 The organization shall implement and maintain a CoC 
management system adequate to its size and complexity 
to ensure its continuous conformity to all applicable 
certification requirements, including the following: 
… 
b. implement and maintain up-to-date documented 
procedures covering the certification requirements 
applicable to the scope of the certificate;” 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood, Clauses 1.6 – 1.8 and Annex A, Clause 
1.5 

“1.6 The organization shall review and, if necessary, 
revise its DDS at least annually, and whenever changes 
occur that affect the relevance, effectiveness, or adequacy 
of the DDS (see Figure 4). 

1.7 The organization shall implement internal audits of its 
DDS at least annually to ensure that it is being 
implemented correctly. 

management. Criteria 7.4 requires Certificate 
Holders to periodically update and revise 
management planning procedural 
documentation.  

Regarding controlled wood at the forest level 
FSC-STD-30-010 does not contain direct 
requirements for the evaluation and revision of 
the organisation’s procedures. 

CoC Certificate Holders are required to keep 
their procedures up to date. However, there is 
no requirement for them to regularly review the 
proper functioning of their procedures. 

In the case of FSC COC controlled wood, an 
annual review of the DDS is required by the 
CW standard for supply chain entities. Clause 
1.6 of FSC-STD-40-005 requires the 
organisation to review and, if necessary, revise 
its DDS at least annually, and whenever 
changes occur that affect the relevance, 
effectiveness, or adequacy of the DDS. 
Clauses 1.7 and 1.8 require the organisation to 
implement internal audits of its DDS at least 
annually to ensure that it is being implemented 
correctly, and to document the scope, dates, 
and staff involved in internal audits, 
respectively. 

Justification 

Based on the normative requirements, this 
indicator has been evaluated as Partially 
Covered. The Scheme requires that Certificate 
Holders regularly review the proper functioning 
of their own procedures, in the case of 
certification at the forest level and in relation to 
the controlled wood DDS implemented 

638 

 
 
 
 
 
 
 
 
A.5.2 

Qualification and 
competence 

A.5.2.1 The Scheme shall 
include requirements that 
ensure that certified 
organisations have 
personnel with sufficient 
qualifications and 
competencies to 
consistently and effectively 
implement Scheme 
requirements. 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

1.8 The organization shall document the scope, dates, and 
staff involved in internal audits.” 

Annex A, Risk  assessment  by the organization: 
“1.5 The organization shall review its risk assessment  at 
least annually to verify the continued correctness and 
relevance of risk designations, and shall revise it when 
necessary.” 

according to standard FSC-STD-40-005. 
However, the scheme does not require the 
same of CoC-certified companies, certified to 
FSC-STD-40-004 only. 

FSC-STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

Findings 

Partially Covered 

“2.5 The Organization* shall demonstrate that workers 
have job-specific training and supervision to safely and 
effectively implement the management plan* and all 
management activities.” 

Criteria 2.5 of the International FM standard 
and Point d of Requirement 1.1 of the CoC 
standard require that workers are adequately 
trained.  

FSC-STD-40-004 V3-0 
Chain of Custody Certification  
“1.1 The organization shall implement and maintain a CoC 
management system adequate to its size and complexity 
to ensure its continuous conformity to all applicable 
certification requirements, including the following: 
… 
d. train staff on the up-to-date version of the organization’s 
procedures to ensure their competence in implementing 
the CoC management system;” 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood 
“5.2 All relevant staff shall demonstrate awareness of the 
organization’s procedures, and competence in 
implementing the applicable requirements of this 
standard.” 

Clause 5.2 of the FSC CoC Controlled Wood 
standard (FSC-STD-40-005) for supply chain 
entities requires that staff demonstrate 
competence relevant to standard 
implementation. However, a gap is noted within 
the Controlled Wood system at the forest level 
because there is no relevant clause in FSC-
STD-30-010.  

Justification 

Based on the normative requirements, this 
indicator has been evaluated as Partially 
Covered. The Scheme does not systematically 
include – across all types of certification - 
requirements that certified organisations have 
personnel with sufficient qualifications and 
competencies. Specifically, a gap is noted 
within regards to the FM Controlled Wood 
standard FSC-STD-30-010.  

639 

 
 
 
 
 
 
 
A.5.3 

Risk  based 
approaches to 
sourcing, trade 
or production 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

A.5.3.1 If the Scheme includes 
an option to implement a risk 
based approach to sourcing 
non-certified material (Due 
Diligence System), it shall:  
i) contain clear requirements 
and ii) ensure consistent 
implementation of the Due 
Diligence System, for all 
activities, materials and 
suppliers included within the 
scope of the certification. 

A.5.3.2 The Scheme shall 
include requirements that 
ensure that whenever there 
is a change in the risk 
related to illegal harvest, 
trade or transport in a 
supply chain – or a supply 
chain covered by a DDS – 
the risk  shall be assessed 
and mitigated prior to 
shipping and sale. 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood 

Findings 

Covered 

PART I DUE DILIGENCE SYSTEM 
1 Implementation and maintenance of a due diligence 
system 
1.1 The organization shall have, implement, and maintain 
a documented due diligence system (DDS) for material 
supplied without an FSC claim to be used as controlled 
material or to be sold with the FSC Controlled Wood claim. 
1.2 The organization shall include all suppliers and sub 
suppliers of the material assessed according to this 
standard in its DDS (see Figure 3). 
1.5 The organization shall only use material as controlled 
material or sell material with the FSC Controlled Wood 
claim3 if it is in conformity with the requirements of this 
standard, confirmed through the DDS. 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood 

“1.6 The organization shall review and, if necessary, 
revise its DDS at least annually, and whenever changes 
occur that affect the relevance, effectiveness, or adequacy 
of the DDS (see Figure 4).” 

“1.10 The organization shall not use material from supply 
chains where ineffectiveness of the DDS leads to, or might 
lead to, non-eligible inputs entering the production.” 

“2.4 The organization shall enforce its suppliers to notify it 
of any changes that may affect a risk designation or the 
mitigation of risk, such as changes in species, origin, or 
supply chain.” 

Annex D Summary of the controlled wood evaluation 
process 

640 

The standard: ‘Requirements for sourcing FSC 
Controlled Wood’ is applicable to supply chain 
entities sourcing non-certified material. It uses 
a risk-based  approach and includes clear 
requirements and requires a consistent 
approach via systems and procedures. In 
aiding the consistent approach FSC have 
published National level risk assessments  for 
many of the World’s timber producing countries 
which Certificate Holders are obliged to use.  

Justification 

Based on the normative requirements within 
standard FSC-STD-40-005, this indicator has 
been evaluated as Covered.  
Findings 

Covered 

The Requirements for sourcing FSC Controlled 
Wood standard requires the Certificate Holder 
to review, and if necessary, revise its DDS at 
least annually, and whenever changes occur 
that affect the relevance, effectiveness or 
adequacy of the DDS (Clause 1.6), and to 
enforce its suppliers to notify it of any changes 
that may affect a risk designation or the 
mitigation of risk, such as changes in species, 
origin and supply chain (Clause 2.4). Nowhere 
does the standard explicitly refer to assessing 
and mitigating prior to shipping and sale, 
however, clause 1.10 prohibits the use of 
material where DDS deficiencies might lead to 
non-eligible material entering production. It is 
considered that this clause, effectively captures 
the requirement to ensure DD is conducted 
prior to sale.  

 
 
 
 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

Additionally, Annex D outlines the CW 
evaluation process which indicates that low risk 
shall be concluded before material is classified 
as controlled material / FSC Controlled Wood, 
although, the Annex is informative only.  

Justification 

Based on the normative requirements within 
standard FSC-STD-40-005, this indicator has 
been evaluated as Covered.  

A.5.3.3 In cases where 
other 3rd party schemes 
permitted to be used by the 
due diligence system as 
meeting specific due 
diligence requirements, the 
scheme shall include 
requirements that ensure 
that it is clear: 
i) on what basis recognition 
is made and;  
ii) how it is verified that 
other Schemes ensure 
conformance with the 
specific due diligence 
requirements. 
A.5.3.4 The Scheme shall 
include requirements to 
ensure that the DDS 
comprises, at a minimum, 
the following elements:  
i) a quality management 
system,  
ii) procedures for obtaining 
access  to information 
pertinent to the 
identification of risk;  

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood 

Findings 

Not Applicable 

FSC Controlled Wood standard FSC-STD-40-
005 does not include the recognition of other 
3rd party schemes. 

Justification 

This indicator is not applicable. 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood 

Findings 

Covered 

PART I DUE DILIGENCE SYSTEM 
1 Implementation and maintenance of a due diligence 
system 
… 
2 Obtaining information on material  
… 
3 Risk  assessment 
… 

641 

Part II of the standard is dedicated to quality 
management, whilst Part I consists of 
requirements covering accessing information, 
risk  assessment  and risk  mitigation.  

Justification 

 
 
 
 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

iii) risk assessments,  and  
iv) the implementation of 
mitigations measures when 
risks  are identified. 

4 Risk  mitigation 
… 
PART II QUALITY MANAGEMENT SYSTEM 
5 Competence, documentation, and records 
… 
6 Publicly available information 
… 
7 Stakeholder input and complaints 
… 

B. Requirements for Certification Bodies 

Based on the normative requirements within 
standard FSC-STD-40-005, this indicator has 
been evaluated as Covered.  

Scheme requirements for Certification Bodies shall be clear and unambiguous and allow the Scheme  owner to verify the level o f conformance of each Certification Body to these requirements. 

B.1 General Certification Body requirements 

B.1.1 

Competence 
and 
qualifications 

B.1.1.1 The Scheme shall 
have mechanisms to 
ensure that auditors, and 
other relevant personnel of 
the Certification Body, are 
qualified and competent to 
evaluate organisations’ 
compliance with specific 
Scheme requirements. 

FSC-STD-20-001 General requirements for FSC accredited 
certification bodies 

Findings 

Covered 

Part 3 of the general requirements for 
Certification Bodies (FSC-STD-20-001) details 
resource requirements. Clause 3.1.1 
specifically covers this requirement.  

Justification 

Based on the normative requirements within 
standard FSC-STD-20-001, this indicator has 
been evaluated as Covered.  

Part 3: Resource requirements  
“3.1.1 The certification body shall have personnel 
competent for managing its work related to the 
implementation of the FSC accredited certification 
program. 
3.1.2 The certification body shall have personnel with 
sufficient capacity to cover all operations and to handle the 
volume of work related to the implementation of the FSC 
accredited certification program. 
3.1.3 The certification body shall have, implement and 
maintain a procedure for the management of 
competencies of personnel involved in the implementation 
of the FSC accredited certification program. 
3.1.4 This procedure shall require the certification body to 
determine the criteria for the competence of personnel for 
each function in the implementation of the FSC accredited 
certification program, taking into account the following 
requirements: 
a) the person(s) that is (are) responsible for the application 
review shall incorporate a level of knowledge and 
experience sufficient to prepare the audit process; 

642 

 
 
  
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

b) auditors shall be qualified and maintain their 
qualification as specified in Annex 2; 
c) technical experts shall have demonstrated competence 
in the relevant field of expertise; 
d) peer reviewers shall have demonstrated competence in 
the relevant field of expertise; 
e) the person(s) of the certification decision making entity 
shall be qualified as an auditor for the respective scope as 
specified in Annex 2 and shall incorporate a level of 
knowledge and experience sufficient to assess  the 
evaluation processes, the audit report and associated 
evidence and recommendations made by the audit team; 
f) those approving the trademark use shall demonstrate 
the required competence through the successful 
completion (certificate) of the FSC Trademark Training 
Module (see FSC-PRO-20-004); 
g) the audit team leader shall be a qualified auditor in the 
respective scope with the ability to manage the audit 
process  and the audit team - including report writing, 
effective use of team resources, team management, 
external team representation during audit process, 
management of stakeholder engagement including 
prevention or resolution of conflicts. 
3.1.5 In terms of the personnel qualification this procedure 
shall require the certification body to: 
a) identify individual initial and continuous training needs 
according to the function of the person; 
b) define the scope of initial and continuous training 
according to the findings mentioned under a) and/or 
monitoring and evaluation results against the applicable 
qualification requirements; 
c) carry out an in-house training covering all internal 
aspects of the certification body relevant to certification 
processes  as  part of the initial training; 
d) provide an initial FSC Training Program for auditors 
(see FSC PRO-20-004) and ensure continuous training 
(see Annex 2), either internally or through external service 
providers approved by ASI – if not specified differently by 
FSC; 
e) demonstrate that the personnel has the required 
competencies for the duties and responsibilities they 

643 

 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

undertake, using the specifications in Annex 2, where 
applicable; 
f) formally authorize personnel for functions in the 
certification process; 
g) send at least one certification body representative to an 
annual national/ regional FSC calibration meeting - if 
provided - with a special focus on interpretation and 
application of National Forest Stewardship Standards. 
3.1.6 Personal attributes of auditors as described in Annex 
2, Table 4 shall be taken into account for the following 
activities: 
a) selection of auditor candidates; 
b) auditor qualification process; 
c) monitoring of auditors; 
d) evaluation of auditor performance. 
3.1.7 Qualified auditors shall be registered in the FSC 
Auditor and Training Registry. 
3.1.8 For the monitoring and evaluation of the 
performance of auditors the certification body shall have, 
implement and maintain a documented procedure with the 
following requirements: 
a) regular monitoring of auditors; 
b) an evaluation at least once every three (3) years based 
on the monitoring results and a witness audit; 
c) the definition of monitoring and evaluation criteria shall 
be risk  based and take into account: 
i. a review of conformity with competence requirements as 
listed in Annex 2; 
ii. an assessment of conformity with certification bodies’ 
operational procedures and guidelines including issues 
with conflict of interest and confidentiality requirements; 
iii. a combination of on-site observation, review of audit 
reports and substantiated feedback from clients. 
d) monitoring and evaluation results shall be considered in 
needs for further training; 
e) monitoring and evaluation results shall be documented 
in the auditor performance appraisal report. 
3.1.9 The certification body shall require personnel 
involved in the certification process to sign a contract or 
other documents by which they commit themselves to the 
following, in accordance with the requirements of Annex 1: 

644 

 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

a) to conform with the rules defined by the certification 
body, including those relating to confidentiality, anti -
corruption and independence from commercial and other 
interests; 
b) to declare any prior and/or present association on their 
own part, or on the part of their employer, with: 
i. a supplier or designer of products, or 
ii. provider or developer of services, or 
iii. an operator or developer of processes to the evaluation 
or certification of which they are to be assigned. 
c) to reveal any situation known to them that may present 
them or the certification body with a conflict of interest. 
3.1.10 The certification body shall maintain records of all 
certification body personnel involved in work related to the 
FSC accredited certification program. The records shall 
include a means to confirm the competence, qualification 
and training status of personnel.” 

Annex 2 Qualification requirements for Forest 
Management and Chain of Custody auditor candidates 
and auditors 

Annex 3 Audit teams 

B.1.1.2 If the Scheme 
includes an option for the 
Certificate Holder to 
implement a Due Diligence 
System, the scheme shall 
ensure that the auditors 
and other relevant 
personnel of the 
Certification Body are 
qualified and competent to 
evaluate organisations’ 
compliance with related 
Scheme requirements. 

FSC-STD-20-001 General requirements for FSC accredited 
certification bodies 

Findings  

Partially Covered 

Part 3: Resource requirements  
“3.1.1 The certification body shall have personnel 
competent for managing its work related to the 
implementation of the FSC accredited certification 
program.” 
… 

“Annex 2: Qualification requirements for Forest 
Management and Chain of Custody auditor candidates 
and auditors” 

Part 3 of the general requirements for 
Certification Bodies (FSC-STD-20-001) details 
resource requirements. Clause 3.1.1 requires 
the Certification Body to have competent 
personnel. Annex 2 includes two tables that 
outline the qualification requirements for FM 
and CoC auditors. However, there are no 
competence requirements specific to FSC COC 
Controlled Wood certification (FSC-STD-40-
005) which requires the evaluation of a Due 
Diligence System.  

Annex 3 Audit teams 
“1.6 For controlled wood audits at forest level: 
a) at least one (1) team member with the experience and 

Annex 3 of FSC-STD-20-001 covers the 
composition of audit teams, with clause 1.6 
stating that at least one member of the audit 

645 

 
 
 
 
 
 
 
 
B.1.2 

Impartiality 

B.1.2.1 The scheme shall 
include requirements to 
ensure that auditors, and 
other personnel relevant to 
the conformance evaluation 
of an organisation shall be 
impartial to the entity(-ies) 
under evaluation. 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

qualifications to 
audit relevant aspects of the controlled wood standard 
taking account of 
the scale and complexity of the area to be assessed. Key 
considerations 
for the selection of auditors for an audit shall include 
experience and 
qualifications in relation to the controlled wood categories 
being audited;” 

team shall have relevant experience and 
qualifications for Controlled Wood audits. 
However, this clause is directed at “controlled 
wood audits at forest level”, not those auditing 
the due diligence systems of CoC certificate 
holders.    

Justification 

Based on the normative requirements within 
standard FSC-STD-20-001, this indicator has 
been evaluated as Partially Covered. There are 
no competence requirements specific to FSC 
COC Controlled Wood certification (FSC-STD-
40-005) which requires the evaluation of a Due 
Diligence System. 

FSC-STD-20-001 V4-0 General requirements for FSC 
accredited certification bodies 

Findings 

Covered 

Impartiality requirements are included in 
Section 1.5 of the general requirements for 
CBs, with Clause 1.5.1 in particular, mandating 
it the CB’s responsibility to ensure impartiality.  

Justification 

Based on the normative requirements within 
standard FSC-STD-20-001, this indicator has 
been evaluated as Covered.  

1.5 Impartiality 
1.5.1 The certification body shall be responsible for 
ensuring that certification activities are undertaken 
impartially and shall not allow commercial, financial or 
other pressures  to compromise impartiality. 
1.5.2 The certification body shall have top management 
commitment to impartiality. 
1.5.3 All certification body personnel (either internal or 
external) and committees involved in certification activities 
shall act impartially. 
1.5.4 The certification body and any part of the same legal 
entity and entities under its organizational control or 
controlling it shall not offer or provide consultancy within 
the scope of accreditation to its clients, in conformity with 
the requirements specified in Annex 1. 
1.5.5 The certification body shall maintain and implement 
written policy and procedures for avoidance of conflicts of 
interest. These procedures shall include: 
a) the contractual obligation for all personnel involved in 

646 

 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

the certification process, to disclose in writing to the 
certification body all possible and actual conflicts of 
interest, at the time that the conflict or possibility of conflict 
becomes evident; 
b) documented procedures for determining timely and 
appropriate responses to such declarations of conflict of 
interest as they arise, to ensure that the declared interests 
neither influence, nor are perceived to influence, the 
decisions of the certification body; 
c) the maintenance of records of: 
i. all declarations of potential conflicts of interest; 
ii. every action which has been taken to resolve the 
possibility and actual occurrence of conflicts of interest. 
1.5.6 The certification body shall identify, analyse and 
document risks to its impartiality on an ongoing basis. This 
shall include those risks that arise from its activities, from 
its relationships, or from the relationships of its personnel. 
However, such relationships may not necessarily present 
a certification body with a risk to impartiality. 
NOTE: A relationship presenting a risk to impartiality of the 
certification body can be based on ownership, 
governance, management, personnel, shared resources, 
finances, contracts, marketing (including branding), and 
payment of a sales commission or other inducement for 
e.g. the referral of new clients. 
1.5.7 If a risk  to impartiality is identified, the certification 
body shall be able to demonstrate how it eliminates or 
mitigates such risk. 
1.5.8 The certification body shall ensure that activities of 
separate legal entities with which it has relationships, do 
not compromise the impartiality of its certification activities. 
This also applies to separate legal entities that have a 
relationship with the legal entity of which the certification 
body forms a part of. 
1.5.9 When a separate legal entity offers or provides 
consultancy, the certification body's management 
personnel and personnel in the audit, review and 
certification decision-making process shall not be involved 
in the consultancy activities of the separate legal entity. 
The personnel of the separate legal entity shall not be 
involved in the management of the certification body, 

647 

 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

audit, review, or the certification decision. 
… 
1.5.11 To ensure that there is no conflict of interest, 
personnel (including those acting in a managerial 
capacity) who have provided consultancy, or been 
employed by a client, shall not be used by the certification 
body to audit, review, make certification decisions or to 
review or approve the resolution of a complaint or appeal 
for that client within three (3) years following the end of the 
consultancy or employment. 
1.5.12 The certification body shall have, maintain and 
implement a documented anticorruption policy. 

Committee for safeguarding impartiality 
1.5.13 The certification body shall have a committee for 
safeguarding its impartiality. The committee shall provide 
input on the following: 
a) the policies and procedures relating to the impartiality of 
its certification activities; 
b) any tendency on the part of a certification body to allow 
commercial or other considerations to prevent the 
consistent impartial provision of certification activities; 
c) matters affecting impartiality and confidence in 
certification. 1.5.14 The committee’s terms of reference 
shall be documented to ensure the following: 
a) a balanced representation of interested parties, such 
that no single interest predominates (internal or external 
personnel of the certification body are considered to be a 
single interest, and shall not predominate);  
b) access  to all the information necessary to enable it to 
fulfil all its functions; 
c) at least one (1) annual meeting; 
d) its independence of the financial control of the 
organization; 
e) its independence of certification decision making; 
f) records of its discussions and recommendations; 
g) records of the certification body’s response(s) to its 
discussions and recommendations. 
1.5.15 If the top management of the certification body 
does not follow the recommendations of this committee, 
the committee shall have the right to take independent 

648 

 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

action (e.g. informing authorities, ASI, stakeholders). In 
taking appropriate action, the confidentiality requirements 
of Section 1.8 relating to the client and certification body 
shall be respected. 
1.5.16 Committee’s recommendations that are in conflict 
with the operating procedures of the certification body or 
other mandatory requirements should not be followed. 
Management should document the reasoning behind the 
decision to not follow the recommendations and maintain 
the document for review by ASI. 

3.2 Outsourcing 
3.2.6 The certification body shall: 
a) have documented policies, procedures and records for 
managing the relationship with bodies providing 
outsourced services according to the requirements in this 
standard, unless the option of outsourcing is explicitly 
excluded by the certification body; 
b) ensure that the body that provides outsourced services, 
and its personnel undertake certification services 
impartially; 
c) maintain a list of approved providers of outsourced 
services; 

4.3 Audit 
4.3.7 For forest management audits the following auditor 
rotation requirements shall be applied based on number of 
certificate holders per certification body and country: 
a) with more than twenty (20) certificate holders no auditor 
shall serve as a member of the audit team for more than 
three (3) consecutive audits of the same client; 
b) with eleven (11) to twenty (20) certificate holders no 
auditor should serve as a member of the audit team for 
more than three (3) consecutive audits of the same client. 
Where a client is audited by the same auditor on more 
than (3) consecutive audits, the certification body shall 
provide a justification why it was not possible, or feasible 
to rotate the auditor and shall demonstrate how an 
impartial and objective evidence based audit is ensured; 
c) with less than ten (10) certificate holders auditor rotation 
after three (3) consecutive audits is recommended. 

649 

 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

4.3.8 For all other types of audits the certification body 
should ensure that no client is audited by the same auditor 
on more than three (3) consecutive audits. Where a client 
is audited by the same auditor on more than (3) 
consecutive audits, the certification body shall provide a 
justification why it was not possible, or feasible to rotate 
the auditor and shall demonstrate how an impartial and 
objective evidence based audit is ensured. 

Annex 1 Avoidance of conflict of interest 
1.1 The certification body is allowed to explain its findings 
and/or clarify the requirements of normative documents, 
but shall not give prescriptive advice or consultancy as 
part of an audit or training. 
1.2 The following conditions shall be met for each of the 
categories: 
a) Training: 
i. where the training relates to FSC requirements, it may 
only cover generic information that is freely available in the 
public domain; 
ii. the training does not provide company-specific solutions 
and is not conducted one-on-one with the certification 
client. 
b) Templates: 
i. are publicly available; 
ii. do not provide company specific solutions; 
iii. include a disclaimer, specifying that the template is no 
guarantee for conformity with FSC requirements. It is the 
responsibility of the client to conform with FSC 
requirements; 
iv. the use is voluntary.  
NOTE: Such templates may include sample procedures, 
which can be created for specific industry sectors or types 
of clients, as long as they only contain generic i nformation 
and fictional examples. The development of company 
specific procedures, manuals and handbooks is not 
allowed. 

Box 1: Informative guidance on managing conflicts of 
interest 
(adapted from: ISEAL (2013), Managing conflict of interest 

650 

 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

B.1.2.2 The Scheme shall 
include requirements that 
ensure that the certification 
decision process is;  
i) well defined and; 
ii) ensures that the decision 
on certification is conducted 
by positions/bodies that are 
impartial to the auditee. 

in standards and assurance; ISO 9001 (2005), Auditing 
practices group guidance on third party auditor impartiality 
and conflict of interest) . 
FSC-STD-20-001 V4-0 General requirements for FSC 
accredited certification bodies 

As per B.1.2.2 and in particular: 

“4.5.3 The certification decision making entity shall: 
a) have clear rules for membership, including 
requirements for qualification, experience and impartiality; 
b) consist of one or more individuals, where none of these 
individuals have any conflicts of i nterest, in particular 
financial or other commercial interest in the outcome of the 
certification decision; 
NOTE: This does not refer to a regularly paid salary of an 
employee who is member of the certification body’s 
decision making entity. 
c) not include individuals who have taken part in the audit 
as audit team leaders, auditors or technical experts. 

4.5.4 The person(s) of the certification decision making 
entity shall be employed by, or shall be under contract with 
the certification body (see Section 3.1).” 

Findings 

Covered 

Certification decision requirements are included 
in Section 4.5 of the general requirements for 
CBs, with Clause 4.5.3 in particular, ensuring 
that the decision on certification is conducted 
by positions/bodies that are impartial to the 
auditee. 

Justification 

Based on the normative requirements within 
standard FSC-STD-20-001, this indicator has 
been evaluated as Covered.  

B.2 Certification Body requirements for auditing and certification 

B.2.1 

Auditing 
process 

B.2.1.1 The Scheme shall 
include requirements that 
ensure that Certification 
Bodies apply a documented 
methodology for the 
evaluation (assessments 
and audits) of clients.  

FSC-STD-20-001 V4-0 General requirements for FSC 
accredited certification bodies 

Findings 

Covered 

“ 
Part 2: General management system requirements 
2.2 Management system documentation 
2.2.1 The certification body's top management shall 
establish, document, and maintain policies and 
procedures for implementation of this standard and other 
applicable FSC requirements. The top management shall 
ensure that 
the policies and procedures are acknowledged and 
implemented at all levels of the certification body’s 
organization relevant to FSC certification.” 

651 

Part 2 of the general requirements for CBs 
covers ‘general management system 
requirements’, with Clause 2.2.1 requiring that 
policies and procedures covering all applicable 
standards are documented.  

Justification 

 
 
 
 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

Based on the normative requirements within 
standard FSC-STD-20-001, this indicator has 
been evaluated as Covered.  

2.2.2 The certification body's top management shall 
appoint a management representative as having overall 
responsibility and authority to establish, implement and 
maintain the management system. 
2.2.3 All documentation, processes, systems,  records, etc. 
related to the implementation of FSC requirements shall 
be included, referenced, or linked to documentation of the 
management system. 
2.2.4 All personnel involved in certification activities shall 
have access to the parts of the management system 
documentation and related information that are applicable 
to their responsibilities (personnel in the certification 
body’s office and, as appropriate, in the field). 
2.2.5 The certification body shall have a quality manual 
and associated operational procedures for: 
a) handling of applications; 
b) preparing and conducting audits (in pre-evaluation, 
main evaluation, surveillance and re-evaluation 
processes)  according to the applicable FSC normative 
documents; 
c) conducting unannounced or short notice audits 
according to specified criteria and conditions; 
d) report reviewing and finalizing certification reports, 
(including public summary certification reports and 
surveillance reports); 
e) identification, management and tracking of 
nonconformities of clients; 
f) all types of certification decision making; 
g) registering the certification status and issuing of 
certificates; 
h) the review and approval of requests to use the FSC 
trademarks; 
i) managing conflicts of interest; 
j) managing complaints and appeals; 
k)  control of internal and external documents; 
l) conducting internal audits; 
m) identification, management and tracking of 
nonconformities of certification body’s operations and 
related preventive and corrective actions; 
n) other procedures as necessary  to conform with 
applicable FSC 

652 

 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

requirements. 

3.2 Outsourcing  
3.2.1 The certification body may outsource work related to 
certification to a separate legal entity. In such a case the 
certification body shall ensure that the body that provides 
the outsourced service conforms with applicable 
requirements of this standard and other FSC normative 
documents. 

4.3 Audit  
4.3.1 The processes and products of a client shall be 
audited against the applicable requirements specified in 
the FSC normative documents. All interpretations of FSC 
requirements are at the sole discretion of the FSC 
International Center.  
4.3.2 The certification body shall conduct audits for forest 
management certification in accordance with FSC-STD-
20-007 and related normative documents. In countri es that 
are lacking a National Forest Stewardship Standard or an 
Interim National Standard, the certification body shall 
participate in the process of developing an Interim 
National Standard as specified in FSC-STD- 20-002.  
4.3.3 The certification body shall conduct audits for chain 
of custody certification in accordance with FSC-STD-20-
011 and related normative documents.  
4.3.4 The certification body shall conduct audits for 
controlled wood certification in forest management 
organizations in accordance with FSC-STD-20-012 and 
related normative documents. 
… 
4.3.9 The certification body shall provide all auditors with 
an up-to-date ‘audit handbook’ or equivalent which 
includes all the guidance necessary for the auditors to 
complete audits in accordance with the certification body’s 
documented procedures. The audit handbook shall include 
instructions for auditors regarding at least:  
a) the implementation of any checklists, guidance 
documents and interpretations of FSC normative 
documents;  
b) detecting, analyzing, grading, and addressing 

653 

 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

B.2.1.2 As a minimum, this 
methodology shall include 
procedures for the following 
activities: 
i) Evaluation of conformity 
of organisations to the 
Schemes (e.g. audit of 
sites, or inspection of 
records or of self-
assessment  declarations); 
ii) Review and certification 
decision; 
iii) Issuance of a certificate; 
and 
iv)  Periodic re-assessment. 

nonconformities;  
c) writing reports in accordance with applicable FSC 
requirements and certification body’s procedures;  
d) procedures for the audit of trademark uses in conformity 
with FSC trademark requirements for on-product and 
promotional uses.  

4.3.10 The certification body shall consider ISO 19011 for 
incorporation into the audit handbook and shall at 
minimum include requirements for opening meetings, 
closing meetings and communication of audit findi ngs in 
accordance with ISO 19011, where appropriate. 
FSC-STD-20-001 V4-0 General requirements for FSC 
accredited certification bodies 

Granting certification 
1.4.1 The certification body shall only grant (re)certification 
when their client: 
a) has entered into and holds a valid and most recent 
version of the ‘License Agreement for the FSC 
Certification Scheme’, where the right to use the FSC 
trademarks is not suspended; 
b) conforms with the requirements of all applicable FSC 
normative documents, which means that major 
nonconformities shall be corrected before granting of 
certification and minor nonconformities shall be corrected 
within the maximum timeline specified by the certification 
body. 
Open minor nonconformities do not prevent granting of 
certification; 
c) signed a certification agreement with the certification 
body. 
1.4.2 The period of validity of FSC certification shall not 
exceed five (5) years. 
1.4.3 Recertification may be granted as the result of a re-
evaluation. 
1.4.4 The specified period of validity of certification may be 
extended for a single exceptional extension of up to six (6) 
months in order to permit re-evaluation to be completed, 
when justified by circumstances beyond the control of the 
certification body and their client. The certification body 

654 

Findings 

Covered 

FSC-STD-20-001 Part 2 of the general 
requirements for CBs covers ‘general 
management system requirements’, with 
Clause 2.2.5 specifying the content of the CB’s 
“quality manual and associated operational 
procedures” which covers all the elements of 
this requirement.   

In relation to the points in the indicator, section 
2.7 of the same standard addresses i) the 
evaluation of conformity of organisations to the 
Schemes. Section 4.5 of the same standard 
addresses  ii) review and certification decision; 
whilst 4.6 relates to Issuance of a certificate. 

1.4.2 and 1.4.3 address points iii) and iv).  

Justification 

Based on the normative requirements within 
standard FSC-STD-20-001, this indicator has 
been evaluated as Covered.  

 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

shall take the following steps: 
a) record such circumstances; 
b) update the entry in the FSC certification database 
(info.fsc.org).  

“2.2.5 The certification body shall have a quality manual 
and associated operational procedures for: 
a) handling of applications; 
b) preparing and conducting audits (i n pre-evaluation, 
main evaluation, surveillance and re-evaluation 
processes)  according to the applicable FSC normative 
documents; 
c) conducting unannounced or short notice audits 
according to specified criteria and conditions; 
d) report reviewing and finalizing certification reports, 
(including public summary certification reports and 
surveillance reports); 
e) identification, management and tracking of 
nonconformities of clients; 
f) all types of certification decision making; 
g) registering the certifi cation status and issuing of 
certificates; 
h) the review and approval of requests to use the FSC 
trademarks; 
i) managing conflicts of interest; 
j) managing complaints and appeals; 
k)  control of internal and external documents; 
l) conducting internal audits; 
m) identification, management and tracking of 
nonconformities of certification body’s operations and 
related preventive and corrective actions; 
n) other procedures as necessary  to conform with 
applicable FSC 
requirements.” 

2.7 Corrective actions and preventive actions of the 
certification body 
2.7.1 The procedures for corrective actions and preventive 
actions shall define requirements for the following: 
a) identifying nonconformities (e.g. from complaints and 
internal and external audits) and potential nonconformities; 

655 

 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

b) determining the causes of nonconformity; 
c) correcting nonconformities; 
d) evaluating the need for actions to ensure that 
nonconformities do not occur or recur; 
e) determining and implementing the actions needed in a 
timely manner; 
f) recording the results of actions taken; 
g) reviewing the effectiveness of corrective actions and/or 
preventive actions. 

4.5 Certification decision 
4.5.1 The certification body shall be responsible for, and 
shall retain authority for, its decisions relating to 
certification. 
4.5.2 The certification body shall assign a certification 
decision making entity to make the certification decision 
based on all information related to the audit, its review, 
and any other relevant information. The person(s) of the 
certification decision making entity shall not have been 
involved in the audit process. 
4.5.3 The certification decision making entity shall: 
a) have clear rules for membership, including 
requirements for qualification, experience and impartiality; 
b) consist of one or more individuals, where none of these 
individuals have any conflicts of interest, in particular 
financial or other commercial interest in the outcome of the 
certification decision; 
… 
c) not include individuals who have taken part in the audit 
as audit team leaders, auditors or technical experts. 
4.5.4 The person(s) of the certification decision making 
entity shall be employed by, or shall be under contract with 
the certification body (see Section 3.1). 
4.5.5 The certification body shall make and communicate 
certification decisions to the client after the main 
evaluation according the following maximum timelines and 
requirements: 
a) six (6) months in the case of chain of custody 
evaluations; 
b) twelve (12) months in the case of forest management 
and controlled wood forest management evaluations, or 

656 

 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

c) up to eighteen (18) months in exceptional and justified 
cases  for forest management evaluations, where due to 
major nonconformities a positive certification decision 
cannot be made within twelve (12) m onths. Between 
twelve (12) months and (18) months an on-site audit shall 
be required to verify the validity of the main evaluation 
findings and to evaluate any 
changes to the management system. 
4.5.6 When communicating a negative certification 
decision the certification body shall provide the reasons for 
this decision. 

4.6 Registering of certification status and issuing of 
certificate 
4.6.1 The certification body shall register the certification 
status in the FSC certification database (info.fsc.org) after 
the certification decision making entity has granted 
certification. The registration requires the entry of all 
specified data, together with an electronic copy of the 
public summary certification report (as applicable). 
4.6.2 In the case of FSC announcing a malfunction of the 
on-line registration service, the certification body shall 
inform ASI and FSC that certification or recertification has 
been granted within ten (10) days of the certification 
decision. 
4.6.3 Certification bodies are responsible for keeping their 
data entries and public summary certification reports 
accurate and up-to-date. 
4.6.4 A certificate shall only be issued after a positive 
certification decision has been taken by the certification 
decision making entity and after it has been registered in 
the FSC certification database, together with the public 
summary certification report. 
FSC-STD-20-001 V4-0 General requirements for FSC 
accredited certification bodies 
2.2.5 (see B.2.1.2 above) 

Findings 

Covered 

i) FM (6.1.1), FM CW (9.1.2) and CoC (3.1) 

“Reporting 
4.3.21 The certification body shall document the findings 
and conclusions of all audit activities prior to review and 
decision making in a certification report in conformity with 

ii) FM (6.3.1) and (6.3.1. to 6.3.3) for SLIMFs. 
SLIMF auditing requires that annual audits be 
conducted on site at least once per certificate 
validity period (5 years). For the remaining four 

657 

B.2.1.3 The Scheme shall 
include requirements that 
ensure that Certification 
Bodies have in place - and 
implement – specific 
procedures for audits that 
include at least the 
following: 

 
 
 
 
 
i) frequency of audits; (no 
longer than every 12 
months); 
ii) requirements for on-site 
(field) visits where 
applicable; 
iii) sampling protocol for 
audits (if applicable); 
iv) structure and 
competencies of the audit 
team; 
v) the minimum set of 
aspects that need to be 
checked in every audit; 
vi) minimum content of 
audit reports, including non-
conformances, clarification 
of scope, audit process and 
evaluation findings. 
vii) ability for unannounced 
or short-notice audits in 
case of substantiated 
claims or for other reasons.  

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

the report writing requirements specified in: 
a) FSC-STD-20-007a for forest management certification 
reports; 
b) FSC-STD-20-007b for forest management public 
summary certification reports; 
c) FSC-STD-20-011 for chain of custody certification 
reports; 
d) FSC-STD-20-012 for controlled wood forest 
management certification reports.” 

Annex 3 Audit teams 

FSC-STD-20-007 V3-0 Forest management evaluations 

“6.1.1 The certification body shall carry out a surveillance 
evaluation to monitor the certificate holder’s continued 
conformity with applicable certification requirements at least 
annually. 

NOTE: For a certificate having a five year duration at least 
four surveillance evaluations shall take place before the 
certificate expires. However, a surveillance evaluation may 
not require an FMU level site visit (see Paragraph 6.3, 
below).” 

“6.3.1 The certification body shall carry out one or m ore 
FMU level site visits annually for all certificate holders 
except in the case of those managing SLIMF operations 
(see below). 

6.3.2 In the case of a single SLIMF, the certification body 
shall carry out at least one FMU level site visit during the 
period of validity of the certificate. If there are no 
outstanding corrective actions to be evaluated which may 
require site verification, no 
complaints requiring evaluation and no significant forest 
activities have taken place 
in the previous 12 months, the remaining surveillance 
evaluations may be based on 
review of the documentation and records specified in 6.2, 
above, and do not require 

years, desk-based audits may be conducted 
based on the absence of the following: i) 
outstanding corrective actions to be evaluated 
which may require site verification; ii) 
complaints received which would require 
evaluation; iii) no significant forest activities 
have taking place in the previous 12 month 
period. FM CW (9.3.1) and CoC (2.6) 

iii) FM (Section 5.3 and Annex 1 for group 
certification), FM CW (4.3.1) and CoC (7.5) 

iv) Covered by Annex 3 in the general 
requirements for CBs (FSC-STD-20-001 V4-0) 

v) At the forest level there is provision for CBs 
to evaluate different requirements each year, 
as long as all are covered within the duration of 
the certificate (Clause 6.3.7). Clause 3.1 in the 
Evaluations of CoC (FSC-STD-20-011) states 
that conformance to all applicable requirements 
shall be evaluated at every surveillance audit. 

vi) Clause 4.3.21 of the general requirements 
for CBs  requires that audit findings and 
conclusions shall be documented in reports 
and references four separate standards to 
specific requirements related to FM, FM CW 
and CoC. For FM FSC-STD-20-007a details 
the requirements for the contents of the full FM 
audit reports and FSC-STD-20-007b gives the 
requirements for the contents of the public 
summaries. Section 10 of the Evaluation 
standard for FM CW  (FSC-STD-20-012 V1-1) 
gives detailed requirements for report contents, 
as does Table B in Part III of the Evaluation 
standard for CoC which also includes the 
sourcing of CW (DDS)  (FSC-STD-20-011 V4-
1).  

vii) Covered by Clause 2.2.5 b in the general 

658 

 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

FMU level site visits. 

requirements for CBs (FSC-STD-20-001 V4-0) 

Justification 

Based on the normative requirements within 
the accreditation series of standards (FSC-
STD-20-XXX), this indicator has been 
evaluated as Covered.  

6.3.3 In the case of groups or sub-groups of SLIMFs with 
less  than 100 members the 
certification body shall carry out at least one FMU level 
site visit at the end of the first 
year in which the certificate was issued, and at least one 
additional FMU level site 
visit during the period of validity of the certificate. If there 
are no outstanding 
corrective actions to be evaluated and no unresolved 
complaints requiring evaluation 
the remaining surveillance evaluations may be based on 
review of documentation 
and records specified in 6.2 above, and do not require 
FMU level site visits. The 
certification body shall take account of the rate of change 
of membership within the 
group; changes to the group management structure and 
the type and variety of 
forest activities being implemented within the group before 
making the decision to 
waive an annual FMU level site visit”. 

Box 1 

“6.3.7 Surveillance shall include: 
a) evaluation of the certificate holder’s compliance with all 
conditions (corrective actions) on which certification is 
based; 
b) review of any complaints or allegations of non-
conformity with any aspect of the applicable Forest 
Stewardship Standards; 
c) evaluation of a sample of sites and records, and 
interviews with affected stakeholders sufficient to verify 
that management systems (documented or 
undocumented) are working effectively and consistently in 
practice, in the full range of management conditions 
present in the area under evaluation. 
NOTE: The certification body may focus its surveillance 
during a particular annual surveillance evaluation on 

659 

 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

specific elements of the applicable Forest Stewardship 
Standard (e.g. those pertaining to particular FSC 
Principles or to particular aspects of 
management) with the provision that all aspects of the 
Forest Stewardship Standard are monitored during the 
period of validity of the certificate. Certification bodies may 
therefore focus on particular aspects of the forest 
management system reducing the 
time and cost of surveillance.” 

Annex 1: Sampling for group certification 

FSC-STD-20-007a V1-0 Forest management evaluations 
addendum – Forest certification reports 

FSC-STD-20-007b V1-0 Forest management evaluations 
addendum – Forest certification public summary reports 

FSC-STD-20-012 Standard for evaluation of FSC 
Controlled Wood in Forest Management Enterprises 

“4.3.1 Requirements for sampling of FMEs with more than 
one FMU sites will be based on those for FSC forest 
management certification.” 

“9.1.1 The certification body shall document, implement 
and maintain evaluation systems and procedures for 
surveillance evaluations. These shall include all of the 
elements in this Section.” 

“9.1.2 Procedures for surveillance evaluations shall 
specify frequency and duration of surveillance visits in 
accordance with the scale and intensity of forest 
management. Surveillance audits shall be conducted at 
least on an annual basis.” 

“9.1.3 A certification body shall also carry out surveillance 
evaluation in response to complaints of non-compliance 
for which evidence is provided.” 

“9.3.1 FMU level site visits shall be employed for 

660 

 
 
 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

surveillance visits.” 

“10. Controlled Wood certification reports” 

“13.1.1 The certification body’s documented procedures 
shall define the composition of evaluation teams for 
Controlled Wood for main evaluations.” 

“13.2.1 The certification body’s evaluation system and 
procedures shall define the composition of evaluation 
teams for Controlled Wood surveillance evaluations.” 

FSC-STD-20-011 V4-1 Chain of Custody Evaluations  

“2.6 The certification body shall evaluate each operational 
site within the scope of the evaluation (including a sample 
of participating sites of group and multisite certificates and 
non-FSC-certified project members in the case of project 
certificates) in order to make direct, factual observations to 
verify the 
organization’s conformance to all applicable certification 
requirements. The evaluation shall include: 
… 
e) physical inspection of all sites selected for evaluation, 
including inspection of all locations where operational 
activities under the scope of the certificate are carried out. 
Desk  audits may be conducted where: 
i. the site does not take physical possession of FSC-
certified materials or products, controlled material, or FSC 
controlled wood in their own or rented facilities, and does 
not label, alter, store, or repackage the products (e.g. 
sales office); 
ii. the site is used for storage of finished and labelled 
products only, and where the certification body has 
confirmed through an initial physical inspection that there 
is no risk  of mixing FSC-certified products with other 
materials (e.g. the site only stores FSC-certified products). 
Certification bodies shall conduct physical inspection of 
these storage sites  at least once during the five-year 
duration of a certificate; 
iii. the physical inspection during surveillance evaluations 

661 

 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

of one-time project certificates is not relevant (e.g. there is 
nothing to inspect on the site; a single delivery of materials 
to the project; when all project members supplying the 
project are FSC-certified). 
NOTE: Certification bodies are not obliged to conduct 
desk  audits, even when all requirements specified in 2.6 e) 
above are satisfied. At its own discretion, initially or at any 
time, the certification body may decide to carry out site 
visits where and when necessary to ensure confidence in 
a certificate.” 

“3.1 The certification body shall carry out a surveillance 
evaluation to monitor the organization’s continued 
conformance to all applicable certification requirements at 
least annually. 
NOTE: The evaluation of corrective action to close major 
nonconformity may require on-site audits at shorter 
intervals.” 

“3.2 For a certificate that has a five-year validity, at least 
four surveillance evaluations shall take place before the 
certificate expires. The number of surveillance evaluations 
may be reduced if Clause 3.3 applies. 
NOTE: In the context of surveillance, “annually” is to be 
interpreted as follows: at least once per calendar year, but 
not later than 15 months after the last evaluation 
(determined by the date of the field visit or desk 
evaluation).” 

“3.3 For an operation or site that did not perform activities 
under the scope of the CoC certificate (e.g. did not 
produce, label, or sell any FSC-certified material and did 
not source controlled material or sell any FSC controlled 
wood since the previous audit), a surveillance evaluation 
may be waived. However, certification bodies shall not 
waive more than two consecutive surveillance 
evaluations.” 

“7.5 The certification body shall select a sample of the 
participating sites for evaluation of conformance to the 
applicable FSC normative documents. The certification 

662 

 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

body shall divide the participating sites into two sets of 
sites: 
normal-risk participating sites and high-risk participating 
sites (see  Terms and definitions), which shall be sampled 
separately by using the following formulas: 
a) for main evaluations, surveillance evaluations, and re-
evaluations: 
y = R √x, where: 
y = number of participating sites to be audited by the 
certification body (rounded to the upper whole number) 
R = risk  index (see Table A) 
x = total number of normal-risk or high-risk participating 
sites 
NOTE: In the case of surveillance evaluations, 
participating sites which have not had any FSC activity 
according to Clause 3.3 since the previous certification 
body evaluation do not need to be included in the 
population of sites (value ‘x’ in the formula) 
from which the sample is drawn. 
b) for the inclusion of new participating sites (beyond the 
approved annual growth rate): 
y = R √n, where: 
y = number of participating sites to be audited by the 
certification body (rounded to the upper whole number) 
R = risk  index (see Table A) 
n = number of new normal-risk or high-risk participating 
sites to be added to the certificate scope.” 

PART III: Chain of Custody Evaluation Reports 
Table B. Minimum content of evaluation reports 
FSC-STD-20-007 V3-0 Forest management evaluations 

Findings 

Covered 

“1.2 In order to provide such an assurance the certification 
body shall: 
… 
c) Carry out sampling of sites, documents, management 
records, interviews, consultation with stakeholders and 
direct factual observations sufficient to verify that there are 
no major non-conformities with the performance 
thresholds specified in the applicable Forest Stewardship 
Standard within any FMU within the scope of the 

The standard ‘Stakeholder consultation for 
forest evaluations’ (FSC-STD-20-006 V3-0) 
outlines FSC’s expectations on the nature and 
extent of stakeholder consultation required for 
FM evaluations. Section 5 of the evaluation 
standard for FM controlled wood covers 
stakeholder consultation which is a streamlined 
version of requirements given in 

663 

B.2.2 

Stakeholder 
consultation 

B.2.2.1 The Scheme shall 
include mechanisms to 
ensure that Certification 
Bodies conduct 
consultation with 
stakeholder (including 
rights holders) as 
appropriate in relation to 
audits (only applicable 
where necessary** for 
evaluating compliance of 

 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

certificate holders).  

evaluation.” 

aforementioned standard.  

Section 6 of the evaluation standard for CoC 
covers stakeholder consultation required for 
CHs  implementing a DDS for sourcing 
controlled wood. 

Justification 

Based on the normative requirements within 
the accreditation series of standards (FSC-
STD-20-XXX), this indicator has been 
evaluated as Covered.  

The scheme shall ensure 
that the certification holder 
has a proper stakeholder 
consultation process in 
place. 

“3.2.1 Pre-evaluations shall include the following 
elements: 
… 
b) Review and discussion with forest managers of the 
requirements of the standard(s) to be used for the 
evaluation, including procedural requirements such as 
stakeholder consultation (see FSC-STD-20-006 
Stakeholder consultation for forest evaluation).” 

FSC-STD-20-006 V3-0 Stakeholder consultation for forest 
evaluations 

FSC-STD-20-012 Standard for evaluation of FSC 
Controlled Wood in Forest Management Enterprises 
“5. Stakeholder consultation for Controlled Wood 
evaluation 
5.1 At least one month prior to the field visit, the 
certification body shall inform the FSC accredited 
National Initiative in the country and stakeholders who can 
provide relevant information as to an applicant's 
compliance. 
5.2 The certification body shall develop and document its 
methodology for informing stakeholders. 
5.3 The methodology shall ensure that: 
a) a range of stakeholders are informed about the 
upcoming audit, appropriate to the scale, complexity and 
number of FMUs being assessed; 
b) stakeholders have the opportunity to present their 
points of view to the auditor(s) 
in confidence; 
c) information and opinions given by stakeholders are 
evaluated objectively and meaningfully, and affect the 
certification decision only in so far as they provide 
evidence of compliance or non-compliance with the 
applicable requirements of the FSC Controlled Wood 
standard for forest management enterprises. 
5.4 The certification body shall keep the following records 
for each evaluation: 
a) names and contact details of individuals/organisations 

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consulted on the applicant's compliance with the 
requirements of the applicable standard; 
b) copies of all correspondence and/or written comments 
received; 
c) references to key  documents provided by the applicant 
5.5 For Small and Low Intensity Managed Forest (SLIMF)3 
the certification body is not required to undertake public 
consultation as outlined in Sections 5.1 to 5.4 above.” 

FSC-STD-20-011 V4-1 Chain of Custody Evaluations  

“6 Evaluation of controlled wood according to FSC-STD-
40-005 
Stakeholder consultation 
NOTE: Stakeholder consultation requirements apply only 
for the first evaluation and subsequent re-evaluations of 
the organization to FSC-STD-40-005. However, these are 
applicable only where material is sourced from 
unassessed,  specified, or unspecified risk areas according 
to the applicable FSC risk assessment. 
6.1 The certification body shall conduct stakeholder 
consultations adequate to the size and scale of the 
organization’s due diligence system (DDS) to verify its 
conformance to applicable requirements. The certification 
body shall: 
a) identify and invite directly affected stakeholders to 
participate in the consultation. Invitation of relevant FSC 
network partners is mandatory; 
b) provide a public notification about the consultation 
process,  including dates and activities in the scope of the 
consultation, in order to accommodate participation of 
interested stakeholders. Means of notification shall ensure 
that interested stakeholders can access information about 
the consultation; 
NOTE 1: Invitation of directly affected stakeholders aims to 
ensure they are directly informed about the consultation 
process  and to increase their engagement, whilst public 
notification aims to provide additional opportunity for 
engagement of interested stakeholders. 
NOTE 2: Consultation can only be conducted based on 
voluntary engagement of directly affected or interested 

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stakeholders. 
c) provide participating stakeholders with access to 
information as required in Section 6 of FSC-STD-40-005 at 
least six weeks  prior to the evaluation; 
d) employ effective and culturally appropriate means of 
invitation, notification, and consultation; 
NOTE: Examples of techniques may include: 
announcement via the certification body's website; face-to-
face meetings; personal contacts by phone, email, or 
letter; notice published in the national and/or local press 
and on relevant websites; local radio announcements; 
announcements on local customary notice boards. 
Consultation may include a request for written comments 
on a predetermined set of specific questions. 
e) ask  participating stakeholders for consent for the 
publication of their comments; 
f) provide stakeholders with the opportunity to comment in 
confidence; 
g) evaluate information and comments provided by 
stakeholders objectively and meaningfully. The 
certification decision shall only be affected in so far as the 
comments provide evidence of conformity or 
nonconformity to the applicable requirements; 
h) respond to all stakeholders who participated in the 
consultation process and explain how their comments 
were taken into account within 30 days of making the 
certification decision; 
i) maintain records of the consultation process, including 
stakeholders identified, stakeholders who participated in 
the consultation and their comments, and evidence that 
the consultation was carried out in line with the 
requirements of this standard.” 
FSC-POL-01-004 V2-0 Policy for the Association of 
Organizations with FSC 
“FSC will only allow its association with organizations that 
are not directly or indirectly 
involved in the following unacceptable activities: 
a) Illegal logging or the trade in illegal wood or forest 
products 
b) Violation of traditional and human rights in forestry 
operations 

666 

B.2.2 

Corruption 

B.2.2.2 The Scheme shall 
include mechanisms to 
identify (or for the 
Certification Body to do so) 
companies sanctioned for 
engagement in corrupt 
practices relevant to the 
forest sector.  

Findings 

Partially Covered 

As noted at C.1.3, normative requirements for 
Certificate Holders addressing corruption are 
clear at the forest management level. For CoC 
Certificate Holders Commitment to FSC’s 
Policy for Association (FSC-POL-01-004) 
addresses  corruption related to illegal 

 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

c) Destruction of high conservation values in forestry 
operations 
d) Significant conversion of forests to plantations or non-
forest use 
e) Introduction of genetically modified organisms in 
forestry operations 
f) Violation of any of the ILO Core Conventions” 

“2 Due Diligence 
2.1 Before entering into an association with an 
organization or individual, FSC shall  
conduct a due diligence evaluation according to FSC-
PRO-10-004 to evaluate the 
existence of objective evidence that an organization is 
directly or indirectly involved 
in any of the unacceptable activities as listed in Part I 
Clause 1. 
2.2 FSC shall only enter into an association with 
organizations or individuals that have 
passed the due diligence evaluation.” 

FSC-PRO-01-009 V4-0 Processing FSC Policy for 
Association Complaints Procedure 
“A Objective 
This procedure is used to process  complaints* about 
violations of the FSC Policy for 
Association, as well as to define the consequences to the 
associated* organization (and their affiliated groups*) or 
individuals when a violation is found to have occurred.” 

“B Scope 
This procedure is applied to individuals and organizations 
associated* with FSC (i.e., members, certificate holders 
and certification bodies) and to their affiliated groups*. 

An evaluation according to this procedure may be initiated 
by FSC upon presentation of substantial information* that 
the associated party (or its affiliated group*) might be in 
violation of the FSC Policy for Association. This may occur 
through a formal complaint* lodged by a stakeholder or by 
other means, as further detailed in Clause 2.3 below. 

667 

harvesting (see A.4.1.2). 

FSC has procedures for processing complaints 
(FSC-PRO-01-008 and FSC-PRO-01-009), 
which can be used for complaints regarding 
corruption of organisations already associated 
with FSC (see  findings at C.1.2.1).  

Clause 2.1 of the policy states that FSC shall 
conduct due diligence “to evaluate the 
existence of objective evidence that an 
organization is directly or indirectly involved in 
any of the unacceptable activities” prior to 
entering into an association with them. It refers 
to a procedure FSC-PRO-10-004 Due 
Diligence Evaluation for the Association with 
FSC. Only a draft version of the procedure 
could be found (Draft 2) but the version history 
indicates that it is an internal operating 
procedure. However, when asked, FSC 
informed that it “is currently not in use” but FSC 
“are assessing  whether to introduce a PfA due 
diligence system as part of the ongoing revision 
process”. 

The report ‘FSC and Corruption’ (2017) states 
that “the Policy for Association has a 
communications value perspective as intention 
to ban corruption in an organization associated 
with FSC” but is unclear how this would be 
effective where corruption is unrelated to illegal 
logging. 

There is an ongoing revision process for the 
Policy for Association.  

Justification 

Mechanisms exist which could identify and deal 

 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

with corrupt practices by Certificate Holders. 
However, there are no normative requirements, 
nor formal processes, for identifying 
Organisations sanctioned for engagement in 
corrupt practices proactively and prior to 
association with FSC. Thus, this indicator has 
been evaluated as Partially Covered. 

This procedure is only used to evaluate possible violations 
to the FSC Policy for Association. Complaints* against an 
organization related to the six unacceptable activities of 
the FSC Policy for Association that overlap with 
certification requirements shall follow the ordi nary route for 
dispute resolution defined in respective certification 
requirements and FSC-PRO-01-008 Processing 
Complaints in the FSC Certification Scheme. The 
complaints* will be processed according to dispute 
resolution procedures of the certificate-holder, the 
certification body and/or Assurance Services International 
(ASI).” 

FSC-PRO-10-004 V2-0 Due Diligence Evaluation for the 
Association with FSC DRAFT  2 
“VERSION HISTORY 
V1-0: initial version, and an internal operating procedure. 
V2-0: proposed, and first proposed public procedure. 
Revisions are being suggested to expand the procedure 
beyond an applicant’s ‘self-declaration’ towards a ‘self-
assessment’  and to include active risk screening by FSC 
and stakeholders. Furthermore, there is now a 
requirement for disclosure of the applicant’s organizational 
structure and countries of operation.” 

“A. Scope 
This procedure is implemented by FSC and is applied to 
both applicant FSC members (for FSC International 
membership) and applicant certificate holders.” 

FSC-PRO-01-008 V2-0 Processing Complaints in the FSC 
Certification Scheme Procedure 

“A Scope 
This document describes the process to be adopted by 
FSC to ensure a timely, independent and effective 
resolution of complaints submitted by FSC stakeholders. 
These can be complaints regarding the FSC normative 
framework or the performance of FSC International, the 
FSC Network as  well as complaints regarding the 

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performance of ASI. 
This procedure does not deal with complaints under the 
Policy for Association for which a specific procedure is 
available (FSC-PRO-01-009).” 

Policy for the Association of Organizations with FSC 
revision process: https://fsc.org/en/current-
processes/policy-for-the-association-of-organizations-with-
fsc-pfa  

C. Requirements for Certification Schemes 

C.1 Transparency 

C.1.1 

Transparency 

C.1.1.1 Scheme 
requirements for both 
Certificate Holders and 
Certification Bodies shall be 
publicly available online.  

https://fsc.org/en/businesses/certification-resources  
https://fsc.org/en/document-centre  

Findings 

Covered 

The requirements for Certificate Holders and 
Certification Bodies are easily accessed on 
FSC’s  website.  

Justification 

Scheme requirements for both Certificate 
Holders and Certification Bodies are fully 
publicly available. T his indicator has been 
evaluated as Covered. 

C.1.1.2 Schemes shall 
include requirements that 
ensure that relevant 
information about the 
following is freely available: 
i) development and content 
of the Scheme; 
ii) how the system is 
governed;  
iii) who is evaluated and 

https://fsc.org/en/current-processes  
https://members.fsc.org/en/Members  
https://fsc.org/en/governance-strategy 
https://consultation-platform.fsc.org/  
https://fsc.org/en/contribute-to-the-standards  

FSC-STD-20-006  V3-0 Stakeholder  Consultation  for 
Forest Evaluations 

https://www.asi-assurance.org/s/disputes 

Findings 

Covered 

Points i and ii are easily found on FSC’s 
website.  

ii) In preparation of forest management audits, 
certification bodies have to inform identified 
stakeholders and invite input (FSC-STD-20-
006). The ASI website allows to file complaints, 
appeals and incidents on the performance of 

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under what process;  
iv) impact information and 
the various ways in which 
stakeholders can engage. 

http://www.asi-assurance.org/s/map  

https://fsc.org/en/impact/demonstrating-impacts 

Certification Bodies, ASI and Certificate 
Holders allows for input to upcoming ASI 
assessments  through the website: 
http://www.asi-assurance.org/s/map. 

iv) FSC’s  new consultation platform provides 
the opportunity to feedback on specific 
documents that are currently out for 
consultation. It is not restricted to FSC 
members; anyone can join the consultation 
platform and participate in any of the 
consultations that are open to the public. In 
general, all consultations that are advertised on 
the FSC newsfeed are open to public (unless 
otherwise specified). Additionally, stakeholders 
can give input anytime to the existing normative 
documents, including the ones not being under 
revision via the ‘contribute to the standards’ 
webpage. 

Impact information is provided on the webpage 
‘Demonstrating Impacts’ 
https://fsc.org/en/impact/demonstrating-
impacts.   

Justification 

The FSC Scheme has been evaluated as 
Covered.  

C.1.1.3 The Scheme shall 
include requirements that 
ensure that an up-to-date 
register of certified/verified 
organisations is publicly 
available. 

https://info.fsc.org/  

Findings 

Covered 

FSC-STD-40-004 V3-0 
Chain of Custody Certification  
 “2.2 In order to confirm any changes that might affect the 
availability and authenticity of the supplied products, the 
organization shall regularly verify the validity and product 
groups scope of the certificates of their active FSC-
certified suppliers through the FSC certificate database 

FSC’s  ‘Public Search’ certificate database is 
“the one stop for inquiries about certificates and 
their status”. The database is searchable by 
company name or certification code. The 
information on each certificate includes names, 
sizes  and locations of all  certified units 
(Latitude/Longitude of FMUs is given in the FM 

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(info.fsc.org).” 

Public Summary reports uploaded to the 
certificate page), including expiry dates, 
standards and certificate scope.  

Information on certified product scope of the 
certificate includes: 

Products groups  
Species (or genera) 
Primary and secondary activities 

 
 
 
  Claims  

The database can be updated at any point by 
the Certification Body but is commonly done 
after an annual audit. The updates made by the 
Certification Body are visible within 24 hours. 
The date and time of the last update to the 
certificate page is also given. 

The certificate database forms a fundamental 
part of the scheme as Certificate Holders are 
required to check the status and scope of their 
certified suppliers’ certificates frequently.  

Justification 

Scheme requirements ensure that an up-to-
date register of certified/verified organisations 
is publicly available. T his indicator has been 
evaluated as Covered. 

C.1.1.4 The Scheme shall 
make summaries (or full 
reports) with relevant 
findings from audits 
available on the internet. 

https://info.fsc.org/ 

Findings 

Covered 

FSC-STD-20-001 V4-0 General requirements for FSC 
accredited certification bodies 

Reporting 

4.3.21 The certification body shall document the findings 
and conclusions of all audit activities prior to review and 

Summaries of FM evaluations with relevant 
findings are required and are available on the 
FSC certificate database. Information in 
relation to the content and language of the 
public summary is governed by FSC-STD-20-
007b. This is also required for FM CW 

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decision making in a certification report in conformity with 
the report writing requirements specified in: 

certificates (FSC-STD-20-012, Clause 10.13.1).  

No public summary report (other than basic 
data in relation to the certification scope) is 
required for COC certificates. However, in the 
case of FSC Controlled Wood certification 
according to FSC-STD-40-005, summaries of 
basic information with relevant Certification 
Body findings are required and are available on 
the FSC certificate database. Information in 
relation to the content and language of the 
public summary is governed by FSC-STD-20-
011. 

Justification 

Scheme requirements ensure that summaries 
with relevant findings from audits are available 
on the internet via an up-to-date register of 
certified/verified organisations. T his indicator 
has been evaluated as Covered. 

a) FSC-STD-20-007a for forest management certification 
reports; 

b) FSC-STD-20-007b for forest management public 
summary certification reports; 

c) FSC-STD-20-011 for chain of custody certification 
reports; 

d) FSC-STD-20-012 for controlled wood forest 
management certification reports. 

4.6.1 The certification body shall register the certification 
status in the FSC certification database (info.fsc.org) after 
the certification decision making entity has granted 
certification. The registration requires the entry of all 
specified data, together with an electronic copy of the 
public summary certification report (as applicable). 
4.6.3 Certification bodies are responsible for keeping their 
data entries and public summary certification reports 
accurate and up-to-date. 
4.6.4 A certificate shall only be issued after a positive 
certification decision has been taken by the certification 
decision making entity and after it has been registered in 
the FSC certification database, together with the public 
summary certification report. 

FSC-STD-20-007b Forest management evaluations 
addendum – Forest certification public summary reports 

1 General requirements 
1.1 The certification body shall prepare a forest 
certification public summary report for each forest 
management enterprise or group entity to which a 
certificate is issued in accordance to the requirements 
specified in this standard. 
NOTE: If the main evaluation report meets the content 
requirements for the public summary report and the main 

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evaluation report is publicly available in accordance to the 
requirements of this standard for language and public 
availability, then there is no requirement to prepare an 
additional, separate, public summary. 

2 Language(s) 2.1 Public certification summaries shall be 
made available in: a) one of the official languages of FSC 
for certificates that cover a total forest area of more than 
1,000 ha in the scope1, and 
b) at least one of the official language(s) of the country in 
which the certified forest management unit is located, or 
the most widely spoken language of the indigenous people 
in the area in which the certified forest management unit is 
located. 
NOTE: FSC reserves  the right to request a translation of 
any forest certification public summary report into one of 
the official languages of FSC, at the expense of the 
certification body. 

3 Public availability  
3.1 The forest certification public summary report 
(including translations as required) shall be published on 
the FSC database of registered certificates (www.fsc-
info.org) before a certificate is issued or re-issued. 
3.2 Annual updates (see Section 8, below) shall be added 
to the published summary report or published separately 
on the FSC database of registered certificates (www.fsc-
info.org), no later than ninety (90) days after the on-site 
closing meeting at the end of a surveillance evaluation. 

4 Units 
4.1 Data presented in the reports should be in metric 
system units. If nonmetric system units are used the report 
shall provide conversion rates together with any 
assumptions made in order to make conversion into metric 
units possible. 

5 Title page 
5.1 The title page of the public summary report shall 
clearly identify: 
a) The name and contact details of the certification body, 

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including contact person and website address 
b) The date (format: day/ month/ year) the public summary 
was  last updated 
c) The name and contact details of the certificate holder2 
and contact person 
d) The name and/or location of the certified forest area(s)3 
e) The FSC certificate registration code 
f) The dates of issue and expiry of the certificate 
g) The sequential information on the evaluation results 
presented in the report (e.g. “main evaluation”, “2nd 
surveillance”, “3rd surveillance”). 

6 Certificate registration information4 
6.1 The basic quantitative information for each certificate 
shall be entered or updated in the FSC database of 
registered certificates (www.fsc-info.org) at each 
evaluation as required by FSC. 

7 Content 
7.1 The report shall be short and concise and bring up the 
most important features and in the specific format outlined 
in this standard (as per Box 1 below). The report should be 
not more than 15-20 pages. 
7.2 SLIMFs 
The elements marked with an asterisk (*)  in the table are 
NOT required in the case of certificates issued to single 
SLIMF FMUs. 
7.3 Groups 
Forest certification public summary reports for group 
certificates shall include an up-to-date list of all non-
SLIMFs group members with name, contact details and 
the geographical location of their FMUs in the scope of the 
certificate, unless national legal restrictions do not allow 
publication of this kind of information (this needs to be 
specified in the public summary report). 

8 Updates 
8.1 An update of the public summary report shall be made 
publicly available on the FSC database of registered 
certificates (www.fsc-info.org) within ninety (90) days after 
the last field day of each surveillance evaluation. Updates 

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should be in the form of additional pages published 
separately or added to the original public summary. 
8.2 Updates shall include at least the following information: 
a) the date of the surveillance evaluation and a brief 
summary of the sites inspected; 
b) a description of any significant changes in the 
management and/or harvesting methods; 
c) quantitative data on the use of pesticides (names and 
quantities of pesticides applied, size of area treated since 
last audit); 
d) a description of the actions taken by the certificate 
holder to correct any non- conformities identified at 
previous evaluations or subsequently; 
e) the certification body’s conclusions as to whether the 
actions taken constitute full conformity with the 
requirements of the relevant elements of the applicable 
Forest Stewardship Standard and, if not, whether the 
remaining non- conformities is considered a ‘minor’ or 
‘major’ non-conformity; 
f) description of any further non-conformities identified as a 
results of the surveillance audit;` 
g) updated presentation of stakeholder comments as 
required in Clause 4.1.3 (Box 1, above); 
h) updated list of members in a group certificate (see 
Clause 7.3 above) 
i) statement of new conditions (requirement to correct all 
identified non-conformities); 
j) the updated certification decision. 

Box 1 
1 Description of forest management 
1.1* A description of the forest, land use history and 
regional context 
1.2 A general description of the management system (e.g., 
uneven-aged management, even-aged management, 
rotation length, silvicultural prescriptions); 
1.3 A summary of the management plan, including a 
description of: 
1.3.1 the management objectives; 
1.3.2 the forest resources (land use and ownership status, 
socio-economic conditions, forest composition, profile of 

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adjacent lands); 
1.3.3 Geographical location of the non-SLIMFs FMU(s) in 
the scope of the certificate: 
i) Latitude E/W ### degrees ## minutes 
ii) Longitude N/S ### degrees ## minutes 
NOTE: the coordinates should refer to the center of a 
FMU. 
1.3.4 the management structures (e.g. management 
structure, division of responsibilities, use of contractors, 
provision of training, etc). implemented by the certificate 
holder; 
1.3.5 the silvicultural and/or other management systems 
being implemented (incl. harvesting techniques and 
equipment, rationale for species selection); 
1.3.6 the environmental safeguards; 
1.3.7 the management strategy for the identification and 
protection of rare, threatened and endangered species; 
1.3.8 the certificate holder's procedures for monitoring 
growth, yield and forest dynamics (incl. changes in flora 
and fauna), environmental and social impacts, and costs, 
productivity, and efficiency; 
1.3.9 summarized quantitative data on the use of 
pesticides (names and quantities of pesticides applied, 
size of area treated annually). 
1.4 A description of any area of forest which the certificate 
holder has chosen to exclude from the scope of the 
certificate together with an explanation of the reason for its 
exclusion and description of the controls that are in place 
to ensure that there is no risk  of confusion being 
generated as to which activities or products are certified, 
and which are not. 
2 Standard(s) 
2.1 Reference to the standards used (e.g. locally adapted 
certification body generic standard, FSC-accredited 
national standard; FSC-STD-30-005 Group forest 
certification: requirements for group managers) including 
the version number and date of finalisation. 
NOTE: The summary report shall include a statement 
and/or link to the website(s) where the standard(s) used 
can be downloaded or requested. 
2.2* A description of the process of local adaptation of the 

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standard, if applicable. 
3 The evaluation process 
3.1 The evaluation dates: (specify actual dates or month, 
year and duration); 
3.2* A general description of the evaluation including, if 
applicable, pre-evaluation visits. The description should 
give an overview of what was audited, audit methods and 
time allocation when significant; 
3.3* A general description of the consultation process with 
stakeholders. 
4 Observations 
4.1 A general presentation of the observations on which 
the certification decision is based, including: 
4.1.1 a list of main strengths and weaknesses with respect 
to the overall conformity with the Forest Stewardship 
Standard used for the evaluation; 
4.1.2* a summarized presentation of findings with clear 
information to enable the reader to make an easy 
correlation between the requirements of each of the 
criteria of the Forest Stewardship Standard used and the 
performance of the certified operation; 
4.1.3* Clear and systematic presentation of the comments 
received from stakeholders (who are not members of the 
enterprise under evaluation) before, during or after the 
evaluation, and the corresponding follow-up action and 
conclusions from the certification body; 
NOTE: similar stakeholder comments may be grouped by 
issues. 
4.1.4* a description of any preconditions that had been 
issued, and the actions taken by the certificate holder to 
close out those preconditions prior to the issue of the 
certificate. 
5 Certification decision 
5.1 A clear statement that the forest has been certified by 
the certification body as meeting the requirements of the 
specified standard, the date of certification, and the expiry 
date of the certificate. 
5.2 A list of all non-conformities that the managers are 
required to correct in order to maintain their certification, 
including the time course within which corrective actions 
shall be taken. 

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ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

FSC-STD-20-011 Chain of Custody Evaluations 

12 Public certification summaries for evaluations of 
controlled wood according to FSC-STD-40-005 
12.1 The certification body shall publish a certification 
summary for the controlled wood evaluation on the FSC 
database upon registration of the certification status. 
NOTE 1: The inclusion of confidential information is not 
required. 
NOTE 2: The certification summary should be short and 
concise. 
12.2 The certification summary shall include at minimum: 
a) the contents of the evaluation report relevant to the 
evaluation of controlled wood (see Table B, Item 7); 
b) a list of all nonconformities that the organization is 
required to correct in order to maintain its certification, 
including the time period within which corrective actions 
shall be made. 
12.3 When the certification body approves a new or 
updated risk assessment  conducted by the organization, 
the certification summary shall be updated with the risk 
assessment  within seven business days of approval. 
12.4 The certification summary shall be made available in:  
a) English or Spanish for certificates that cover a total 
supply area of more than 50,000 ha in the scope; and 
b) at least one of the official languages of the country in 
which the supply area is located, or the most widely 
spoken language of the indigenous people in the supply 
area, where material is sourced from specified or 
unspecified risk areas. 
NOTE: FSC and ASI reserve the right to request a 
translation of any certification summary into one of the 
official languages of FSC, at the expense of the 
certification body. 
12.5 In the case of surveillance evaluations, the public 
certification summary shall include at least the following 
information: 
a) the date of the surveillance evaluation; 
b) a description of any significant changes in the DDS; 
c) a description of the actions taken by the organization to 

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correct any nonconformities identified during previous 
evaluations; 
d) the certification body’s conclusions as to whether the 
actions taken result in conformity to the applicable 
requirements, and if not, whether the remaining 
nonconformities are considered minor or major 
nonconformities; 
e) a description of any further nonconformities identified as 
a result of the surveillance evaluation and conditions to 
correct all identified nonconformities; 
f) the updated certification decision. 
FSC-STD-20-012 V1-0 Standard for evaluation of FSC 
Controlled Wood in Forest Management Enterprises 
“10.13.1 The certification body shall make available a 
public summary in relation to compliance with the FSC 
Controlled Wood standard for forest management 
enterprises.” 

C.1.2 

Impartiality 

C.1.2.1 Procedures for 
handling complaints and 
grievances shall be in 
place, made publicly 
available and implemented. 
The procedures shall be 
clearly publicized, making it 
easy for stakeholders to 
submit comments or 
complaints where 
applicable. 

https://fsc.org/en/complaints  

Findings 

Covered 

FSC-PRO-01-008 V2-0 Processing Complaints in the FSC 
Certification Scheme 

FSC’s  Complaints webpage hosts two 
documents:  

FSC-PRO-01-005 V3-0 Processing Appeals 

FSC-PRO-01-009 V3-0 Processing Policy for Association 
Complaints in the FSC Certification Scheme 

 

 

‘Processing Complaints In The FSC 
Certification Scheme’ (FSC-PRO-01-
008) for complaints regarding the 
FSC normative framework or the 
performance of FSC International, 
the FSC Network  as well as 
complaints regarding the 
performance of ASI; and  
‘Processing Appeals’ (FSC-PRO-01-
009) setting out the process for 
receiving, evaluating and deciding on 
appeals against decisions taken by 
FSC (not including accreditation 
decisions). 

The webpage also includes a visible direct link 
to feedback form to people to submit 
complaints.  

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Section 2 of FSC-PRO-01-008 sets out which 
procedure shall be followed under which 
circumstance, whilst Annex 2 gives a Dispute 
Resolution Map to aid the reader. There is a 
third FSC procedure (FSC-PRO-01-009) for 
handling complaints with regard to the Policy 
for Association of Organizations with FSC 
(FSC-POL-01-004) which is not linked to 
directly from the complaints page but is easily 
found in the Document Centre. 

FSC-PRO-01-008 also points that ASI’s 
procedure ASI-PRO-20-104 shall be followed 
for complaints against the actions of 
Certification Bodies (Clause 2.4) and 
Complaints against Certificate Holders shall be 
dealt with by the Certification Body who issued 
the certificate and processed according to the 
Certification Body’s own complaint procedure 
(Clause 2.3). 

All procedures include mechanisms for: 

 
 

 

 

 

 

Acknowledging receipt of complaints; 
Informing stakeholders of the complaint 
procedure, and providing an initial 
response to complainants within ten (10) 
days; 
Conducting a preliminary assessment to 
determine whether evidence provided in a 
complaint is or is not substantial; 

Dialogue with complainants that aims to 
solve complaints assessed  as substantial 
before further actions are taken; 
Providing information on the steps to be 
taken by the Scheme/CB in order to 
resolve the complaint, as well as how a 
precautionary approach will be used, shall 
be included with the complaint; 
Implementing a process (e.g. field 
verification and/or desk verification) to 

680 

 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

verify a complaint assessed as substantial 
by the Scheme or CB, within two (2) 
months of its receipt; 
Determining the corrective action to be 
taken and the means to enforce its 
implementation, if a complaint has been 
assessed  and verified as substantial;  
Verifying whether corrective action has 
been taken and whether it is effective; 
Informing the complainant, the 
Certification body, or other stakeholders, 
as necessary; 

Recording and filing all complaints 
received and actions taken. 

 

 

 

 

Justification 

This indicator has been evaluated as Covered. 
Procedures for handling complaints and 
grievances are in place, made publicly 
available and implemented. The procedures 
are clearly publicized, making it easy for 
stakeholders to submit comments or 
complaints where applicable. 

C1.3 

Conflict of 
interest and 
corruption 

C.1.3.1 The Certification 
Scheme shall have in place 
requirements at all levels of 
the scheme (normative 
requirements for CHs, 
requirements for CBs, and 
for the scheme functioning) 
to manage risks of 

FSC-STD-01-001 V5-2 / FSC-STD-60-004 V2-0 

Findings 

Partially Covered 

1.7: ““The Organization* shall* publicize a commitment not 
to offer or receive bribes in money or any other form of 
corruption, and shall* comply with anti-corruption 
legislation where this exists. In the absence of 
anticorruption legislation, The Organization* shall* 
implement other anticorruption measures proportionate to 
the scale* and intensi ty* of management activities and the 

Normative requirements for Certificate Holders 
addressing corruption are clear at the forest 
management level. For CoC Certificate Holders 
Commitment to FSC’s Policy for Association 
(FSC-POL-01-004) addresses corruption 
related to illegal harvesting (see A.4.1.2). The 

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ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

corruption and conflict of 
interest. 

risk*  of corruption.” 

FSC-STD-60-004 V2-0 

1.7 Instructions for Standard Developers:  

“This Criterion* recognizes that corruption is generally 
regarded as illegal but that not all countries have or 
implement anti-corruption laws and regulations. 

Where anti-corruption laws and regulations are ineffective 
or do not exist, Standard Developers shall* include other 
anti-corruption measures that may include for example, 
The Organization* develops or participates in formal 
integrity pacts with other organizations in the public and 
private sectors, such that each participant agrees in well 
publicized statements not to engage in corruption by 
offering or receiving bribes, whether in money or in any 
other forms (Indicator 1.7.4). 

An independent third party with expertise in such matters 
should then monitor* performance related to such 
statements.” 

“1.7.4  Bribery, coercion and other acts of corruption do not 
occur.” 

FSC-STD-30-010 V2-0 

report ‘FSC and Corruption’ (2017) states that 
“the Policy for Association has a 
communications value perspective as intention 
to ban corruption in an organization associated 
with FSC” but is unclear how this would be 
effective where corruption is unrelated to illegal 
logging.  

There is an ongoing revision process for the 
Policy for Association.  

This requirement is covered by clauses 1.5.12 
and 3.1.9 within FSC-STD-20-001 V4-0 
(General requirements for FSC accredited 
certification bodies) for Certification Bodies. 

FSC`s  Code of Conduct is applicable to FSC 
International members (which includes the 
Board of Directors), external staff and 
consultants. It addresses bribery and conflicts 
of interest and is available on their website. 

“Intent box: The Forest Management Enterprise shall provide  
evidence that legal procedures have been follo we d t o  g a in  
permits and licenses.”  

Justification 

The normative requirements applicable to 
supply-chain certificate holders do not fully 
cover this indicator that the scheme has in 
place requirements at all levels of the scheme 
to manage risks of corruption and conflict of 
interest. This indicator has been evaluated as 
Partially Covered.  

“3.1.  All  harvesting shall take place in compliance with all 
laws applicable to harvesting in the jurisdiction in accordance 
with the criteria outlined in table 1.” 

“4.2. No conflicts relating to land tenure or land use ri g h t s o f  
traditional  or  indigenous peoples groups exist in the FMUs 
under control of the Forest Management Enterprise for which  
a resolution process has not been agreed by the main parties 
to the dispute (see section 4.4 below).”  

FSC-ADV-30-010 V1-0 DATED 10 JULY 2014 

FSC-STD-20-001  V4-0  General  requirements  for  FSC 
accredited certification bodies 

“1.5.12  The  certification  body  shall  have,  maintain  and 
implement a documented anti-corruption policy.” 

“3.1.9 The certification body shall require personnel invol ved  

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ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

in  the  certification  process  to  sign  a  contract  or  other 
documents by which they commit themselves to the following, 
in accordance with the requi rements of Annex 1: 

a) to conform with the rules defined by the certification bod y,  
including those relating to confidentiality, anti-corruption a n d  
independence from commercial and other interests; 

b)  to  declare  any  prior  and/or  present  association on the ir 
own part, or on the part of their employer, with: 

i. a supplier or designer of products, or 

ii. provider or developer of services, or 

iii. an operator or developer of processes to the evaluation o r 
certification of which they are to be assigned. 

c)  to  reveal  any  situation  known  to  them that may present 
them or the certification body with a conflict of interest.” 

FSC & Corruption 2017 V1-1 

FSC Code of conduct – February 2019 

https://fsc.org/en/current-processes/policy-for-the-
association-of-organizations-with-fsc-pfa  

C.2 Scheme & standard scope 

Note: section C2 is not specifically referring to EUTR issues but has been included as part of the evaluation of schemes to u nderstand scheme structures. 
C.2.1 

Findings 

FSC-STD-01-001-V5-2 FSC Principles and Criteria (P&C) 
for Forest  Stewardship 

Partially Covered 

Standard 
adaptation to 
the national or 
subnational 
context 

C.2.1.1 International 
standards shall be adapted 
to the national or 
subnational context in 
which they are being 
implemented and contain a 
list of applicable legislation, 
or the Scheme shall 
enable/require detailed 
evaluation of applicable 
legislation in a national 
context. 

FSC-STD-60-002 V1-0 Structure and Content of National 
Forest Stewardship Standards 

FSC-PRO-60-006 V2-0 Development and Transfer of 
National Forest Stewardship Standards to the FSC 
Principles and Criteria Version 5-1 

FSC-STD-60-004 V2-0 International Generic Indicators 

FSC-STD-40-004 V3-0 Chain of Custody Certification 
“6.1 The organization shall ensure that its FSC-certified 
products conform to all applicable timber legality 
legislation. At a minimum, the organization shall: 
a. have procedures in place to ensure the import and/or 
export of FSC certified products by the organization 

FSC-PRO-60-006 V2-0 details the procedure 
that must be followed for either developing new 
National Forest Stewardship Standards (NFSS) 
or transferring existing NFSS to meet the 
updated Principles and Criteria of Version five 
of FSC-STD-01-001. It also sets out how the 
International Generic Indicators (IGI) of FSC-
STD-60-004. are to be used as a starting point 
in the process.  

All NFSSs shall conform with FSC-STD-60-002 
V1-0 which specifies the structure and content 
of the NFSS. 

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ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

conform to all applicable trade and customs laws1 (if the 
organization exports and/or imports FSC products);” 

FSC-STD-30-010 V2-0 FSC Controlled Wood Standard for 
Forest Management Enterprises 

“3.1. All harvesting shall take place in compliance with all 
laws applicable to harvesting in the jurisdiction in 
accordance with the criteria outlined in table 1.” 

ADVICE-30-010-01 Applicable National and Local Laws 
and Regulations for Controlled Wood for Forest 
Management Enterprises 

“1. From March 01 2013, Companies shall use a list of 
applicable 
legislation and any legally required verifiers, such as 
licences or 
permits, supplied by their Certification Body. 
2. This list of applicable legislation refines FSC-STD-30-
010 Section 3 Table 1, and is based on the minimum list 
below.” 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood 
“3.1 The organization shall use the applicable FSC risk 
assessment  to determine the risk related to the origin of 
the material for each controlled wood category. 
3.1.1 The organization may use an FSC risk  assessment 
under development, including: 
a) Approved risk assessment  for controlled wood 
categories of a 
centralized national risk assessment,  and/or, 
b) Draft risk  assessment  for controlled wood categories 
developed under a national risk assessment  process  when 
agreed by national consensus (according to the 
information provided on the FSC website). 
3.1.2 For the organization that wants to demonstrate 
compliance with EUTR requirements through conformance 
with this standard, the assessment for category 1 in the 
‘old NRA’ shall be replaced by a draft FSC risk 
assessment  for category 1 developed according to FSC-
PRO-60-002 V3-0.” 

Principle 1 of the updated International 
Standard requires a list of applicable legislation 
to be developed in the NFSS. 

According to the effective date within FSC-
STD-60-004 V2-0 all NFSSs should have been 
updated to incorporate all new or revised IGI by 
01 July 2020. However, not all the NFSSs 
sampled had been updated by the time of 
writing. FSC states on the individual NFSS 
webpages that “Revisions of Forest 
Stewardship Standards are ongoing, and all 
existing standards will be transferred to the 
revised Principles & Criteria version 5-2. All 
standards are valid until replaced by a new 
Forest Stewardship Standard” but no 
information is shared publicly about  when this 
will happen or what the status of the overall 
progress  is. When asked,  FSC provided a 
spreadsheet showing which standards had 
been transferred and which haven’t. Out of 78 
national standards the transfer process is still 
ongoing for approximately 40. Regarding the 
transfer progress they stated:  

“There is an approved timeline for each of the 
ongoing processes. The currently ongoing 
processes are planned to be submitted to PSU 
in 2021 (including the tw o standards for Brazil), 
two of them in the second half and the rest in 
the first half.    

All standards have to be transferred. The 
reasons for not having a transfer process in 
place in some countries are diverse. There are 
countries where the process started and was 
cancelled or put on hold due to political 
instability (e.g. DRC or Venezuela, both without 
CHs), lack of resources, etc.  

In most  of these countries there are no CHs or 

684 

 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

there are very few. The certified area under 
standards that are not being transferred is less 
than a 0,5% of the total certified area.” 

FSC Controlled Wood Standard for Forest 
Management Enterprises is a global standard, 
however, normative Advice Note FSC-ADVICE-
30-010-01 effectively adapts it to national or 
subnational context. 

The CoC standard is a global standard and is 
not adapted to national or subnational context. 
There is no requirement, nor provision, for a list 
of applicable legislation at the national level.  

There is no requirement in the CoC standard 
that requires the Certificate Holder to 
demonstrate legal compliance with the 
exception of requirement 6.1 in relation to 
import and export. A footnote to this 
requirement only guides to the types of laws 
that could be included, no definitive list is 
prepared by FSC, nor is required from the 
Certificate Holder. 

The Requirements for Sourcing Controlled 
Wood are adapted via the National ‘FSC Risk 
Assessments’  required to be used in the DDS. 
Risk  assessments  are developed at the 
national level based on the international 
standards: Raise FSC-PRO-60-002 and FSC-
PRO-60-002a. FSC-PRO-60-002b provides a 
list of all approved risk assess. 

Justification 

This indicator has been evaluated as Partially 
Covered, due the delays in updating all 
National Forest Stewardship Standards (NFSS) 

685 

 
 
C.2.2 

International 
conventions 
and treaties 

C.2.2.1 The Scheme shall 
include a list of the relevant 
international conventions to 
which the country has 
ratified, and which hold 
legal force in the country. 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

to meet the updated Principles and Criteria 
(FSC-STD-01-001 V5). 

Findings 

Covered 

It is required that all National Forest 
Stewardship Standards contain a list of the 
relevant international conventions to which the 
country is signatory, and which hold legal force 
in the country. 

The CoC standard references the ILO Core 
Conventions, which are the only applicable 
conventions for supply chain entities. 
Additionally, during the development of this 
report, FSC published a new version of the 
CoC standard, Version 3-1, which introduces 
the new 'FSC core labour requirements' based 
on the ILO core conventions (Section 7).  

Within the CW system this requirement is met 
by FSC-ADVICE-30-010-01 and the FSC Risk 
Assessments.   

Justification 

This indicator has been evaluated as Covered.  

FSC-STD-60-002 V1-0 Structure and Content of National 
Forest Stewardship Standards 
Principle 1, Annex A 

“Standard Developers shall complete a list of all applicable 
laws, obligatory codes of practice and legal and customary 
rights at the national and, where applicable, subnational 
level as outlined in Annex A. This list shall be included in 
the National Standard or the Interim National Standard.” 

FSC-STD-40-004 V3-0 Chain of Custody Certification 
“1.3 The organization shall commit to the FSC values as 
defined in FSC-POL-01-004 by signing a self-declaration 
that the organization is not directly or indirectly involved in 
the following activities:  
… 
violation of any of the ILO Core Conventions, as defined in 
the ILO Declaration on Fundamental Principles and Rights 
at Work,  1998.” 

FSC-STD-40-004 V3-1 Chain of Custody Certification 
Standard 
“7 FSC core labour requirements3 
7.1 In the application of the FSC core labour requirements, 
the organization shall give due consideration to the rights 
and obligations established by national law, while at the 
same time fulfilling the objectives of the requirements. 
7.2 The organization shall not use child labour. 
7.2.1 The organization shall not employ workers below the 
age of 15, or below the minimum age as stated under 
national, or local laws or regulations, whichever age is 
higher, except as specified in 7.2.2. 
7.2.2 In countries where the national law or regulations 
permit the employment of persons between the ages of 13 
to 15 years in light work, such employment should not 
interfere with schooling nor be harmful to their health or 
development. Notably, where children are subject to 
compulsory education laws, they shall work only outside of 
school hours during normal day-time working hours. 
7.2.3 No person under the age of 18 is employed in 
hazardous or heavy work  except for the purpose of 
training within approved national laws and regulations. 
7.2.4 The organization shall prohibit the worst forms of 

686 

 
 
 
 
 
 
 
  
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

child labour. 
7.3 The organization shall eliminate all forms of forced and 
compulsory labour. 
7.3.1 Employment relationships are voluntary and based 
on mutual consent, without the threat of a penalty. 
7.3.2 There is no evidence of any practices indicative of 
forced or compulsory labour, including, but not limited to, 
the following: 
• physical and sexual violence 
• bonded labour 
• withholding of wages /including payment of employment 
fees and or payment of deposit to commence employment 
• restriction of mobility/movement 
• retention of passport and identity documents 
• threats of denunciation to the authorities. 
7.4 The organization shall ensure that there is no 
discrimination in employment and 
occupation. 
7.4.1 Employment and occupation practices are non-
discriminatory. 
7.5 The organization shall respect freedom of association 
and the effective right to 
collective bargaining. 
7.5.1 Workers  are able to establish or join worker 
organizations of their own 
choosing. 
7.5.2 The organization respects the full freedom of 
workers’  organizations to draw up their constitutions and 
rules. 
7.5.3 The organization respects the rights of workers  to 
engage in lawful activities related to forming, joining or 
assisting a workers’  organization, or to refrain from doing 
the same, and will not discriminate or punish workers for 
exercising these rights. 
7.5.4 The organization negotiates with lawfully established 
workers’  organizations and/ or duly selected 
representatives in good faith and with the best efforts to 
reach a collective bargaining agreement. 
7.5.5 Collective bargaining agreements are implemented 
where they exist.” 

FSC-STD-30-010 V2-0 FSC Controlled Wood Standard for 
Forest Management Enterprises 

“3.1. All harvesting shall take place in compliance with all 
laws applicable to harvesting in the jurisdiction in 
accordance with the criteria outlined in table 1.” 

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ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

ADVICE-30-010-01 Applicable National and Local Laws 
and Regulations for Controlled Wood for Forest 
Management Enterprises 

“1. From March 01 2013, Companies shall use a list of 
applicable 
legislation and any legally required verifiers, such as 
licences or 
permits, supplied by their Certification Body. 
2. This list of applicable legislation refines FSC-STD-30-
010 Section 3 Table 1, and is based on the minimum list 
below.” 

FSC-STD-40-005 V3-1 Requirements for Sourcing FSC 
Controlled Wood 
“3.1 The organization shall use the applicable FSC risk 
assessment  to determine the risk related to the origin of 
the material for each controlled wood category. 
3.1.1 The organization may use an FSC risk  assessment 
under development, including: 
a) Approved risk assessment  for controlled wood 
categories of a 
centralized national risk assessment,  and/or, 
b) Draft risk  assessment  for controlled wood categories 
developed under a national risk assessment  process  when 
agreed by national consensus (according to the 
information provided on the FSC website). 
3.1.2 For the organization that wants to demonstrate 
compliance with EUTR requirements through conformance 
with this standard, the assessment for category 1 in the 
‘old NRA’ shall be replaced by a draft FSC risk 
assessment  for category 1 developed according to FSC-
PRO-60-002 V3-0.” 
. 
FSC-STD-40-004 V3-0 Chain of Custody Certification 

Section B: Scope, Box 1. ‘To whom does FSC CoC 
certification apply?’ 

“12.4 The organization shall establish an outsourcing 
agreement with each non-FSC-certified contractor, 
specifying at minimum that the contractor shall: 
a. conform to all applicable certification requirements and 
the organization’s procedures related to the outsourced 

688 

Findings 

Covered 

The CoC standard makes it clear that the 
requirements are also applicable to the 
Certificate Holder’s contractors, except for 
limited circumstances which are 
unambiguously described. Where non-certified 
contractors are used the CoC standard 
requires an outsourcing agreement to be in 

C.2.3 

Use  of 
contractors 

C.2.3.1 The requirements 
for forest managers and 
supply chain entities shall 
be applicable to the 
organisation’s contractors 
and outsourcing facilities. 

 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

activity;” 

FSC-STD-01-001 V5-2 FSC Principles and Criteria for 
Forest Stewardship 
“3. Scope 
The Principles and Criteria cover all of The Organization’s 
management activities that are related to the Management 
Unit, whether within the Management Unit or outside; 
whether directly undertaken or contracted out.” 

“5. Responsibility for Compliance 
As a performance-based standard, the FSC Principles and 
Criteria are explicit about defining where responsibility lies. 
Responsibility for ensuring compliance with the FSC 
Principles and Criteria lies with the person(s) or entities 
that is/are the certificate applicant or holder. For the 
purpose of FSC certification these person(s) or entities are 
referred to as ‘The Organization’. The Organization is 
responsible for decisions, policies and management 
activities related to the Management Unit. The 
Organization is also responsible for demonstrating that 
other persons or entities that are permitted or contracted 
by The Organization to operate in, or for the benefit of the 
Management Unit, comply with the requirements of the 
FSC Principles and Criteria. Accordingly, The Organization 
is required to take corrective actions in the event of such 
persons or entities not being in compliance with the 
Principles and Criteria.” 

place, whereby the contractor agrees to comply 
with the applicable requirements.   

Sections 3 (Scope) and 5 (Responsibility for 
Compliance) of the International FM standard 
make it clear that the requirements are the 
responsibility of the Certificate Holders.   

Having recognised the significant role that 
contractors play FSC have been developing a 
system for incorporating contractors within the 
FSC system since 2017. As of November 2019, 
a standard for certifying contractors is being 
pilot tested.  

Justification 

This indicator has been evaluated as Covered.  

N/A 

Findings 

Not Applicable 

FSC does not recognise or endorse other 
schemes or systems.   

FSC-STD-20-001 General requirements for FSC accredited 
certification bodies 

Findings 

Covered 

Certification bodies are accredited by an 
independent accreditation body. FSC’s 
accreditation body is Assurance Services 

689 

C.2.4 

Endorsing and 
recognising of 
other Schemes 
and systems 

C.2.4.1 If the Scheme 
includes the recognition or 
endorsement of other 
schemes or systems,  it 
shall ensure coverage and 
consistent implementation 
of EUTR requirements at all 
levels. 

C.3 Accreditation and oversight 

C.3.1 

Accreditation 

C.3.1.1 The Scheme shall 
include a system for 
accreditation or oversight of 
Certification Bodies to ensure 
that CBs have in place the 

 
 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

required procedures, capacity 
and competencies. 

FSC-STD-20-007 Forest management evaluations 

FSC-STD-20-011 Chain of Custody Evaluations 

International (ASI). ASI is responsible for 
checking Certification Body compliance with 
FSC rules and procedures through a 
combination of field and office audits. 

C.3.1.2 The Scheme shall 
ensure that the requirements 
and process for accreditation 
is publicly available. 

C.3.1.3 The Scheme shall 
make publicly available, an up-
to-date list and details of all 
accredited Certification Bodies 

C.3.1.4 The Accreditation 
Body shall have mechanisms 
to ensure that relevant 
personnel are qualified and 
competent to evaluate 
Certification Body’s 
performance in relation to 

https://fsc.org/en/certification-body-accreditation  
https://fsc.org/en/integrity/accreditation  

Findings 

Covered 

Justification 

This indicator has been evaluated as Covered.  

The requirements and process for accreditation 
is available on FSC’s website.  

Justification 

This indicator has been evaluated as Covered. 

https://www.asi-assurance.org/s/find-a-cab  

Findings 

Covered 

A list of accredited Certification Bodies could 
not be found on FSC’s website but is available 
on ASI’s website via the ‘Find a CAB’ function. 

Justification 

This indicator has been evaluated as Covered. 

http://www.asi-
assurance.org/s/post/a1J1H000002Jea3UAC/p0164  

Findings 

Covered 

ASI has established internal procedures 
describing the qualification, experience and 
competence requirements of ASI staff and 
contractors. These documents also describe 
the processes  for recruitment, initial training, 
mentoring, ongoing training and ongoing 

690 

 
 
 
 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

Scheme requirements. 

C.3.2 

Oversight 
mechanism 

C.3.2.1 The Scheme shall 
ensure that the 
competence and consistent 
performance of Certification 
Bodies is regularly 
evaluated.  

Performance shall employ 
both desk-based AND field 
approaches, including: 
i) Stakeholder consultation 
ii) In-field evaluation of the 
performance of the 
Certification Body, whether 

ASI Accreditation Procedure: ASI-PRO-20-101-
Accreditation-V5.1  
“14.2 Upon receipt of the completed checklists and 
documentation, ASI shall conduct three types of 
Assessments,  in the sequence specified below: 
1) Desk  Review of the CAB application and documentation 
… 
2) Office Assessment(s)  (Head Office (HO) and Affiliate 
Office (AO)) 
… 
3) Witness Assessment(s)  for each Scope of 
Accreditation.” 

“17.1 To ensure that an accredited CAB continues to 

691 

performance monitoring through self-evaluation 
and peer monitoring. Additionally, ASI 
maintains a Quality Management System 
document that contains competence criteria of 
different assessment scopes  per accredited 
program.  

FSC provided this study with the following 
information: 

FSC has a service and License agreement with 
ASI in place which includes a set of Key 
Performance Indicators (KPIs) that ASI reports 
against on a regular basis. One of the KPIs is 
that "All ASI assessors  meet FSC Auditor 
requirements". In practice, ASI assessors  take 
the same trainings on the FSC normative 
documents as Certification Bodies' auditor do, 
which ensures they have in-depth knowledge of 
the FSC normative framework. 

Justification 

This indicator has been evaluated as Covered. 

Findings 

Covered 

ASI ensures the competence and consistent 
performance of Certification Bodies at initial 
assessments  and annual audits (Clauses 14.2 
and 17.1). ASI’s accreditation procedure 
includes requirements for desk and field audits 
(Clauses 14.2 and 17.4). There is also 
provision for extra and unannounced audits, 
when deemed necessary (Clauses 17.8 and 
17.9).  

ASI publishes announcements to stakeholders 
of annual audits for accredited Certification 

 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

via on-site inspections of 
certified forests/ supply 
chain entities or witness 
audits of audit personnel. 

operate in compliance with the Accreditation 
Requirements, ASI monitors and evaluates the CAB’s 
competence and Conformity throughout the five-year 
Accreditation Cycle via surveillance Assessments.. 
.” 

Bodies. There is no requirement for this to be 
done at the initial assessment, although it is fair 
that – as CBs  have no activity or record of 
performance – it is unlikely stakeholder 
feedback will be received. 

Clause 17.7 of ASI’s Accreditation Procedure 
states that ASI conducts stakeholder 
consultation “for some Assessment types” but it 
does not state which assessment types. Clause 
7.2 of ASI’s Procedure for Witness and 
Compliance Assessments states that “ASI may 
request stakeholders to submit comments” but 
it is not required.  

Justification 

This indicator has been evaluated as Covered. 
While stakeholder consultation in relation to the 
initial assessment of Certification Bodies for 
accreditation purposes is not required this is 
considered as acceptable. 

“17.4 Annual surveillance includes: 
1) Assessment  of HO and a sample of AOs; 
2) Witness and/or Compliance Assessment(s); 
3) Any other Assessments  such as  Desk  Review, incident 
follow-up and NC verification as considered necessary by 
ASI to confirm that the CAB is operating in accordance 
with the Accreditation Requirements.” 

“17.7 ASI publishes announcements of surveillance 
Assessments  for accredited CABs on its website and 
carries out Stakeholder consultation for some Assessment 
types. If Stakeholder comments are received, they are 
considered by ASI during the Assessment and responded 
to in the Assessment  Report while ensuring Stakeholder 
confidentiality.” 

“17.8 ASI may conduct Extra Assessments in addition to 
the ASI surveillance Assessment program to investigate 
Incidents and/or Complaints or the outcome of an earlier 
Assessment  or under other circumstances as deemed 
necessary by ASI.” 

“17.9 ASI may conduct Unannounced Assessments as 
part of or outside of its surveillance Assessment program 
in order to address heightened risk or allegations of 
serious violations or negligence of Accreditation 
Requirements.” 

Procedure for Witness and Compliance Assessments: 
ASI-PRO-20-111-Witness & Compliance Assessments-
V2.1 
7.2 Prior to any assessment,  ASI may request 
stakeholders to submit comments about the CAB and the 
CH and may inform them about the assessment date, type 
and location as mandated by SO requirements or at the 

692 

 
 
 
 
 
 
 
 
 
 
 
  
 
C.3.2.2 The Scheme shall 
include requirements that 
ensure that the oversight 
mechanism applies a clear 
basis for:  
i) establishing 
conformance;  
ii) raising corrective actions 
for non-conformance, and 
ensuring closure within 
timeframes to avoid legal 
non-compliance, and;  
iii) certification issue (or 
maintenance) decision 
making. 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

discretion of ASI. 

ASI Findings: ASI-PRO-20-106-ASI Findings-V6.1 

Findings 

Partially Covered 

“6.1 ASI findings may be identified during Assessments 
(irrespective of the scope evaluated) or as a result of other 
sources  of information (for example Complaint, Integrity 
and Traceability investigations).” 

i) The basis for establishing conformance is not 
detailed, however, Clause 7.2 of ASI’s Findings 
procedure (ASI-PRO-20-106) notes that 
objective evidence shall be recorded. 

“6.2 ASI findings shall be raised if objective evidence of 
Conformity with an Accreditation Requirement is not 
provided by the CAB when requested.” 

“7.2 For each NC, the following information shall be 
recorded in the SOF: 
7.2.1 The specific Accreditation Requirement that the CAB 
was  not able to demonstrate conformity with. 
7.2.2 An informative subject that refers directly to the i ssue 
in question. 
7.2.3 Proposed grading of the finding. 
7.2.4 Description of how the CAB has failed to 
demonstrate Conformity with the Accreditation 
Requirement cited. 
7.2.5 Objective Evidence that demonstrates how the CAB 
was  not able to demonstrate Conformity with the 
Accreditation Requirement (including a grading 
justification in the case of Major NCs). 
7.2.6 Timelines within which the CAB must address the 
NC.” 

“11.2 The default timeline within which ASI NCs must be 
addressed and closed shall be 3 months for Major NCs 
and 12 months for Minor NCs from the date the final 
Assessment  Report is shared with the CAB.” 

ASI Accreditation Procedure: ASI-PRO-20-101-
Accreditation-V5.1 
“10.1 Accreditation Decisions (decisions Granting, 
renewing, Extending and Reducing technical Scope, 
Suspending and/or Withdrawing Accreditation for all or 

ii) ASI has a clear procedure for communicating 
findings with Certification Bodies (ASI-PRO-20-
106). This includes audit findings and findings 
from other sources, such as ‘Complaint, 
Integrity and Traceability’ investigations. 
Section 11 details the timelines associated with 
corrective actions: CBs normally have three 
months for addressing Major nonconformities 
and 12 months for Minors (Clause 11.2).  

Certification bodies shall define a timeframe 
(up to 3 months for major non-conformities and 
up to the next audit for minor non-conformities) 
in the case of initial assessments (minor non-
conformities only) and surveillance audits 
(minor and major non-conformities). There is a 
potential risk that a non-conformity may 
represent an infringement of legislation and 
that, as a result, illegal wood may enter the EU 
market without mitigation measures to prevent 
this from occurring for a period of up to 3 or 12 
months. 

iii) Section 10 of ASI’s Accreditation Procedure 
(ASI-PRO-20-101) covers ‘Accreditation 
Decisions’, setting out the process by which an 
Accreditation Committee (Clause 10.1) bases 
their decision on an Accreditation Report 
prepared by ASI (Clause 10.2). To gain 
accreditation a Certification Body must comply 
with all relevant requirements and any 

693 

 
 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

part of the requested Scope) are made by the ASI 
Accreditation Committee (AC) unless otherwise specified 
in this Accreditation Procedure. When making an 
Accreditation Decision, the AC acts as a representative of 
ASI, and the decision is consequently attributed to ASI. No 
legal or contractual relationship is established between the 
AC (or any subset thereof) and a CAB. The AC shall have 
access  to all Assessment Reports and Nonconformities 
(NCs)  issued, including ASI and CAB responses to these.” 

“10.2 An Accreditation Decision made by the AC is based 
on an Accreditation Report prepared by ASI for the AC. 
The Accreditation Report may include a recommendation 
on how to decide, but any such recommendation is non-
binding for the AC. The decision-making process starts 
with the preparation of the Accreditation Report.” 

“15.1 If, after the completion of the initial Accreditation 
Assessments,  ASI concludes that the CAB’s Certification 
system meets all Accreditation Requirements, including 
closure of all major NCs, ASI prepares an Accreditation 
Report for the AC, recommending initial Accreditation.” 

“21.1 If a CAB fails to comply with the Accreditation 
Requirements or is/has been in breach of the terms of the 
ASI Service Agreement, ASI can impose Sanctions on the 
CAB. ASI further reserves  the right to exercise any rights 
provided by the law or by the Service Agreement or any 
other agreement concluded with the CAB.” 

“22.6 For each Suspension decision (except for non-
payment of fees - see section 24), ASI shall prepare an 
Accreditation Report for the AC explaining the reasons 
leading to Suspension, a justification of the scope 
(technical and/or geographical) proposed for Suspension, 
the conditions for lifting the Suspension and any other 
relevant information considered material for the 
recommendation.” 

identified nonconformities shall be closed 
(Clause 15.2). Regarding maintenance of 
accreditation: Section 21 covers ‘Sanctions’, 
which are issued for noncompliance and 
breach of contract (Clause 21.1). A table is 
included (Table 1) giving examples of situations 
leading to Sanctions, of which two refer to 
corrective actions. Suspension and withdrawal 
decisions are also made by the Accreditation 
Committee based on recommendations made 
in ASI reports (Clauses  10.1, 10.2, 22.6 and 
23.2). 

The General Requirements for FSC Accredited 
Certification Bodies (FSC-STD-20-001 V4-0) 
includes requirements for the grading of non-
conformities as minor and major (Clause 
4.3.13), which, in relation to the Certification 
Bodies evaluating CoC Certificate Holders due 
diligence systems under the Sourcing of 
Controlled Wood (FSC-STD-40-005), align with 
the description of negligible and non-negligible 
risk  in the EUTR, respectively.  

As per FSC-STD-20-001, Certification bodies 
define a timeframe (up to 3 months for major 
non-conformities and up to the next audit for 
minor non-conformities) in the case of initial 
assessments  (minor non-conformities only) and 
surveillance audits (minor and major non-
conformities). There is a potential risk that a 
non-conformity may represent an infringement 
of legislation and that, as a result, illegal wood 
may enter the EU market without mitigation 
measures to prevent this from occurring for a 
period of up to 3 or 12 months. 

Justification 

“23.2 ASI shall prepare an Accreditation Report for the AC 
explaining the reasons leading to Withdrawal and any 

This indicator has been evaluated as Partially 
Covered. Requirements for non-conformities 

694 

 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

are structured in a way that there is a potential 
risk  that a non-conformity may represent an 
infringement of legislation and that, as a result, 
illegal wood may enter the EU market without 
mitigation measures to prevent this from 
occurring for a period of up to 3 or 12 months 

other relevant information considered material for the 
recommendation.” 

FSC-STD-20-001 V4-0 General requirements for FSC 
accredited certification bodies 
“4.3.13 Nonconformities shall be graded as follows: 
a) a nonconformity shall be considered minor if: 
i. it is a temporary lapse, or 
ii. it is unusual/non-systematic, or 
iii. the impacts of the nonconformity are limited in their 
temporal and organizational scale, and 
iv. it does not result in a fundamental failure to achieve the 
objective of the relevant requirement. 
b) a nonconformity shall be considered major if, either 
alone or in combination with further nonconformities, it 
results in, or is likely to result in a fundamental failure to 
achieve the objective of the relevant requirement within 
the scope of the evaluation. Such fundamental failures 
may be indicated by nonconformities which: 
i. continue over a long period of time, or 
ii. are systematic, or 
iii. affect a wide range of the production, or 
iv. affect the integrity of the FSC system, or 
v. are not corrected or adequately addressed by the client 
once they have been identified.” 

“4.3.16 The corrective action request timelines commence 
from the moment when they are formally presented to the 
client and no later than three (3) months from the audit 
closing date. Corrective action requests shall have the 
following timeframes: 
a) minor nonconformity shall be corrected within the 
maximum period of one (1) year (under exceptional and 
justified circumstances the timeline may be extended to 
two (2) years); 
b) major nonconformity shall be corrected within three (3) 
months (under exceptional and justified circumstances 
within six (6) months). 
NOTE: Action(s) taken to correct a major nonconformity 
may continue over a period of time which is longer than 
three (3) months. However, action must be taken within 

695 

 
 
 
 
  
 
C.3.2.3 The Scheme shall 
specify the approach to be 
used in oversight, ensuring 
that the oversight 
mechanism is independent 
of the Certification Bodies 
being assessed.  

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

the specified period which is sufficient to prevent new 
instances of 
nonconformity within the scope of the certification.” 

Findings 

Covered 

The FSC certification system operates as a 3rd 
party certification system with three key actors: 
FSC International Center GmbH (under the 
responsibility of the FSC AC Board, 
representing FSC’s membership)_is 
responsible for the development, maintenance 
and interpretation of the FSC normative 
framework. Certification bodies evaluate the 
conformity of organisations applying for and 
holding certification against the requirements of 
the normative framework. These certification 
bodies must be accredited to conduct 
evaluations and issue FSC certificates by a 
separate entity, Assurance Services 
International GmbH (ASI). Just as the 
certification bodies evaluate the conformity of 
organisations, ASI checks that the certification 
bodies follow the relevant accreditation 
requirements. 

Justification 

This indicator has been evaluated as Covered. 

C.3.2.4  The Scheme shall 
define the frequency of 
oversight or the procedure 
for determining the 
frequency, applicable in the 
case of risk-based 
oversight. 

ASI Procedure on Surveillance & Sampling: ASI-PRO-20-
105-Surveillance & Sampling-V6.4 

Findings 

Covered 

“5.1.1 At least once per calendar year, ASI shall review all 
assessment  results and other relevant information (e.g. 
complaints, incidents, stakeholder input, business profi le, 
etc.) for each CAB, since the date of the previous review.” 

“5.1.2 ASI shall modify and adjust the annual sampling 

696 

ASI’s Procedure on Surveillance and Sampling 
(ASI-PRO-20-105) outlines the process used 
by ASI to develop their annual plan for 
assessing  Certification Bodies. It takes a risk-
based approach based on performance. 

 
 
 
 
 
 
 
 
 
 
C.4 Certification process 

C.4.1 

Compliance 
evaluation 

C.4.1.1 The Scheme shall 
include requirements that 
ensure that the Certification 
Bodies applies a clear 
basis for:  
i) establishing 
conformance;  
ii) raising corrective actions 
for non-compliance, and;  
iii) certification decision 
making. 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

plan based on the results of the CAB Performance 
Review.” 

“5.2.1 Following the CAB Performance Review, ASI shall 
prepare an assessment plan for the forthcoming year for 
each CAB, following the sampling design described in this 
procedure.” 

Justification 

This indicator has been evaluated as Covered. 

FSC-STD-20-001 V4-0 General requirements for FSC 
accredited certification bodies 

Findings 

Covered 

The General requirements for CBs cover i) and 
ii) in Sections 4.3 – 4.5, with the grading of 
nonconformities specified in Clause 4.3.13. 
Detailed requirements for CoC, FM and FM 
CW evaluations are given in the respective 
FSC evaluation standards (FSC-STD-20-011, 
FSC-STD-20-007 and FSC-STD-20-012) 
where certification decision making is specified 
(Sections 4, 8 and 7, respectively).  

Justification 

This indicator has been evaluated as Covered. 

“4.3.11 The certification body shall evaluate each 
nonconformity identified in the audit to determine whether 
it constitutes a minor or major nonconformity.” 

“4.3.13 Nonconformities shall be graded as follows: 
a) a nonconformity shall be considered minor if: 
i. it is a temporary lapse, or 
ii. it is unusual/non-systematic, or 
iii. the impacts of the nonconformity are limited in their 
temporal and organizational scale, and  
iv. it does not result in a fundamental failure to achieve the 
objective of the relevant requirement. 
b) a nonconformity shall be considered major if, either 
alone or in 
combination with further nonconformities, it results in, or is 
likely to result in a fundamental failure to achieve the 
objective of the relevant requirement within the scope of 
the evaluation. Such fundamental failures may be 
indicated by nonconformities which: 
i. continue over a long period of time, or 
ii. are systematic, or 
iii. affect a wide range of the production, or 
iv. affect the integrity of the FSC system, or 
v. are not corrected or adequately addressed by the client 
once they have been identified.” 

“4.3.14 Nonconformities shall be transformed into 
corrective action requests that at minimum include a 

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ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

description of the nonconformity, the objective evidence 
on which the  nonconformity is based and a timeline within 
which the nonconformity shall be corrected by the client.” 

“4.7.3 The occurrence of five (5) or more major 
nonconformities in a surveillance audit shall be considered 
as a breakdown of the clients’ management system and 
certification shall be suspended within ten (10) days of the 
certification decision being taken.” 

FSC-STD-20-011 V4-1 Chain of Custody Evaluations  
“4.1 Certification bodies shall make certification decisions 
based on their evaluation of the chain of custody 
operation's conformity to each applicable requirement 
specified in the relevant FSC normative document(s) and 
in accordance with the latest version of FSC-STD-20-
001.2” 

“4.4 Five or more major corrective action requests issued 
to the central office of a group or multisite by the 
certification body shall result in the suspension of the 
entire certificate. Five or more major corrective action 
requests issued to a participating site of a group or 
multisite certificate by the certification body shall result in 
suspension of that particular participating site but will not 
necessarily result in the suspension of the entire 
certificate. Nonconformities identified at the participating-
site level may result in nonconformities at the central office 
level when the nonconformities are determined to be the 
result of the central 
office’s performance, per Clause 4.3 (a).” 

FSC-STD-20-007 Forest management evaluations 
Standard 
“8.14 The certification body shall not issue a certificate to 
an applicant if there is any major non-conformity with a 
requirement of the applicable Forest Stewardship 
Standard and/or other applicable certification 
requirements.” 

“8.15 A certificate shal l not be issued in the case that a 

698 

 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

large number of minor nonconformities or the cumulative 
impact of the non-conformities represents a fundamental 
failure or total breakdown of a system and thus constitute 
a major nonconformity.” 

“8.17 The occurrence of five or more major non-
conformities in one surveillance evaluation shall be 
considered as a total breakdown of the company’s 
management system and the certificate shall be 
suspended.” 

“8.18 The certification body shall not re-issue a certificate 
to a client if there is major nonconformity with a 
requirement of the applicable Forest Stewardship 
Standard and/or other applicable certification 
requirement.” 

FSC-STD-20-012 Standard for evaluation of FSC 
Controlled Wood in Forest Management Enterprises 

“7.6 The certification body shall not issue or re-issue a 
Controlled Wood certificate to a FME if there is a major 
non-compliance with the requirements of the standard.” 

“7.7 The certification body shall suspend or withdraw a 
certificate if a major noncompliance is identified after the 
Controlled Wood certificate has been issued.” 
FSC-STD-20-011 V4-1 Chain of Custody Evaluations  
“1.1 A chain of custody certificate issued by an FSC-
accredited certification body provides a credible guarantee 
that all chain of custody operations within the scope of a 
certificate conform to all applicable requirements of the 
relevant FSC normative documents. In order to provide 
such a guarantee, the certification 
body shall: 
a) analyse and describe the chain of custody operation 
and/or group or multisite certificate to be evaluated in 
terms of one or more operational sites; 
b) confirm that there is a control system in place capable 
of ensuring that all the applicable requirements are 
implemented by every operational site, including non-

699 

C.4.1.2 The Scheme 
requirements for 
establishing conformance 
should enable comparison 
with the definition of 
negligible and non-
negligible risk as  outlined in 
the EUTR and associated 
guides.  

Findings 

Covered 

The evaluation of Certificate Holders is system 
and performance based. Detailed requirements 
for CoC, FM and FM CW evaluations are given 
in the respective FSC evaluation standards 
(FSC-STD-20-011, FSC-STD-20-007 and FSC-
STD-20-012) which all specify that both 
systems  (Clauses  2.4, 5.2.1 and 1.3 
respectively) and performance shall be 
evaluated (Clauses 2.6, 5.4.2/5.4.4 and 1.3 
respectively). 

The General Requirements for FSC Accredited 

 
 
 
 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

Certification Bodies (FSC-STD-20-001 V4-0) 
includes requirements for the grading of non-
conformities as minor and major (Clause 
4.3.13), which, in relation to the Certification 
Bodies evaluating CoC Certificate Holders due 
diligence systems under the Sourcing of 
Controlled Wood (FSC-STD-40-005), align with 
the description of negligible and non-negligible 
risk  in the EUTR, respectively. 

Justification 

This indicator has been evaluated as Covered.  

certified suppliers as part of controlled wood and 
reclaimed material verification programs, project members 
in the case of project certificates and contractors as part of 
outsourcing agreements, within the 
scope of the evaluation; 
c) where applicable, carry out sampling of operational 
sites3 , non-certified suppliers4, contractors, project sites, 
non-FSC-certified project members, documents, 
management records, and interviews with personnel 
sufficient to verify that the control system is being 
implemented effectively and consistently across the whole 
scope of the certificate; 
d) confirm that any nonconformity is adequately addressed 
by the 
organization within the established timelines. 
NOTE: The chain of custody requirements of the FSC 
normative framework are designed to be applied at the 
site level of a chain of custody operation, unless otherwise 
specified in a standard.” 

“2.4 The certification body shall complete an analysis of 
the organization’s management control required to ensure 
that all applicable certification requirements are 
implemented over the full range of chain of custody 
operations, including the identification and analysis of the 
critical control points.” 

“2.6 The certification body shall evaluate each operational 
site within the scope of the evaluation (including a sample 
of participating sites of group and multisite certificates and 
non-FSC-certified project members in the case of project 
certificates) in order to make direct, factual observations to 
verify the 
organization’s conformance to all applicable certification 
requirements. The evaluation shall include: 
a) identification and assessment of management 
documentation and a sufficient variety and number of 
records at each operational site selected for evaluation in 
order to confirm that management is functioning effectively 
and as described, particularly with respect to the identified 
critical control points; 

700 

 
 
 
  
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

b) interviews with a sufficient variety and number of 
employees and contractors at each operational site 
selected for evaluation in order to verify the organization’s 
conformance to all applicable certification requirements. 
As a minimum, interviews shall be conducted to verify 
training measures and understanding of individual 
responsibilities at different locations across the operation 
under evaluation. The interviewer shall ensure that 
comments can be provided in confidence; 
c) review of the organization’s implementation of all 
applicable corrective action requests; 
d) review of all complaints, disputes, or allegations of 
nonconformities received by the organization and/or the 
certification body; 
e) physical inspection of all sites selected for evaluation, 
including inspection of all locations where operational 
activities under the scope of the certificate are carried out. 
Desk  audits may be conducted where: 
i. the site does not take physical possession of FSC-
certified materials or products, controlled material, or FSC 
controlled wood in their own or rented facilities, and does 
not label, alter, store, or repackage the products (e.g. 
sales office); 
ii. the site is used for storage of finished and labelled 
products only, and where the certification body has 
confirmed through an initial physical inspection that there 
is no risk  of mixing FSC-certified products with other 
materials (e.g. the site only stores FSC-certified products). 
Certification bodies shall conduct physical inspection of 
these storage sites  at least once during the five-year 
duration of a certificate; 
iii. the physical inspection during surveillance evaluations 
of one-time project certificates is not relevant (e.g. there is 
nothing to inspect on the site; a single delivery of materials 
to the project; when all project members supplying the 
project are FSC-certified). 
NOTE: Certification bodies are not obliged to conduct 
desk  audits, even when all requirements specified in 2.6 e) 
above are satisfied. At its own discretion, initially or at any 
time, the certification body may decide to carry out site 
visits where and when necessary to ensure confidence in 

701 

 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

a certificate. 
f) purchasing and sales documentation of any materials or 
products related to FSC certification (e.g. invoices, bills, 
transport documents, sales contracts); 
g) confirmation that inputs described as FSC-certified or 
FSC controlled wood were covered by a valid FSC chain 
of custody certificate and supplied with the applicable FSC 
claims and certificate codes; 
h) review of systems  for controlling FSC claims: 
i. for percentage and credit systems, review of calculations 
of 
percentages and/or credits for each product group within 
the scope of the certificate;  
ii. for transfer systems,  review of a sample of records of 
certified outputs, and confirmation that these can be 
traced to certified inputs 
iii. for project certification: verification that only eligible 
materials were used in projects (or components thereof) 
and the FSC claims made on them are true and correct; 
i) confirmation of the correct use of FSC trademarks (on-
product and promotional) and the ‘FSC Controlled Wood’ 
claim in segregation marks, sales, and transport 
documentation; 
j) review of training records (e.g. training materials and list 
of participants);” 

FSC-STD-20-007 V3-0 Forest management evaluations 
Standard 
“5.2.1 The certification body shall complete an explicit 
analysis of the critical aspects of management control 
required to ensure that the applicable Forest Stewardship 
Standard is implemented over: 
a) the full geographical area of the evaluation; 
b) the full range of management operations. 
NOTE: The extent to which the management system is 
documented shall be an important part of the evaluation. 
For large enterprises a fully documented management 
system is expected. A system based on verbal 
descriptions and simple 
documentation may be sufficient to implement the 
requirements of the applicable Forest Stewardship 

702 

 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

Standard for small scale or low intensity enterprises.” 

“5.4.1 The auditor(s) shall identify and assess 
management documentation and a sufficient variety and 
number of records at each FMU selected for evaluation as 
to make direct, factual observations to verify conformity 
with all the indicators of the 
applicable Forest Stewardship Standard that are under 
evaluation at that FMU and for which such documents are 
a necessary  means of verification.” 

“5.4.2 The auditor(s) shall visit a sufficient variety and 
number of sites within each FMU selected for evaluation 
as to make direct, factual observations as to conformity 
with all the indicators of the applicable Forest Stewardship 
Standard that are under evaluation at that FMU and for 
which such inspection is a necessary means of 
verification, over the range of conditions under 
management by the applicant forest management 
enterprise.” 

“5.4.4 The auditor(s) shall interview a sufficient variety and 
number of people affected by or involved in the forest 
management of each FMU as to make direct, factual 
observations as to conformity with all the indicators of the 
applicable Forest Stewardship Standard that are under 
evaluation at that FMU and for which such consultation is 
a necessary  means of verification, over the range of 
conditions under management by the applicant forest 
management enterprise. Annex 4 provides 
examples of stakeholder groups that the auditor(s) may 
consult.” 

FSC-STD-20-012 Standard for evaluation of FSC 
Controlled Wood in Forest Management Enterprises 

“1.3 A FSC Controlled Wood certificate issued by an FSC-
accredited certification body provides a credible guarantee 
that there is no major failure in compliance with the 
requirements of the FSC-STD-30-010 in any FMU within 
the scope of the certificate.” 

703 

 
 
 
 
 
 
ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

“1.4 In order to provide such a guarantee the certification 
body shall:  
a) analyze and describe the forest area to be evaluated in 
terms of one or more FMU’s; 
b) confirm that there is a management system in place that 
is capable of ensuring that all the requirements of the 
FSC-STD-30-010 are implemented in every FMU within 
the scope of the evaluation; 
c) carry out sampling of sites, management records and 
interviews with consultation with stakeholders sufficient to 
provide a credible guarantee that there are no major non-
compliances with the categories of the FSC Controlled 
Wood standard for forest management enterprises within 
any FMU within the scope of the evaluation.” 

FSC-STD-20-001 V4-0 General requirements for FSC 
accredited certification bodies 
“4.3.13 Nonconformities shall be graded as follows:  
a) a nonconformity shall be considered minor if: 
i. it is a temporary lapse, or 
ii. it is unusual/non-systematic, or 
iii. the impacts of the nonconformity are limited in their 
temporal and organizational scale, and  
iv. it does not result in a fundamental failure to achieve the 
objective of the relevant requirement. 
b) a nonconformity shall be considered major if, either 
alone or in 
combination with further nonconformities, it results in, or is 
likely to result in a fundamental failure to achieve the 
objective of the relevant requirement within the scope of 
the evaluation. Such fundamental failures may be 
indicated by nonconformities which: 
i. continue over a long period of time, or 
ii. are systematic, or 
iii. affect a wide range of the production, or 
iv. affect the integrity of the FSC system, or 
v. are not corrected or adequately addressed by the client 
once they have been identified.” 

704 

 
 
 
 
C.4.1.3 The Scheme shall 
include requirements that 
ensure that the above 
requirements are in line 
with the requirements of the 
EUTR to prohibit illegal 
material or material with a 
non-negligible risk category 
being placed on the EU 
market. 

ANNEX 5 : SCHEME ASSESSMENT REPORT – FSC 

FSC-STD-20-001 V4-0 General requirements for FSC 
accredited certification bodies 
“4.3.13 Nonconformities shall be graded as follows: 
a) a nonconformity shall be considered minor if: 
i. it is a temporary lapse, or 
ii. it is unusual/non-systematic, or 
iii. the impacts of the nonconformity are limited in their 
temporal and organizational scale, and 
iv. it does not result in a fundamental failure to achieve the 
objective of the relevant requirement. 
b) a nonconformity shall be considered major if, either 
alone or in combination with further nonconformities, it 
results in, or is likely to result in a fundamental failure to 
achieve the objective of the relevant requirement within 
the scope of the evaluation. Such fundamental failures 
may be indicated by nonconformities which: 
i. continue over a long period of time, or 
ii. are systematic, or 
iii. affect a wide range of the production, or 
iv. affect the integrity of the FSC system, or 
v. are not corrected or adequately addressed by the client 
once they have been identified.” 

“4.3.16 The corrective action request timelines commence 
from the moment when they are formally presented to the 
client and no later than three (3) months from the audit 
closing date. Corrective action requests shall have the 
following timeframes: 
a) minor nonconformity shall be corrected within the 
maximum period of one (1) year (under exceptional and 
justified circumstances the timeline may be extended to 
two (2) years); 
b) major nonconformity shall be corrected within three (3) 
months (under exceptional and justified circumstances 
within six (6) months). 
NOTE: Action(s) taken to correct a major nonconformity 
may continue over a period of time which is longer than 
three (3) months. However, action must be taken within 
the specified period which is sufficient to prevent new 
instances of 
nonconformity within the scope of the certification.” 

705 

Findings  

Partially Covered 

When a Certification Body identifies a non-
conformity the Certificate Holder is given a 
maximum timeframe in which to implement 
corrective actions. The timeframe is determined by 
the severity of the non-conformance, with minor 
non-conformities being given a maximum of one 
year to be corrected and major non-conformities 
given a maximum of three months (Clause 4.3.16, 
FSC-STD-20-001 V4-0). Certification Bodies can 
issue shorter timelines, where they are deemed 
appropriate.  

The General Requirements for FSC Accredited 
Certification Bodies (FSC-STD-20-001 V4-0) 
includes requirements for the grading of non-
conformities as minor and major (Clause 
4.3.13), which, in relation to the Certification 
Bodies evaluating CoC Certificate Holders due 
diligence systems under the Sourcing of 
Controlled Wood (FSC-STD-40-005), align with 
the description of negligible and non-negligible 
risk  in the EUTR, respectively.  

Certification bodies define a timeframe (up to 3 
months for major non-conformities and up to 
the next audit for minor non-conformities) in the 
case of initial assessments (minor non-
conformities only) and surveillance audits 
(minor and major non-conformities). There is a 
potential risk that a non-conformity may 
represent an infringement of legislation and 
that, as a result, illegal wood may enter the EU 
market without mitigation measures to prevent 
this from occurring for a period of up to 3 or 12 
months. 

Justification 

This indicator has been evaluated as Partially 

 
 
 
 
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Covered. Requirements for non-conformities are 
structured in a way that there is a potential risk 
that a non-conformity may represent an 
infringement of legislation and that, as a result, 
wood may enter the EU market that could be 
interpreted as illegal or non-negligible risk. 

Justification 

This indicator has been evaluated as Partially 
Covered. 

C.4.1.4 the Scheme shall 
include requirements that 
ensure that the decision 
process  to certify 
organisations, or maintain 
certification of CHs, is free 
from conflict of interest and 
includes checks and 
balances. 

FSC-STD-20-001 V4-0 General requirements for FSC 
accredited certification bodies 

Findings 

Covered 

1.5.1 The certification body shall be responsible for 
ensuring that certification activities are undertaken 
impartially and shall not allow commercial, financial or 
other pressures  to compromise impartiality. 
. 

Impartiality requirements are included in 
Section 1.5 of the general requirements for 
CBs, with Clause 1.5.1 mandating it the CB’s 
responsibility to ensure impartiality.  

Justification 

This indicator has been evaluated as Covered. 

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Annex 6: Scheme Assessment  Report 
Sustainable Biomass Program (SBP) 

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Table of Contents 

Executive summary ................................................................................................. 709 
Introduction............................................................................................................... 711 
Acronyms ................................................................................................................. 712 
1.  Overview of the SBP Certification Scheme .................................................... 713 
Background .......................................................................................................... 713 
Global Governance .............................................................................................. 713 
The SBP Framework............................................................................................ 714 
Biomass Producers with Supply Base Evaluation.............................................. 715 
Risk Assessments................................................................................................ 715 
Supplier Verification Program.............................................................................. 716 
Risk mitigation ...................................................................................................... 716 
Supply Base Report ............................................................................................. 717 
Feedstock types ................................................................................................... 717 
Data Transfer System (DTS) ............................................................................... 717 
SBP Audit Portal .................................................................................................. 717 
Accreditation Process .......................................................................................... 718 
Scope of this evaluation....................................................................................... 718 
2.  Overview of the scheme Standards used for this assessment...................... 719 
3.  Assessment methodology................................................................................ 720 
4.  Overview of findings ......................................................................................... 721 
Performance information (Articles and other reliable info)  ................................ 722 
5.  Evaluation ......................................................................................................... 724 
A. Requirements for Certificate Holders  ............................................................. 724 
A.1  Legal  Requirements at the forest level  including  wood growing  in areas 
outside forest ........................................................................................................ 724 
A.2 Legal requirements for supply chain entities ............................................... 758 
A.3 Requirements for material control ................................................................ 768 
A.4 General requirements for Certificate Holders  .............................................. 775 
A.5 Quality and procedural requirements for Certificate Holders ...................... 777 
B. Requirements for Certification Bodies ............................................................ 784 
B.1 General Certification Body requirements ..................................................... 784 
B.2 Certification Body requirements for auditing and certification  .................... 787 
C. Requirements for Certification Schemes ....................................................... 795 
C.1 Transparency................................................................................................. 795 
C.2 Scheme & Standard scope ........................................................................... 800 
C.3 Accreditation and oversight .......................................................................... 805 
C.4 Certification process...................................................................................... 814 
Annex 1. References ............................................................................................... 819 

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Executive summary 

The objective of the Scheme Assessment Report of the Sustainable Biomass Program 
(SBP) is to create a resource of knowledge and reference for all interested and concerned 
parties  in  the  forest-  and  wood-based  products  sector.  It  should  help  Competent 
Authorities,  Operators  and  Monitoring  Organisations  covered  by  the  EUTR  in  their 
understanding of potential benefits and shortcomings of certification, in particular in the 
context of the implementation of the EUTR. 

The  SBP  is  a  certification scheme that accepts input from other large and well -known 
certification schemes (currently FSC, PEFC and PEFC endorsed schemes), as well as 
input sourced under the scope of its own evaluation framework. The sourcing through its 
own scheme is based on risk assessments for SBP’s indicators. The objective is to have 
one system for certified biomass. 

The overall finding of the assessment is that SBP is a transparent scheme that covers 
many critical parts of the EUTR. 

It should be noted that the coverage of the SBP scheme is dependent, to a large extend, 
on  the  strength  of  the  schemes  they  approve  –  currently  FSC  and  PEFC  endorsed 
schemes.  Many  of  the  Biomass  Producers  uses  only  input  from  these  approved 
certification schemes. Therefore, conclusions from this report needs to be supported by 
strength  and  weaknesses  from  the  approved  schemes.  Wood  sourced  from  land not 
classified as forest land is included in the scope of this evaluation. 

The following strengths and weaknesses have been found in the SBP scheme:  

Main strengths: 

In  general,  the  SBP  scheme  standards  cover  most  requirements  of  the  Assessment 
Framework including requirements for Certificate Holders, the Certification Bodies and the 
Scheme. SBP is considered relatively transparent and has public summary reports that 
includes most information from the audit, for example non-conformities. Also, the Supply 
Base Reports and Supply Base Evaluations, including risk ratings, are publicly available. 

The  SBP  has  implemented  a  data  transfer  system  (DTS)  for  digital  transactions  of 
biomass with SBP-claims. This system must be used in order to transfer valid claims. This 
means  that  SBP  or  auditors  can  see all transactions in the supply chain and that the 
amount of biomass cannot be inflated further down the supply chain. SBP has also started 
to implement an on-line reporting portal. This portal must be used by certification bodies 
and certificate holders and enables increased digital monitoring of information added into 
the audit reports, Supply Base Reports or Supply Base Evaluations. For example, risk 
ratings or information used by the accreditation body will be easy to find and summarise.  

Main weaknesses: 

Some issues have been identified that could constitute a weakness in the scheme’s ability 
to meet important aspects of legality quality assurance. 

There is no requirement within the SBP Standards to control illegal activities related to 
offshore trading and transfer pricing. There are two requirements that aims at covering 
EUTR in a general way in Standard 4 (6.1.2 and 6.1.3) and one requirement that attempts 
to cover all applicable laws in the country where the certificate holder conduct its business 
(Standard 4, 6.3.3). However, these requirements are general and not comprehensive 
enough to cover specific issues like offshore trading and transfer pricing without further 
specifications or guidelines. 

There are no requirements explicitly covering payment of VAT, other sales taxes or taxes. 
There are requirements for control of sales invoices and for payment of any fees and 
duties, but VAT or other types of taxes are not explicitly mentioned in these requirements. 

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Therefore, this is only considered to be partially (or potentially) covered by the SBP chain 
of custody Standard.  

SBP  itself  has  no  system  or  written  procedures  for  how  to  approve  new  certification 
schemes. This is found to be a significant gap in the scheme, since there is no information 
regarding criteria for approval of schemes and many of the chain of custody requirements 
in the SBP Standard 4 rely on the approved CoC-scheme (e.g. requirements related to 
written procedures). It should be noted that SBP has not approved any new schemes after 
approval of FSC, PEFC and PEFC-endorsed schemes, but PEFC endorses new schemes 
which then also affects SBP. According to SBP, their secretariat is currently working on 
written procedures for approvals of other certification schemes. 

If the certificate holder is not a Biomass Producer, there is no requirement for Certificate 
Holders to review the proper functioning of their own procedures internally and regularly 
(A5).  However,  this  is  not  assessed  as  a  critical  gap  since  annual  audits  from  an 
independent certification body is required. 

Performance information: 

Even  though  SBP  is  a  quite  young  certification  scheme,  there  are  publicly  available 
criticism  of  the  scheme,  but  also  criticism  or  impact  information  regarding  other 
certification schemes that is also relevant to SBP. 

The conclusion from this study is that care must be takes before implementing the findings 
from this report in countries with high corruption or where high risk for illegality within the 
forest  sector  exists.  Extra  risk  mitigation  measures  beyond  certification  and  the gaps 
found in this report should be considered in these cases. Issues raised in reports related 
to the SBP risk assessments and risk ratings are considered to be more important when 
SBP has not endorsed any Regional Risk Assessment (RRA), but the companies make 
their own Risk Assessment (RA). Many issues raised in publicly available sources that 
relates to SBP are related to concerns about sustainability issues of using woody biomass 
as a source of energy and do not related to legality. These issues are not addressed in 
this framework. 

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Introduction 

The objective of the Scheme Assessment Report of the Sustainable Biomass Program 
(SBP) is to create a resource of knowledge and reference for all interested and concerned 
parties  in  the  forest-  and  wood-based  products  sector.  It  should  help  Competent 
Authorities,  Operators  and  Monitoring  Organisations  covered  by  the  EUTR  in  their 
understanding of potential benefits and shortcomings of certification, in particular in the 
context of the implementation of the EUTR. As such, one part of the overall objectives is 
to create an overview of existing certificates, third-party verified schemes and certifying 
bodies issuing certificates with regard to forests and wood-based products and to evaluate 
their  respective  strengths  and  weaknesses  in  respect  to  the  EUTR  obligations.  This 
should, in turn, encourage stronger Standards and transparency of certification and third 
part verification schemes. 

It should be underlined that it is NOT the intention of the study to create a compliance 
checklist  of  certification  schemes.  The  EUTR  continues  to  recognise  third  party 
certification  as  an  important  potential tool for Risk Assessment and risk mitigation but 
does not recognise certification as proof of compliance. This will not change based on this 
study. 

As part of the above objective, this framework has been developed to allow evaluation of 
the  differences  and  uniformities  between  certificates  and certifying bodies. It includes 
requirements  to  assess  to  which  degree different forest certification schemes provide 
assurance of negligible risk of ‘legal non-compliance’ of certified material.  

The  Framework  aligns  with  the  definitions  and  approach  to  certification  schemes  as 
described within the EU Timber Regulation (No. 995/2010) and the associated Guidance 
Document,  along  with  additional  requirements  for  the  use  of  third  party  certification 
schemes as outlined in the Commission implementing Regulation (EU) No 607/2012 and 
specifically Article 4 in the Commission Implementing Regulation (EU) No 607/2012. 

The Scheme Assessment Framework has been developed by Preferred by Nature as a 
comprehensive  interpretation  of  the  EUTR  legality  definition  to  provide  the  ability  to 
evaluate in detail the different aspects of legality covered by the schemes included in this 
study. It should therefore be underlined that the legality definition used in the Assessment 
Framework is a comprehensive interpretation of the EUTR intended to expand on the five 
legality categories included in the Regulation.  

The Framework takes into account verifiers for Article 6 in the EUTR, and documentation 
for  Article  4  of  the  Implementing  Regulation,  as  well  as  a  wide  array  of sustainability 
Standards and benchmarks used in the areas of forest and wood -based products, among 
other resources identified under References. 

The current report contains an evaluation of the Sustainable Biomass Program (SBP).  

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Acronyms 

BP 

CB 

CH 

Biomass Producer 

Certification Body 

Certificate Holder 

CoC  Chain of Custody 

DTS  Data Transfer System 

FM 

Forest Management 

FPIC  Free, Prior and Informed Consent 

FSC  Forest Stewardship Council® (SBP-approved certification scheme) 

NGO  Non-governmental organisation (i.e. non-profit organisations) 

PEFC  Programme for the Endorsement of Forest Certification  

(SBP-approved certification scheme) 

RA 

Risk Assessment (company-made) 

RRA  Regional Risk Assessment (SBP-endorsed) 

SAF  Scheme Assessment Framework 

SAP  Scheme Assessment Procedure  

SBE  Supply Base Evaluation 

SBR  Supply Base Report 

SFI 

Sustainable Forestry Initiative (SBP-approved certification scheme) 

SVP    Supplier Verification Program 

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39.  Overview of the SBP Certification Scheme 

Background 

The Sustainable Biomass Program (SBP) is a risk-based certification scheme for sourcing 
of biomass that  aims at accepting input from different large and well-known certification 
schemes, or from its own evaluation framework, in order to have one system for certified 
biomass.  The  risk-based approach means that there are no SBP-certified forests, but 
biomass  is verified against risk assessments based on SBP criteria. If raw material for 
biomass (so called feedstock) is not sourced through an approved certification schemes, 
SBP’s Standards for feedstock compliance are used instead. This means that the SBP 
framework for risk identification, supplier monitoring, and risk mitigation defined in these 
Standards must be implemented (see more details below). 

SBP was founded in 2013 and was initiated by large energy producers in Europe under 
the name Sustainable Biomass Partnership. Today, the energy producers’ role has faded 
in order to make SBP an independent and impartial certification scheme. At present, the 
board  consists  of  three  stakeholder representatives from each of the following areas: 
biomass end-users, Biomass Producers and civil society. 

In the SBP Annual Review Report (2020), the SBP declared that by the end of 2019 they 
had 210 certificate holders whereof 167 were Biomass Producers, 35 traders and 8 end -
users. The SBP’s geographical extent of certificate holders included 25 different countries 
in Europe, Asia, Oceania, North and South America. The amount of certified biomass sold 
through the SBP system was 12 million tons (Mt) of biomass (wood chips or wood pellets). 

Global Governance 

SBP are committed to following the ISEAL Codes of Good Practice for Standard -setting, 
assurance  and  impacts.  The  SBP  Secretariat  manage  the  Standards  Development 
Process and support the work of the various Working Groups responsible for developing 
the content, with significant  input from the Standards Committee, Technical Committee 
and Stakeholder Advisory Group, as well as Certificate Holders, Certification Bodies and 
Accreditation Body. All interested parties shall have the opportunity to participate in the 
Standard  development  process  through  getting  involved  in  the  work  of  the  various 
Working  Groups,  public  consultations,  events  or  simply  through  getting  in  touch  and 
providing  SBP  with  views  and  ideas.  However,  the  SBP  scheme  is  no  member 
organization with different stakeholder chambers that can vote and directly influence the 
standard development. The Standards Committee is finally approving the Standards. 

The Standard committee has six representatives from commercial interests and six from 
civil society interests. There is a Stakeholder Advisory Group whose role is to provide a 
platform  for  stakeholder  input  and  advice  to  support  the  work  of  the  SBP  Standards 
Committee in the development, implementation and maintenance of SBP Standards and 
related  documents,  and  other  relevant  activities.  Certification  Bodies  are  doing 
stakeholder  consultations  during  assessments  and  re-assessments  of  Biomass 
Producers. Traders applying for a certification evaluation is not exposed to stakeholder 
consultation. 

SBP  has  no  regional  or  country  Standards,  but  implement  all  its  Standards  on  an 
international level. Standard indicators at the forest level are addressed in such way that 
they  shall  be  adapted  to  reflect  risks  and  situations  in  specific  regions  where  it  is 
implemented. This is done through the risk assessment process where all indicators are 
evaluated  in  its  local  context  (country  or  regional  level).  Risks  identified  in  the  risk 
assessment must be mitigated by the Biomass Producer before feedstock can be sourced 
from the area. 

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The SBP Framework 

The SBP scheme accepts input from other certification schemes and SBP implements the 
term  “SBP-approved”  scheme,  system  or  claim.  The  forest  management  certification 
schemes currently approved by SBP are: FSC® and PEFC including direct sourcing fro m 
all  PEFC-endorsed  Forest Management Schemes (e.g. SFI). SBP also approves non -
certified  input  from  FSC,  PEFC  and  PEFC  endorsed  schemes.  For  example,  FSC 
Controlled Wood and PEFC Controlled Sources, and input from the SFI Fiber Sourcing 
Standard. There are currently no system or procedures, nor written information, relating to 
how  SBP  has approved the certification schemes to become SBP eligible input. It was 
decided to approve FSC and PEFC-endorsed forest management schemes back in 2015 
when  SBP  started  up.  According  to  SBP,  their  secretariat  is  currently  working  on 
formalizing this process. 

There are three ways for material to be accepted into the SBP system (i.e., physically 
enter the system):  

1.  through an SBP Supply Base Evaluation (SBE) covering the entire supply base, 
where  risks  are  identified  in  regional  Risk  Assessments (see more information 
below) 

2.  through already certified material from SBP-approved schemes: FSC, PEF C and 
PEFC-endorsed  schemes  (e.g.  SFI).  This  material  must  be received with valid 
claims from these certification schemes. 

3.  controlled  material  from  SBP-approved  schemes:  FSC,  PEFC  and  PEFC-
endorsed schemes (e.g. SFI) that are received with valid claims or origins from the 
Biomass  Producer’s  own  control  system  in  line  with  applicable  scheme 
requirements for these schemes. 

SBP  certified  (called  SBP-compliant)  biomass  can  only  be  accepted  as compliant if it 
origins from one of the two first points, but can physically be mixed with, and thus also 
contain, SBP-controlled biomass. In other words, there is no claim to ensure the biomass 
only  contains  100%  SBP-compliant  biomass,  but  it  can  always  be  mixed  with  SBP-
controlled biomass. 

SBP  does  not  have  its  own  system  for  controlling  uncertified  material,  but  accepts 
controlled material from FSC, PEFC and SFI. This means that material must be received 
with valid claims from respectively scheme, OR the SBP certificate holder must implement 
the  FSC  controlled  wood  Standard  (FSC-STD-40-005),  PEFC  controlled  sources 
requirements  (parts  of  PEFC  ST  2002:2013),  or SFI Fiber Sourcing Standard (or the 
standard  from other PEFC-endorsed schemes). This is then under the scope of FSC, 
PEFC or SFI evaluations and not the SBP evaluation. The ratio of controlled material can 
only be sold as SBP-controlled and is not SBP-compliant. 

Please note: This evaluation only focuses on material certified against the SBE. 

Before the material reaches its final biomass product, SBP calls the material  fe edstock 
(i.e. the input material). When the final product is made (e.g. wood  pellets or wood chips) 
it is referred to as biomass. 

Certificate Holders can be either Biomass Producers or biomass traders. The scope of 
traders  is  that  they  are  only  evaluated  against  Standard  4  (Chain  of  custody) and 5 
(Collection and communication of data). Biomass producers are always evaluated against 
Standards 2 (Verification of SBP-compliant feedstock), 4 and 5, but if they also include 
feedstock that is not already certified by another scheme, they are also evaluated against 
Standard 1 (Feedstock compliance). 

Biomass  Producers  can  have  different  scopes  of  their  certificate  depending  on  the 
feedstock they source for biomass production. Either they only source already certified or 
controlled feedstock (i.e. feedstock with an SBP-approved claim), or they source under 
their own Supply Base Evaluation (SBE) and mitigate any risks related to requirements in 
Standard  1  (Feedstock  Compliance  Standard).  Biomass  Producers  can  have  a 
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certification scope with a combination of these types of input, but always ha ve to show 
compliance  to  Standard  4  and  5.  In  all cases, Biomass Producers must implement all 
relevant  aspects  of  Standard  2  (Verification  of  SBP-compliant  Feedstock)  including 
requirements regarding determination of origin, supply base report (SBR), manag ement 
system, credibility of the SBR, and comments or complaints. 

Sourcing  of  wood  origin  from areas not defined as forest are also included under the 
scope  of  Standard  1  and  2  and  shall  be assessed in the same way as other primary 
feedstock. 

Biomass Producers with Supply Base Evaluation 

The Supply Base Evaluation (SBE) shall be implemented by all Biomass Producers that 
are  not  only  sourcing  feedstock  from  SBP-approved  certification  schemes.  The  SBE 
consists  of  three  parts:  Risk  Assessment  (RA  or  RRA), Supplier Verification Program 
(SVP) to assign a risk level to those indicators where the RA was inconclusive (if needed) 
and  risk  mitigation  (Figure  1).  These  parts  have  to  be  completed  for  all  Biomass 
Producers  that  are  not  only  sourcing  feedstock  that  alrea dy  holds  an SBP-approved 
certification claim. 

The whole Supply Base Evaluation shall go through stakeholder consultation before the 
process is finished and the SBE can be accepted. 

Figure  1.  Flow  showing  the  relationship  between  the  Risk  Assessment  and  su pplier 
verification program within the supply base evaluation. (Figure from SBP Standard 2).  

Risk Assessments 

Risk Assessments are a key tool in the SBP system and is used to assess the indicators 
in  Standard  1.  The  Risk  Assessment(s)  must  cover  the  entir e  Supply  Base  and  the 
Biomass Producer must declare the Supply Base in an official Supply Base Report (SBR).  

There are two types of Risk Assessments:  

1.  SBP-endorsed Regional Risk Assessment (RRA) and  
2.  “Company-made” Risk Assessments (RA).  

Both  must  be  exposed  to  stakeholder  consultation  and  accepted  by  SBP  and  the 
certification  body  before it can be used. However, the SBP-endorsed RRA is stronger 
since all Biomass Producers must use it if it exists. Where risks are identified in the Risk 
Assessments, risk mitigation measures must be executed to a level that low risk can be 

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concluded.  These  measures  are  the  focus  on  SBP  audits  at  the  forest  level.  All  risk 
indicators in Standard 1 are evaluated if and when they are relevant, but the indicator s 
with  risk  is  the  main  focus  at  audits.  Currently,  four  Regional  Risk  Assessments  are 
endorsed by SBP. These are for the following countries: Denmark, Estonia, Latvia and 
Lithuania. According to SBP, several Regional Risk Assessments that aim to be endors ed 
by SBP are in development. 

Process for Risk Assessments 

Company-made  Risk  Assessments  (RAs)  are  made  in  accordance  with  requirements 
specified in Standard 2. All indicators in Standard 1 must be covered and the risk rating 
must conclude specified risk, unspecified risk, or low risk for each indicator. Unspecified 
risk is only accepted in the Risk Assessments and must be re-categorized to low risk or 
specified  risk  in  the  Supplier  Verification  Program.  The  risk-based  approach  is 
implemented in three steps: gathering information, Risk Assessment and management of 
risk (i.e. risk avoidance or risk mitigation) and starts on a regional level and not at a forest 
level. Risk mitigation is implemented at the forest level. 

The Regional Risk Assessments (RRAs) shall be made by a competent “working body” 
not  working  at  the  Biomass  Producer  and  selected  by  a  “sponsoring  body”  who  will 
monitor the RRA process. SBP shall confirm the competence of the working body before 
the  work  starts.  Last,  the working body appoints a “co-ordinator” which facilitates and 
manages  the  process,  including  stakeholder  consultation.  The  RRA  has  its  own 
Stakeholder consultation arranged by the RRA Co-ordinator who shall both identify and 
contact relevant stakeholders and perform the consultation. All requirements for RRA is 
defined in RRA-procedure v 1.1 and there is a template that shall be used (Annex 2). SBP 
reviews the draft before it is in consultation. 

Regardless of type of Risk Assessment used by the company, the company’s draft Supply 
Base  Evaluation  shall  be  in  stakeholder  consultation for at least 30 days. This report 
contains  the company’s Risk Assessment (if no SBP-endorsed RRA) and the Supplier 
Verification Program.  

Risks identified in the RA or RRA must be mitigated or avoided by certificate holders and 
proof of compliance must be provided during audits. 

Supplier Verification Program 

The purpose of the SVP is to assign a risk level to those indicators where the RA was 
inconclusive (i.e. for indicators initially rated as unspecified risk). The SVP might include 
field-based  assessments  of  indicators  (for  example,  audit  of  the  Biomass  Producer’s 
feedstock  suppliers).  The  purpose,  extent  and  nature  of any SVP evaluation and the 
associated mitigation measures shall be documented. 

Risk mitigation 

Where an indicator is rated as specified risk, mitigation measures shall be taken to reduce 
the risk level to low risk. Mitigation measures shall be justified and recorded. The BP shall 
implement a plan to monitor the effectiveness of the mitigation measures, at least annually 
(i.e. every 12 months).  

Where mitigation measures have not been effective in managing risk, and an indicator 
cannot  be  rated  as  low  risk,  further  measures  shall  be  implemented  in  order  for  the 
feedstock to be compliant with SBP Standard 1 (Feedstock Compliance Standard). If it is 
not  possible  to  mitigate  risks  to  a  low  risk  level,  the  source  shall  be  avoided,  and 
feedstock physically excluded from SBP-certified biomass. 

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Supply Base Report 

Each Biomass Producer shall write a supply base report that is publicly available on their 
webpage. The idea with the supply base report is that Biomass Producers openly shall 
show  where  their  feedstock  comes  from  and  that  they  have  knowledge  about  their 
sourcing area. 

The  supply  base  report  shall  be  written  in  a  specific  format  and  include  relevant 
information about forest management practice, forest resource, scale of harvest, presence 
of CITES and IUCN red listed species within the supply base. Additionally, the Biomass 
Producer shall declare which type of feedstock (certified, primary, secondary or tertiary) 
that is sourced from the supply base and indicate how many suppliers that are used. It is 
acceptable to exclude company sensitive information from the supply base report.  

Feedstock types 

Primary feedstock: Feedstock sourced directly from the forest. For example, tops and 
branches, small-sized trees, roundwood and degraded wood. 

Secondary  feedstock:  Feedstock  sourced  from  primary  processors.  For  example, 
sawdust and cut-offs from sawmills. 

Tertiary  pre -consumed  feedstock:  Feedstock  from  secondary  processors.  This 
feedstock is usually dry. For example, sawdust and cut-offs from industries using alrea dy 
sawn  material  from  secondary  processors.  This  feedstock  is  not  considered  post -
consumed. 

Tertiary post-consumed feedstock: Feedstock from reclaimed material from consumers 
or commercial products. For example, wood material from demolished buildings or w ood 
collected at a recycling facility. The Biomass Producer shall control and collect evidence 
for post-consumer tertiary feedstock (also called reclaimed feedstock). If all evidence is in 
place, this material can be considered eligible input to SBP-compliant biomass. T he SBP 
definition is in line with the EUTR definition of reclaimed material (see Instruction Note 4A: 
SBP tertiary feedstock requirements). 

All  feedstock  types  that  are  not  tertiary  post-consumed  feedstock  must go through a 
supply base evaluation including risk mitigation against criteria in Standard 1 (F eedstock 
Compliance Standard), if they are not received with an SBP-approved certification claim.  

Data Transfer System (DTS)  

In SBP, all claims are transferred digitally in order to be valid. The system used is called 
DTS (Data Transfer System) 98 and is mandatory to use when selling and buying biomass 
with  SBP-claims.  In  the  system,  auditors  can  extract  summaries  of  transactions  and 
control volume balances. 

SBP Audit Portal 

SBP has recently started up an audit portal that will be compulsory to use from the 1st of 
January 2021. Certification Bodies must use this portal when reporting audit results that 
are  included  in  the  public  summary  report.  The  public  summary  report  will  then  be 
automatically  regenerated  from  this  system  and  includes  details  like  risk  ratings  of 
indicators in Standard 1 (Feedstock Compliance Standard) and open and closed non -

98 https://sbp-cert.org/data-transfer-system/  

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conformities. The Supply Base Report and Supply Base Evaluation will also have to be 
submitted through this system by certificate holders.  

The portal will also allow the accreditation body (ASI) to do more effective surveillance of 
Certification  Bodies’  performance.  This  includes  more  efficient  desk  reviews  of  audit 
reports (earlier ASI had to manually browse through PDF files), monitor audit timeliness in 
real time, validate that only qualified auditors are assigned to SBP audits, and allow an 
efficient way to monitor Certification Bodies’ sampling methodology and how much time 
they spend on different audit parts. SBP will also assure that report templates are not 
modified by using this portal and will make it easy for SBP to monitor data such as risk 
ratings and overdue reports or non-conformities. 

Accreditation Process 

Organisations  who  would  like  to  be  accredited  to  certify  against  the SBP certification 
standards apply to SBP’s accreditation body ASI (Assurance Services International). This 
is  a  well-known  international  accreditation  body  that,  among  other  schemes,  is  the 
accreditation body for FSC® and RSPO. ASI is a full member of ISEAL Alliance. 

When the Certification Body’s application to ASI is approved, the Certification Body will 
enter  into  an  accreditation  agreement  with  ASI.  ASI  will  then  follow  their  normal 
accreditation procedures. This includes a document review of e.g. the Certification Bodie’s 
quality management system, head office assessment and witness assessment. After this, 
ASI report findings from the assessments, which is reviewed and signed off by technical 
reviewers. If everything is approved, the accreditation is granted. According to ASI, the 
process usually takes between 12-24 months. 

ASI will do annual audits of accredited Certification Bodies, which includes office audits, 
witness audit of auditors and evaluate audit reports. More information about the process 
can be found on ASI’s webpage (https://www.asi-assurance.org/s/apply-for-accreditation). 

There  are  currently  five  Certification  Bodies  accredited  to  SBP  certification.  Different 
Certification Bodies may have different scope for their accreditation. Some Certification 
Bodies do not have Supply Base Evaluation in their scopes, and others have a limited 
number  of countries or all countries included for Supply Base Evaluation. All currently 
accredited  Certification  Bodies  and  their  scopes  can  be  found  on  SBP’s  webpage 
(https://sbp-cert.org/accreditations-and-certifications/accredited-certification-bodies/). 

Scope of this evaluation 

In  this  report,  only  SBP  criteria  are  evaluated,  meaning  we  are  not  evaluating  the 
coverage of the SBP-approved schemes (FSC, PEFC and PEFC-endorsed schemes) in 
this  report. Feedstock or biomass growing in areas not defined as forest are included 
when requirements are assessed in this report. 

The FSC and PEFC schemes are covered in other assessment reports. It is important to 
keep in mind that in cases where weaknesses were found in the FSC or PEFC evaluation 
reports,  this  will  also  affect  the  SBP-system  IF a Biomass Producer has used FSC or 
PEFC certified material as input to the biomass production. If other schemes have been 
used as SBP input (i.e. PEFC-endorsed schemes such as SFI), this is out of scope of this 
Assessment Framework and the input source must be evaluated separately.  

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40.  Overview  of  the  scheme  Standards  used  for  this 

assessment 

Type 

General  

Forest 
Managem ent 

Norm ative 
SBP  Fram ew ork Standard 3: 
Certification  Systems.  Requirements 
for Certification  Bodies 

Instruction  Note  3A: General 
Surveillance  - SBP  requirements  for 
CBs 

Norm ative Interpretations, 
September  2020  

SBP  Certification Tradem ark 
License Agreement 

SBP  Fram ew ork Standard 1: 
Feedstock  Compliance  Standard 

Instruction  Note  1A: Instructions  for 
Biomass  Producers  for the 
development  of Locally Applicable 
Verifiers 

SBP  Fram ew ork Standard 2: 
Verification of SBP-compliant 
Feedstock 

Instruction  Note  2A: Supplier 
Verification Programme  – 
Requirements  for Biomass 
Producers 

Instruction  Note  2B: Supply Base 
Evaluation  Stakeholder  Consultation 
– Requirements  for Biomass 
Producers 

Instruction  Note  2C:  Supply Base 
Report  – Requirements  for Biomass 
Producers SBP  Regional  Risk 
Assessment Procedure,  version 1.1 

Supply  Base Report  Template 
Version 1.3 

Guidance 

https://sbp-cert.org/documents/Standards-
documents/Standards/   

https://sbp-cert.org/documents/Standards-
documents/instruction-documents/   

https://sbp-cert.org/documents/interpretative-
documents/   

Guidance  mentioned  in relation  to Standard  1 is 
included  in the Standard document. 

https://sbp-cert.org/documents/Standards-
documents/Standards/   

https://sbp-cert.org/documents/Standards-
documents/instruction-documents/   

https://sbp-cert.org/documents/interpretative-
documents/ 

Chain of 
Custody 

SBP  Fram ew ork Standard 4: 
Chain  of Custody 

Instruction  Note  4A: SBP  tertiary 
feedstock requirements 

https://sbp-cert.org/documents/Standards-
documents/Standards/   

https://sbp-cert.org/documents/Standards-
documents/instruction-documents/   

https://sbp-cert.org/documents/interpretative-
documents/ 

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41.  Assessment methodology 

The  SBP  scheme  is  assessed  against  the  Preferred  by  Nature  Scheme  Assessment 
Framework (SAF) and Scheme Assessment Procedure (SAP) in order to assess how the 
scheme  covers  relevant  requirements  of  the  EUTR,  and  the  criteria  defined  by  the 
European Commission as the basis for this Study. 

For each indicator, we will have a conclusion that will show the level of conformance of 
the Scheme with the indicator, as follows: 

Conclusion 

Definition 

Covered 

When  available  Scheme  requirements 
and information  - and any impacts 
evidence available  - indicate the 
coverage of the SAF indicator. 

When  available  Scheme  requirements 
and information  - and any impacts 
evidence available  - indicate only 
partial coverage of the SAF indicator.   

Partially Covered 

Alternatively,  special concerns about 
Scheme  Standards,  credibility,  rigor or 
coverage may  exist. 

NOTE:  It is important  to justify the 
partial  coverage and  indicate  w here 
the issues are w hich result in a 
Coverage  conclusion not being  given. 
When  available  Scheme  requirements 
and information  - and any impacts 
evidence available  - indicate that 
there is no coverage of the SAF 
indicator. 

NOTE:  It is important  to justify a no 
coverage conclusion. 
When,  for w hichever reason, the SAF 
indicator  does not apply.   

Not Covered 

Not Applicable 
(N/A) 

Explanation 
Coverage  is the ability  of the Scheme  to 
provide assurance that material  traded via the 
Scheme  has a low  (negligible)  risk of being 
illegally  harvested, traded in line w ith the 
legality  definition  of the EU  Timber  Regulation. 

Partial  Coverage  means  the Scheme  is only 
partly able – or may be compromised  in one or 
more  w ays – to provide assurance that material 
traded via the Scheme  has a low  (negligible) 
risk of being  illegally  harvested, traded in line 
w ith the legality  definition  of the EU  Timber 
Regulation.   

The  Scheme  is not  – or inadequately  – able to 
provide assurance that material  traded via the 
Scheme  has a low  (negligible)  risk of being 
illegally  harvested, traded in line  w ith the 
legality  definition  of the EU  Timber  Regulation.   

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42.  Overview of findings 

Requirements for Certificate 

Requirement Section 
A. 
Holders 
A.1 Legal Requirements at the forest 
lev el 
A.1.1 Rights to harvest timber within 
legally gazetted boundaries 
A.1.2 Payments for harvest rights and 
timber including duties related to timber 
harvesting 
A.1.3 Timber harvesting, including 
environmental and forest legislation 
including forest management and 
biodiversity conservation, where directly 
related to timber harvesting 
A.1.4 Third parties’ legal rights 
concerning use and tenure that are 
affected by timber harvesting 
A.1.5 Trade and customs, in so far as 
the forest sector is concerned 

A.2 Legal requirements for supply 
chain entities 
A.2.1. Legal registration 

A.2.2 Taxes and fees 

Conclusion  Summary 

Partially 
covered 
Partially 
covered 

There are no requirements related to the use of legal methods 
to obtain legal rights to harvest (A.1.1.2.1) 
SBP does not specifically include mention of land area taxes. 
The indicator is considered partially covered (A.1.2.1.1) 

Covered 

All indicators of this criterion are covered by the Scheme  

Partially 
covered 

Partially 
covered 

There is no mention of FPIC in the standards (A.1.4.2.1) 

There is no specific requirement regarding offshore trading and 
transfer pricing in the SBP Standards. Existing requirements are 
considered too general to catch these illegal activities. 
(A.1.5.3.1) 

Covered 

Partially 
covered 

It is not clearly required in the standards to verify the existence 
of legal business registration (A.2.1.1.1). 
There is a requirement for payment of any fees , taxes and 
duties, mentioned in this requirement 

There is requirement for control of sales invoices and for 
payment of any fees and duties, but VAT or other types of 
sales taxes are not explicitly mentioned in these 
requirements (A.2.2.2.1) 

A.2.3 Trade and transport 

Partially 
covered 

transportation documentation is not explicitly mentioned in any 
SBP requirement (A.2.3.2.1) 

A.3 Requirements for material control 
A.3.1 Material control 
A.3.2 Recycled material 
A.4 General requirements for 
Certificate Holders 
A.4.1 Conflict resolution 

Covered 
Covered 
Covered 

Covered 

There is no requirement regarding offshore trading in SBP 
Standards.  Or  
There is no requirement regarding transfer pricing in SBP 
Standards (A.2.3.3.1) 

Requirement only covers material still defined as feedstock 
under the SBP system. Export of biomass containing CITES 
species is not covered (A.2.3.3.2) 

All indicators of this criterion are covered by the Scheme  
All indicators of this criterion are covered by the Scheme  

The indicator for this criterion has been evaluated as Covered, 
based on the scheme normative requirements.  

A.4.2 Corruption 

Covered 

The indicator for this criterion has been evaluated as Covered, 
based on the scheme normative requirements.  

A.5 Quality and procedural 
requirements for Certificate Holders 

A.5.1 Internal procedures for Certificate 
Holders 

Partially 
covered 

There is no SBP requirement after the BP that covers written 
procedures for all requirements. This relies on the SBP-
approved CoC-system and there are no written procedures for 
how SBP approves schemes. (A5.1.1) 

There is a standard revision process ongoing and that the 
requirement to have documented procedures and internal audits 
for all SBP CHs is included in the draft new Standard 4. This 
can be checked from the documents on the SBP website: 
https://sbp-cert.org/documents/consultation-documents/live-
consultations/rdv1-36/ 

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ANNEX 6 : SCHEME ASSESSMENT REPORT – SUSTAINABLE BIOMASS PROGRAM 

A.5.2 Qualification and competence 
A.5.3 Risk based approaches to 
sourcing, trade or production 

Covered 
Partially 
covered 

If the certificate holder is not a Biomass Producer, there is no 
requirement for Certificate Holders to review the proper 
functioning of their own procedures internally and regularly 
(A.5.1.2) 

SBP has no clear procedures on how to recognize other 
certification schemes. This is considered a major gap since 
material from other schemes can enter the supply chain through 
the use of their own DDS (A.5.3.3) It should be mentioned that 
currently SBP only have endorsed FSC and PEFC. 

Requirements for 

B. 
Certification Bodies 
B.1 General Certification Body 
requirements 
B.2 Certification Body requirements for 
auditing and certification 
C. 
Certification Schemes 
C.1 Transparency 
C.2 Scheme & Standard scope 

Requirements for 

C.3 Accreditation and oversight 

C.4 Certification process 

Covered 

All indicators of this criterion are covered by the Scheme  

Covered 

All indicators are met. 

Covered 
Partially 
covered 
  Partially 
covered 

All indicators of this criterion are covered by the Scheme  
In SBP Standards there are no specific requirements addressed 
to a specific country of harvest (C.2.1.1 and C.2.2.1). 
The SBP scheme ensure ASI continuously evaluate CBs’ 
performances, including reporting of non-conformities and 
timelines for follow-up on these. CB’s must follow-up on non-
conformities, or they get suspended. Requirements for non -
conformities are structured in a way that there is a potential risk 
that a non-conformity may represent an infringement of 
legislation and that, as a result, illegal wood may enter the EU 
market without mitigation measures to prevent this from 
occurring for a period of up to 3 or 12 months (C.3.2.2). 

Partially 
covered 

Requirements for non-conformities are structured in a way that 
there is a potential risk that a non-conformity may represent an 
infringement of legislation and that, as a result, wood may enter 
the EU market that could be interpreted as illega l or non-
negligible risk ((C.4.1.2 and C.4.1.2) 

Performance information (Articles and other reliable info) 

This assessment framework also included analysis of information that is publicly available 
and could affect the impact or credibility of the certification scheme. In general, there are 
not many sources mentioning SBP explicitly. One reason is likely that the scheme itself is 
quite young and still fairly small. Most open sources or scientific articles focuses on larger 
schemes such as FSC and PEFC. In many cases, this criticism or impact is also related to 
the  SBP  scheme.  One  reason  is  that  these  schemes  are  accepted  as  input  to  SBP 
biomass  (the  so  called  SBP-approved  schemes).  Secondly,  the  articles  are  often 
highlighting  general  problems  such  as  implementation  of  certification  requirements in 
countries  or  areas  where  corruption  is  high  and  many  functions  and  legality aspects 
related to forest management suffers from traditions in corrupt practices. In this aspect, 
the SBP is as exposed to fraud or practical implementation problems as other accredited 
schemes.  One  example  of  a  recent  report  highlighting  certification problems in forest 
sectors exposed to high corruption is Earthsight’s report “Complicit in Corruption  - How 
billion-dollar firms and EU governments are failing Ukraine’s forests” (2018). 

Even though SBP is a relatively recent scheme, there are some publicly available criticism 
of the system. Most reports focus on the sustainability itself in burning biomass for heat 
and electricity. These types of reports are not considered for this assessment framework 
since the issues reported does not relate to illegality issues, but rather political aspects of 
energy policies. 

Recently, SBP has met some criticism to implementation of its standard re quirements in 
Estonia  and  Latvia  where  the  NGO  Estonian  Fund  for Nature (in association with the 
Latvian Ornithological Society) has accused SBP to accept biomass origin from protected 
areas such as Natura 2000. Few of the presented aspects involves illega lity in this report, 
but most findings relate to sustainability concerns and protection of biodiversity. It should 

722 

 
 
 
 
 
 
 
 
 
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be noted that there are several sources concluding the same criticism, but they all refer to 
the same report written by Estonian Fund for Nature. There are also several responses to 
the report available online. This report also contains criticism against the FSC and PEF C 
schemes. 

There has also been criticism and accusations from TV2 in Denmark concerning illegal 
activities  related  to  biomass  production  for  biomass  imported  from  Brazil  to Denmark 
(2020). These accusations also relate to several certification schemes, but mainly one 
Brazilian company supplying biomass to a Danish importer. 

The NRDC (Natural Resources Defense Council) and the author Debbie Hammel reported 
in 2017 some weaknesses related to the SBP scheme. She found several weaknesses in 
the scheme related to legality and sustainability. The main criticism related to on what 
level  risk  assessments  were  written  (country  level  rather  than a more locally adapted 
level) and who has written the risk assessments or made the locally adapted risk ratings 
(the Biomass Producer themselves). This report also highlights that some of the schemes 
approved for input to SBP does not have standard requirements that fully cover the SBP 
requirements specified in Standard 1. Thus, there is a loophole in the SBP scheme to 
attain the SBP-compliant Biomass status. These are still relevant potential weaknesses. 

In  conclusion,  when  using  this  report  to  mitigate  risks  in  countries  exposed  to  high 
corruption or illegal forestry activities, extra risk mitigation measures beyond certification 
and  the  gaps  found  in  this  report  should  be considered. Issues raised related to risk 
assessments and risk ratings are considered to be more important when SBP has not 
endorsed  any  Regional  Risk  Assessment  (RRA),  but  the  companies  make  their own. 
Many  issues  raised  in  publicly  available  sources  that  relates  to  SBP  are  related  to 
concerns about sustainability issues and not legality. 

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43.  Evaluation 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A. Requirements for Certificate Holders 

Requirements  applicable  to the Certificate  Holders.  These include  requirements  to comply  w ith applicable  legislation,  as w ell as requirements  relevant to ensuring  continued 
performance and integrity  of the operations  – as far as is related to legal compliance. 

A.1 Legal Requirements at the forest level including wood growing in areas outside forest 

This principle  relates to how  the scheme  ensures that Certificate  Holders  comply w ith all  applicable  legislation.  This section relates to requirements  of the Scheme  that applies  to 
Certificate  Holders  - or other entities  subject to the normative  requirements  of the Scheme  (e.g. included  w ithin the scope of a certified due diligence  system) - w ithin the Country 
of Harvest. 

A.1.1 Rights to harvest tim ber within 
legally gazetted boundaries  

Trees growing in areas not defined as forest (i.e. 
w ood from  non-forest land) 

Normative  Interpretations,  September  2020 

Findings 

Covered 

All w oody feedstock, from forest and non-forest 
origins must  meet  the requirements  set out in 
Standard  2. 

Standard  1 

2 Scope 

This document  (SBP  Standard  1. Feedstock 
Compliance  Standard) sets out the principles, 
criteria and indicators to be met  by participating 
Biomass  Producers  (BPs) as part of a Supply  Base 
Evaluation  (SBE).  The requirements  are applicable 
to w oody feedstock used in the production of 
biomass  including  feedstock included  in biomass 

724 

Scheme info 

The  Normative  Interpretation  document  states that 
also biomass  from non-forest origins shall  live up to 
requirements  in Standard 2. Standard  1 states in its 
scope that the standard requirements  are applicable 
to w oody feedstock used in biomass  production. 
Thus, all  requirements  regarding  sourcing of 
biomass  applies  also to w ood that origins from land 
that is not defined as forest land  (e.g. short rotation 
forestry on agricultural  land,  w indbreaks around 
agricultural  land,  w ood from parks or gardens, 
roadside trees or trees in open landscapes). 

Even  though some  requirements  in Standard 1 

 
 
 
 
 
ANNEX 6 : SCHEME ASSESSMENT REPORT – SUSTAINABLE BIOMASS PROGRAM 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

and that used for drying during  the production  of 
biomass. 

Feedstock  shall not be sourced from large  (>1000 
ha) short rotation plantations  that are fully dedicated 
to the production  of biomass  and that w ere 
established  after 1 January 2015. 

states “forest” the requirements  are interpreted  to 
also include  non-forest land  based on the Normative 
Interpretation  and the indicators and guidelines  in 
Standard  1. When  criteria states “forest” the 
indicator  does not specify that it is limited  to forest 
land.  For example: 

Criterion  1.2: The forest ow ner and manager  hold 
legal  use rights to the  forest. 

Indicator  1.2.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that legality  of ow nership and land  use can 
be demonstrated  for the Supply Base. 

Means  of verification and guidance:  Existing 
legislation,  Levels of enforcement,  Documents 
demonstrating  that the BP  is a legally  defined entity, 
Documentation  show ing legal  ow nership patterns in 
the region, level  of enforcement,  records of disputes 
over land tenure,  etc. (in situations  w here customary 
rights govern use and access, these rights are 
clearly identifiable),  and long-term  unchallenged 
use. 

Justification 

Even  though some  requirements  in Standard 1 
states “forest” the requirements  are interpreted  to 
also include  non-forest land  based on the Normative 
Interpretation  and the indicators and guidelines  in 
Standard  1. When  criteria states “forest” the 
indicator  does not specify that it is limited  to forest 
land.  Therefore, all requirements  assessed in this 
framew ork also include  feedstock or biomass  that 

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ANNEX 6 : SCHEME ASSESSMENT REPORT – SUSTAINABLE BIOMASS PROGRAM 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1.1.1  Land tenure 
and 
management 
rights 

A.1.1.1.1.  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  covering land 
tenure rights, including 
customary rights as w ell 
as management  rights.   

Standard  1 

Findings 

Covered 

origin  from non-forest land and the same 
conclusions can be applied  to this source of w ood. 

Principle  1: Biomass  feedstock is legally  sourced 

Scheme info 

Criterion  1.2: The forest ow ner and manager  hold 
legal  use rights to the forest. 

Indicator  1.2.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that legality  of ow nership and land  use can 
be demonstrated  for the Supply Base. 

The  first requirement  in SBP  Standard  1 is that the 
Biomass  Producer  (BP)  know s and has defined their 
supply base, w hich means  that they must  know  
w here the feedstock to biomass  comes  from (1.1). 
Then,  the BP  is obliged  to know  that the forest 
ow ner and manager  hold  the legal  use rights to the 
forest (1.2).  

Criterion  1.3: There is compliance  w ith the 
requirements  of local,  national  and applicable 
international  law s, and the law s applicable  to Forest 
Management. 

Feedstock  for biomass  must  also be compliant  w ith 
local, national  and applicable  international  law s, and 
applicable  forest management  law s (1.3). 

Indicator  1.3.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that feedstock is legally  harvested and 
supplied  and is in compliance  w ith EUTR  legality 
requirements. 

These requirements  are evaluated first through a 
Risk  Assessment w here risks are identified,  and 
then, through risk mitigation  measures.  The BP 
must  show  that risks are mitigated  during  audits and 
have to control and monitor  (internal  audit) that 
suppliers implement  risk mitigation  measures  as 
intended. 

Means  of verification and guidance:  Existing 
legislation,  Level of enforcement,  Interview s w ith 
key staff show  a good know ledge of relevant 
forestry legislation,  BPs  have an up-to-date forest 
legislation/regulations  registry, BPs  make  use of 
public  information  on legal  non-compliance, 
provided by regulatory authorities,  Payments  for 
harvest rights and timber,  including  duties related to 

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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

timber  harvesting,  and Third  parties’  legal rights 
concerning use and tenure that are affected by 
timber  harvesting. 

Justification 

The  Standard has clear requirements  related to 
legislation  covering land tenure rights. The 
means  of verification and guidance  covers the 
practical implementation  of the Standard 
requirements.  The Risk  Assessments investigate 
w here risks are and w here risk mitigation 
measures  must be put in place. 

Standard  1 

Findings 

Covered 

Principle  1: Biomass  feedstock is legally  sourced 

Scheme info 

A.1.1.1.2.  The Scheme 
shall include 
requirements  to ensure 
that licenses, right of 
tenure and 
management  rights, 
have been issued: 

i)  according to the 
legally  prescribed 
procedure, 

Criterion  1.2: The forest ow ner and manager  hold 
legal  use rights to the forest. 

Indicator  1.2.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that legality  of ow nership and land  use can 
be demonstrated  for the Supply Base. 

ii) in compliance  w ith 
third parties' legal  rights 
concerning tenure, 

Criterion  1.3: There is compliance  w ith the 
requirements  of local,  national  and applicable 
international  law s, and the law s applicable  to Forest 
Management. 

iii) specifying the 
legally-gazetted 
boundaries,  and; 

iv) w ith absence of 

Indicator  1.3.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that feedstock is legally  harvested and 
supplied  and is in compliance  w ith EUTR  legality 

727 

The  indicator 1.2.1  requires that “Legality  of 
ow nership and land  use can be demonstrated  for 
the Supply Base”. If this indicator  is not classed as 
low  risk in relevant Risk  Assessment, the risk must 
be mitigated,  and the measure  demonstrated  at the 
audit. 

Examples  of means  of verifications are presented in 
the SBP  indicator  and guidance,  and are: 

  Existing  legislation 
 
  Documents  demonstrating  that the BP  is a 

Levels of enforcement 

legally  defined entity 

  Documentation  show ing legal  ow nership 

patterns in the region,  level of 
enforcement,  records of disputes over land 

 
 
 
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Conclusion 

corrupt practices. 

requirements. 

Criterion  1.4: All applicable  royalties and taxes have 
been paid. 

Indicator  1.4.1:  The BP  has implemented 
appropriate  control systems and procedures to 
verify that payments  for harvest rights and timber, 
including  duties, relevant royalties and taxes related 
to timber  harvesting, are complete  and up to date. 

tenure, etc. In  situations  w here customary 
rights govern use and access, these rights 
are clearly identifiable 
Long term  unchallenged  use 

 
  Payments  for harvest rights and  timber, 

 

including  duties related to timber 
harvesting 
There  should be evidence  that systems are 
in place to ensure forestry operations are 
legal 

The  indicator that mostly  relates to forest legislation 
is 1.3.1.  In the guidance  this indicator  states: 

“Applicable  legislation  includes that in force in the 
country of harvest, covering the follow ing aspects: 
Rights  to harvest timber  w ithin legally  gazetted 
boundaries,  Payments  for harvest rights and timber, 
including  duties related to timber  harvesting, and 
Third  parties’ legal  rights concerning use and tenure 
that are affected by timber  harvesting”. 

Indicator  1.3.1 also mention  that “Risks  of non-
compliance  are greater in areas w ith high  levels of 
corruption relating  to the granting  of harvesting 
permits  and other aspects of the harvesting and 
w ood trade.” This must  be taken  into account w hen 
risks are assessed and described for this (and 
other) indicator. For example,  Transparency 
International’s  Corruption  Perception  Index (CPI)  is 
explicitly  mentioned  in Standard  2 w ere risk ratings 
for Risk  Assessments of indicators in Standard  1 
are described (Standard  2, requirement  11.2). 

Payments  for harvest rights and timber,  including 
duties, relevant royalties and taxes related  to timber 

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Conclusion 

harvesting, are complete  and up  to date.  (1.4.1)  

Examples  of means  of verifications: “BPs  should 
show  records of payments and correspondence w ith 
revenue authorities  to show  payments  are complete 
and up to date.” 

How ever, SBP  point  out in their guidance  that 
certification is not a legal  compliance  audit. 

Justification 

SBP  does not specify all documents  that needs to 
be controlled  during an audit, but the purpose of the 
Risk  Assessment is that risks are pointed  out for the 
relevant supply base and the BPs  can demonstrate 
that these risks are mitigated  in their supply chains. 
Problems  related to corruption is built  into the 
conclusions in the Risk  Assessment. 

A.1.1.1.3  The Scheme 
shall include 
requirements  that 
ensure the existence of 
legal  business 
registration,  and other 
relevant legally  required 
licenses.  

Standard  1 

Findings 

Covered 

Principle  1: Biomass  feedstock is legally  sourced 

Scheme info 

Criterion  1.2: The forest ow ner and manager  hold 
legal  use rights to the forest  

Indicator  1.2.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that legality  of ow nership and land  use 
can be demonstrated  for the Supply Base. 

Criterion  1.3: There is compliance  w ith the 
requirements  of local,  national  and applicable 
international  law s, and the law s applicable  to 

Indicator  1.2.1 requires that “Legality  of ow nership 
and land use can be demonstrated  for the Supply 
Base”. If this indicator is not classed as low  risk in 
relevant Risk  Assessment, the risk must  be 
mitigation  and the measure  demonstrated  at the 
audit. 

Examples  of means  of verifications presented in the 
SBP  indicator and guidance  are: 

Levels of enforcement 

 
  Documents  demonstrating  that the BP  is a 

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Conclusion 

Forest Management. 

Indicator  1.3.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that feedstock is legally  harvested and 
supplied  and is in compliance  w ith EUTR  legality 
requirements. 

SBP  Certification  Trade  Mark  Licence Agreement 

730 

legally  defined entity 

Requirements  regarding  that feedstock shall be 
legally  harvested and supplied  and is in 
compliance  w ith EUTR  legality  requirements 
(1.3.1) also covers the legality  of legally 
registered businesses. There should be evidence 
that systems are in place to ensure forestry 
operations  are legal. 

The  Certification  Trademark  Licence Agreement 
must  be signed by all  certificate holders before 
certificates are issued. This document  contains 
the business registration  number  and details 
about the legal  entity. 

Direct interviews / discussions / Stakeholder  input 

SBP  response: The  SBP  scheme  requires all 
Certificate  Holders  to enter into a Trade Mark 
Licence Agreement  w ith SBP  (Standard 3 clause 
13.4) and certification agreement  w ith a 
Certification  Body (Standard  3 section 13). 
Signing  both documents  include  verification of a 
Certificate  Holder’s  legal  registration  and hence 
SBP  is compliant  in this regard. 

Justification 

The  Risk  Assessments investigate w here risks are 
and w here risk mitigation  measures must  be put in 
place. The  means  of verification and guidance 
covers the practical implementation  of the Standard 
requirements.  There is no clear requirement  related 
to of legal  business registration,  but this is indirectly 
included  in Standard  1 (see indicators in findings) 

 
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Standard reference 

Findings and Justification 

Conclusion 

A.1.1.2  Concession 

licenses 

A.1.1.2.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  regulating 
procedures for the 
issuing of concession 
licenses, including  use 
of legal methods  to 
obtain  concession 
licenses and that 
licenses are covering 
only legally  gazetted 
areas 

for BPs.  For all  certificate holders, SBP  informs that 
they control that all  certificate holders are legally 
registered w hen signing  the trademark  license 
agreement.  The  certification bodies most likely  do 
the same w hen signing  certification agreements  w ith 
certificate applicants. 

Standard  1 

Findings 

Principle  1: Biomass  feedstock is legally  sourced 

Scheme info 

Partially 
Covered 

Criterion  1.2: The forest ow ner and manager  hold 
legal  use rights to the forest. 

Legality  of ow nership and land use can be 
demonstrated  for the Supply Base. (1.2.1) Guidance 
example: 

Indicator  1.2.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that legality  of ow nership and land  use 
can be demonstrated  for the Supply Base. 

Criterion  1.3: There is compliance  w ith the 
requirements  of local,  national  and applicable 
international  law s, and the law s applicable  to 
Forest Management. 

Indicator  1.3.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that feedstock is legally  harvested and 
supplied  and is in compliance  w ith EUTR  legality 
requirements. 

Criterion  1.4: All applicable  royalties and taxes 
have been paid. 

Indicator  1.4.1:  The BP  has implemented 
appropriate  control systems and procedures to 

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  Payments  for harvest rights and timber, 

including  duties related to timber 
harvesting 

Feedstock  is legally  harvested and supplied  and is 
in compliance  w ith EUTR  legality  requirements. 
(1.3.1) There should be evidence that systems are 
in place to ensure forestry operations are legal. 
Guidance:  Applicable  legislation  includes that in 
force in the country of harvest, covering the 
follow ing aspects: 

  Rights  to harvest timber  w ithin legally 

gazetted boundaries 

  Payments  for harvest rights and timber, 

including  duties related to timber 
harvesting 

Payments  for harvest rights and timber,  including 
duties, relevant royalties and taxes related  to 
timber  harvesting,  are complete  and up to date. 
(1.4.1) Indicator:  BPs  should show  records of 

 
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Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1.1.3  Management 

and harvesting 
planning 

A.1.1.3.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  and legal 
obligations  for 
management  planning, 
including  conducting 
forest inventories, 
having a forest 
management  plan and 
related  planning  and 
monitoring. 

verify that payments  for harvest rights and 
timber,  including  duties, relevant royalties and 
taxes related  to timber  harvesting,  are complete 
and up to date. 

payments  and correspondence w ith revenue 
authorities  to show  payments are complete  and 
up to date. 

Justification 

SBP  does not specify all documents  that needs to 
be controlled  during an audit, but the purpose of the 
Risk  Assessment is that risks are pointed  out for the 
relevant supply base and the BPs  can demonstrate 
that these risks are mitigated  in their supply chains. 
. 

Standard  1 

Findings 

Covered 

Principle  1: Biomass  feedstock is legally  sourced 

Scheme info 

Criterion  1.3: There is compliance  w ith the 
requirements  of local,  national  and applicable 
international  law s, and the law s applicable  to 
Forest Management 

Indicator  1.3.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that feedstock is legally  harvested and 
supplied  and is in compliance  w ith EUTR  legality 
requirements. 

Principle  2: Biomass  feedstock is sustainably 
sourced 

1.3.1: There  should be evidence that systems are in 
place to ensure forestry operations are legal 

Guidance  examples  are the follow ing aspects are 
covered if applicable  in the country of harvest: 
Environmental  impacts  (w ater and soil protection). 

Guidance  for 2.2.2: “Potential  impacts  of feedstock 
harvesting on soil should be identified,  w ith 
mitigation  measures  implemented  in the field as 
necessary. Impacts  should be monitored  and there 
should be a mechanism  to feed monitoring  results 
back into operational  practice.” 

Criterion  2.2: Management  of the forest ensures 
that ecosystem function is assessed and 
maintained,  through  both the conservation/set-
aside of key ecosystems or habitats in their 

2.3.1 “Management  of the forest ensures that 
productivity is maintained.  Analysis show s that 
feedstock harvesting does not exceed the long-term 
production  capacity of the forest, avoids significant 

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Conclusion 

natural  state, and the maintenance  of existing 
ecosystem functions throughout  the forest 

2.2.2: The  BP  has implemented  appropriate 
control systems and procedures for verifying that 
feedstock is sourced from forests w here 
management  maintains  or improves  soil quality 

Criterion  2.3: Management  of the forest ensures 
that productivity is maintained 

Indicator  2.3.1:  Analysis show s that feedstock 
harvesting does not exceed the long-term 
production  capacity of the forest, avoids 
significant negative  impacts  on forest productivity 
and ensures long-term  economic  viability. 
Harvest levels are justified by inventory and 
grow th data. 

negative  impacts  on forest productivity and ensures 
long-term  economic  viability.  Harvest levels are 
justified by inventory and grow th data.” 

The  SBP  does not specifically require forest 
management  plans, inventories,  etc., but that the 
carbon stock is maintained  over time,  w hich 
indicates  that forest stands are regenerated,  and the 
forest is not overused. There are also several 
indicators related  to biodiversity  and environmental 
considerations  in Standard 1. 

Justification 

In  supply bases w here forest management  plans 
are required  by the  legislation,  this is covered by the 
SBP  requirements.  If there is a risk of this not being 
w ell-implemented,  it should be detected  during the 
Risk  Assessment and risk mitigation  measures  must 
be put in place to control the risk. Where pollution 
control, use of pesticides/herbicides  and emissions 
to air/w ater is a legal  requirement  during  forest 
operations,  this is covered under indicator 1.3.1. 
Soil  erosion, is covered as described above under 
indicators 1.3.1 and 2.2.2. 

A.1.1.3.2  The Scheme 
shall include 
requirements  that all 
legally  required 
planning  documents 
have been approved 
prior to implementation 

Standard  1 

Findings 

Covered 

Principle  1: Biomass  feedstock is legally  sourced 

Scheme info 

Criterion  1.3: There is compliance  w ith the 
requirements  of local,  national  and applicable 
international  law s, and the law s applicable  to 

Law s applicable  to forest management  is covered 
by SBP  requirements.  If specific risk is raised for 
this indicator, the BP  must  show  method  and result 

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Findings and Justification 

Conclusion 

of forest harvesting 
activities. 

Forest Management 

for risk mitigation. 

Indicator  1.3.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that feedstock is legally  harvested and 
supplied  and is in compliance  w ith EUTR  legality 
requirements. 

The  guidance for indicator 1.3.1 states “applicable 
legislation  includes  that in force in the country of 
harvest and also acknow ledge the higher  risks in 
areas w ith a high level of corruption”. 

Guidance:  “There  should be evidence that 
systems are in place  to ensure forestry 
operations  are legal”.  Aspects of “timber 
harvesting, including  forest management  and 
silvicultural  activities” are included  as examples 
of applicable  legislation  for this indicator. 

Justification 

In  countries w here forest management  plans 
including  documentation  of it is required by law , this 
is covered by the Risk  Assessment and Standard. 
This w ould include  all necessary approvals prior to 
harvest. 

A.1.1.4  Harvesting 

permits 

A.1.1.4.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  regulating 
the issuing of 
harvesting permits, 
licenses or other legal 
documents  required  for 
specific harvesting 
operations. 

Standard  1 

Findings 

Covered 

Principle  1: Biomass  feedstock is legally  sourced 

Scheme info 

Criterion  1.2: The forest ow ner and manager  hold 
legal  use rights to the forest. 

Indicator  1.2.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that legality  of ow nership and land  use 
can be demonstrated  for the Supply Base. 

Legality  of ow nership and land use can be 
demonstrated  for the Supply  Base. (1.2.1) 
Guidance:  For example,  “payments  for harvest 
rights and timber,  including  duties related to timber 
harvesting”. 

Feedstock  is legally  harvested and supplied  and is 
in compliance  w ith EUTR  legality  requirements. 

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Conclusion 

Criterion  1.3: There is compliance  w ith the 
requirements  of local,  national  and applicable 
international  law s, and the law s applicable  to 
Forest Management. 

Indicator  1.3.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that feedstock is legally  harvested and 
supplied  and is in compliance  w ith EUTR  legality 
requirements. 

Criterion  1.4: All applicable  royalties and taxes 
have been paid. 

Indicator  1.4.1:  The BP  has implemented 
appropriate  control systems and procedures to 
verify that payments  for harvest rights and 
timber,  including  duties, relevant royalties and 
taxes related  to timber  harvesting,  are complete 
and up to date. 

735 

(1.3.1) There should be evidence that systems are 
in place to ensure forestry operations are legal. 
Guidance:  Applicable  legislation  includes that in 
force in the country of harvest, covering the 
follow ing aspects: 

  Rights  to harvest timber  w ithin legally 

gazetted boundaries 

  Payments  for harvest rights and timber, 

including  duties related to timber 
harvesting 

Indicator  1.3.1 also mention  that “Risks  of non-
compliance  are greater in areas w ith high  levels of 
corruption relating  to the granting  of harvesting 
permits  and other aspects of the  harvesting and 
w ood trade.” This must  be taken  into account w hen 
risks are assessed and described for this (and 
other) indicator. For example,  Transparency 
International  Corruption  Perception  Index (CPI)  is 
explicitly  mentioned  in Standard  2 w ere risk ratings 
for Risk  Assessments of indicators in Standard  1 
are described. 

Payments  for harvest rights and timber,  including 
duties, relevant royalties and taxes related  to timber 
harvesting, are complete  and up to date.  (1.4.1) 
Indicator:  BPs  should show  records of payments 
and correspondence w ith revenue authorities  to 
show  payments are complete  and up to date. 

SBP  recognizes that “Risks of non-compliance 
are greater in areas w ith high  levels of corruption 
relating  to the granting  of harvesting permits  and 
other aspects of the harvesting and w ood trade.” 
This w ould be included  in the Risk  Assessment 

 
 
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Standard reference 

Findings and Justification 

Conclusion 

and risk mitigation  measures shall  be in place 
during audits. 

Justification 

"applicable  local, national  and international 
legislation  on forest management,  including  but not 
limited  to forest management  practices" could not 
possibly avoid including  harvesting licenses, 
therefore w e conclude the requirement  is covered.  

A.1.2 Paym ents for harvest rights and 
tim ber including duties related to tim ber 
harvesting 

A.1.2.1  Payment  of 
royalties and 
harvesting fees 

A.1.2.1.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  covering 
payment  of all legally 
required forest 
harvesting-specific fees 
such as royalties, 
stumpage  fees and 
other volume-based 
fees, as w ell as land 
area taxes or fees. 

Standard  1 

Findings 

Principle  1: Biomass  feedstock is legally  sourced 

Scheme info 

Partially 
Covered 

Criterion  1.2: The forest ow ner and manager  hold 
legal  use rights to the forest. 

Indicator  1.2.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that legality  of ow nership and land  use 
can be demonstrated  for the Supply Base. 

Criterion  1.3: There is compliance  w ith the 
requirements  of local,  national  and applicable 
international  law s, and the law s applicable  to 
Forest Management. 

Legality  of ow nership and land use can be 
demonstrated  for the Supply Base (1.2.1). Guidance 
example:  “payments for harvest rights and timber, 
including  duties related to timber  harvesting”. 

Feedstock  is legally  harvested and supplied  and is 
in compliance  w ith EUTR  legality  requirements 
(1.3.1). There should  be evidence that systems are 
in place to ensure forestry operations are legal. 
Guidance:  Applicable  legislation  includes that in 
force in the country of harvest, covering the 
follow ing aspects: 

Indicator  1.3.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that feedstock is legally  harvested and 

  Rights  to harvest timber  w ithin legally 

gazetted boundaries 

  Payments  for harvest rights and timber, 

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Conclusion 

supplied  and is in compliance  w ith EUTR  legality 
requirements. 

including  duties related to timber 
harvesting 

Criterion  1.4: All applicable  royalties and taxes 
have been paid. 

Indicator  1.4.1:  The BP  has implemented 
appropriate  control systems and procedures to 
verify that payments  for harvest rights and 
timber,  including  duties, relevant royalties and 
taxes related  to timber  harvesting,  are complete 
and up to date. 

The  BP  is responsible  to have a control system to 
control that payments  for harvest rights and timber, 
including  duties, relevant royalties and taxes related 
to timber  harvesting, are complete  and up to date. 
Indicator  1.4.1:  BPs should  show  records of 
payments  and correspondence w ith revenue 
authorities  to show  payments are complete  and up 
to date. 

SBP  recognizes that “Risks of non-compliance 
are greater in areas w ith high  levels of corruption 
relating  to the granting  of harvesting permits  and 
other aspects of the harvesting and w ood trade.” 
This w ould be included  in the Risk  Assessment 
and risk mitigation  measures shall  be in place 
and controlled  at audits. 

Justification 

SBP  does not specifically include  mention  of land 
area taxes. The indicator  is considered partially 
covered. 

A.1.2.2  Value-added 

taxes and other 
sales taxes 

A.1.2.2.2  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  covering 
different types of sales 
taxes that apply to the 
material  being  sold, 
including  selling 
material  as grow ing 

Standard  1 

Findings 

Covered 

Principle  1. Biomass  feedstock is legally  sourced 

Scheme info 

Criterion  1.3: There is compliance  w ith the 
requirements  of local,  national  and applicable 
international  law s, and the law s applicable  to 
Forest Management. 

Indicator  1.3.1:  The BP  has implemented 

Indicator  1.3.1 deals w ith compliance  to local and 
national  legislation  w hich covers all relevant 
aspects to sales and purchases of feedstock. The 
indicator  refers to supplied  feedstock in a general 
w ay but refer to EUTR  w hich covers VAT and 

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Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

forest (standing  stock 
sales). 

appropriate  control systems and procedures to 
ensure that feedstock is legally  harvested and 
supplied  and is in compliance  w ith EUTR  legality 
requirements. 

Criterion  1.4: All applicable  royalties and taxes 
have been paid. 

Indicator  1.4.1:  The BP  has implemented 
appropriate  control systems and procedures to 
verify that payments  for harvest rights and 
timber,  including  duties, relevant royalties and 
taxes related  to timber  harvesting,  are complete 
and up to date. 

sales taxes. 

Indicator  1.4.1 deals w ith taxes and duties  in a 
general  w ay. There are no specific requirement 
or guidance  related to VAT and sales taxes.  

Examples  of means  of verification: “Records of 
payments  and correspondence w ith revenue 
authorities  show  payments are complete  and up 
to date.” 

Justification 

The  feedstock compliance  standard (1) has a risk-
based approach. The Risk  Assessment for relevant 
region should  have specified any risks related  to 
different types of sales taxes. If risks are identified, 
risks must  be mitigated  by the BP. 

A.1.3 Tim ber harvesting, including 
environm ental and forest legislation 
including forest m anagement and 
biodiversity conservation, w here directly 
related to tim ber harvesting 

A.1.3.1  Timber 

harvesting 
regulations 

A.1.3.1.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legal  obligations  for 
harvesting techniques 
and technology 
including  timing  of 

Standard  1 

Findings 

Covered 

Principle  1: Biomass  feedstock is legally  sourced 

Scheme info 

Criterion  1.3: There is compliance  w ith the 
requirements  of local,  national  and applicable 
international  law s, and the law s applicable  to 
Forest Management. 

Feedstock  is legally  harvested and supplied  and is 
in compliance  w ith EUTR  legality  requirements 
(1.3.1).  

Guidance:  There  should be evidence that systems 

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Conclusion 

harvest, selective 
cutting, shelter w ood 
regeneration,  clear 
felling,  transport of 
timber  from felling  sites 
and seasonal limitations 
etc. 

This includes  the mis-
use of salvaging 
permits  or other specific 
ministerial  permits,  w ith 
the intention  of 
circumventing  harvest 
regulations 

Indicator  1.3.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that feedstock is legally  harvested and 
supplied  and is in compliance  w ith EUTR  legality 
requirements. 

Principle  2: Biomass  feedstock is sustainably 
sourced 

Criterion  2.3: Management  of the forest ensures 
that productivity is maintained 

Indicator  2.3.1:  Analysis show s that feedstock 
harvesting does not exceed the long-term 
production  capacity of the forest, avoids 
significant negative  impacts  on forest productivity 
and ensures long-term  economic  viability. 
Harvest levels are justified by inventory and 
grow th data. 

are in place to ensure forestry operations  are legal. 
Applicable  legislation  includes  that in force in the 
country of harvest, covering the follow ing aspects: 

  Rights  to harvest timber  w ithin legally 

gazetted boundaries 

  Payments  for harvest rights and timber, 

including  duties related to timber 
harvesting 
Timber  harvesting, including  forest 
management  and silvicultural  activities 

 

This should  be verified through, for example, 
“existing legislation,  interview s w ith key staff show  a 
good know ledge of relevant forestry legislation,  BPs 
have an up-to-date  forest legislation/regulations 
registry, and level of enforcement”. 

Examples  of means  of verification for 2.3.1: 
“Harvesting  records, inventory and grow th data 
and yield calculations  demonstrate  that biomass 
feedstock harvesting rates are not having 
significant negative  impacts  on forest productivity 
and long-term  economic  viability,  and 
Documentation  of Operational  Practice.” 

Justification 

The  Risk  Assessment for relevant region  should 
have specified any risks related to legal obligations 
related  to different types of forest management 
systems. If risks are identified,  risks must  be 
mitigated  by the BP. 

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Standard reference 

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Conclusion 

A.1.3.1.2  The Scheme 
shall include 
requirements  to control 
potential  illegal  activities 
by third parties w ithin 
the area managed  by 
the operation. 

Standard  1 

Principle  2: Biomass  feedstock is sustainably 
sourced 

Criterion  2.4: Management  of the forest ensures 
that forest ecosystem health  and vitality is 
maintained 

2.4.3: The  BP  has implemented  appropriate 
control systems and procedures for verifying that 
there is adequate  protection  of the forest from 
unauthorised  activities,  such as illegal  logging, 
mining  and encroachment 

740 

Misuse  of salvaging  permits  or other specific 
ministerial  permits  are results of corruption and shall 
be included  w hen rating risks related  to the 
indicators above in the Risk  Assessment. 

Findings 

Scheme info 

Covered 

2.4.3 Guidance:  “Where the forest ow ner or 
management  organisation  is not legally  able  to 
protect the forest fully, there must be a system for 
w orking w ith appropriate  regulatory bodies to 
identify, report, control and discourage 
unauthorised  activity w ithin the forest.  

Where illegal/unauthorised  activities  are 
detected, appropriate  action  should be taken. 

Control  systems and procedures must  firstly 
stipulate  the adequate  protection measures  for 
the particular forest type and region, and 
secondly, verify that these are being 
implemented. 

Justification 

The  Risk  Assessment for relevant region  should 
have specified risks related  to unauthorised 
activities in the area. There is no specified area 
managed  by the operation  in the SBP  system, but a 
supply base w here feedstock is sourced from. If 
risks are identified  in the supply base, risks must be 

 
 
 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1.3.2  Protected  sites 

and species 

A.1.3.2.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  related  to 
protected areas as w ell 
as protected, rare, or 
endangered  species, 
including  their habitats 
and potential  habitats. 

mitigated  by the BP. 

Standard  1 

Findings 

Covered 

Principle  1: Biomass  feedstock is  legally  sourced 

Scheme info 

Criterion  1.3: There is compliance  w ith the 
requirements  of local,  national  and applicable 
international  law s, and the law s applicable  to 
Forest Management. 

Indicator  1.3.1:  The BP  has implemented 
appropriate  control systems and procedures  to 
ensure that feedstock is legally  harvested and 
supplied  and is in compliance  w ith EUTR  legality 
requirements. 

Principle  2: Biomass  feedstock is sustainably 
sourced 

Criterion  2.2: Management  of the forest ensures 
that ecosystem function is assessed and 
maintained,  through  both the conservation/set-
aside of key ecosystems or habitats in their 
natural  state, and the maintenance  of existing 
ecosystem functions throughout  the forest 

1.3.1 SBP  means  of verification can be: “Level of 
enforcement  of existing legislation,  public 
information,  interview  w ith key staff related to 
relevant legislation,  up-to-date  register of 
regulations”,  etc. 

SBP  guidance suggest: “Biodiversity conservation, 
(including  rare, threatened and endangered  species 
and ecosystems)”. 

Examples  of Means  of Verification (2.2.1 and 2.2.3): 
“Regional  Best Management  Practices, Supply 
contracts, Assessment of potential  impacts  at 
operational  level, Assessment of measures  to 
minimise  impacts,  Monitoring  results, and Publicly 
available  information  on protecting the values 
identified,  Maps,  Standard  Operating  Procedures, 
Codes  of Practice  and monitoring  records indicate 
that appropriate  safeguards are implemented.” 

Indicator  2.2.1:  The BP  has implemented 
appropriate  control systems and procedures to 
verify that feedstock is sourced from forests w here 
there is appropriate  assessment of impacts,  and 
planning,  implementation  and monitoring  to 

In  countries w here this requirement  is applicable 
and exposed to risks this w ould be addressed in the 
Risk  Assessment. After this, any risks w ould need a 
system for mitigation  measures  that w ould be 

Justification 

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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

minimise  them. 

Indicator  2.2.3:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that key ecosystems and habitats  are 
conserved or set aside in their natural  state. 

Standard  1 

Principle  2: Biomass  feedstock is  sustainably 
sourced 

Criterion  2.1: Management  of the forest ensures 
that features and species of outstanding  or 
exceptional  value are identified  and protected 

Indicator  2.1.1:  The BP  has implemented 
appropriate  control systems and procedures for 
verifying that forests and other areas w ith high 
conservation value in the Supply Base are 
identified  and mapped. 

A.1.3.2.2  Requirements 
that ensure compliance 
w ith legislation  related 
to protected areas and 
habitats,  shall include 
that the identification  of 
protected areas is 
conducted according to 
the legal  requirements. 

742 

controlled  and accepted during audits. To  protect 
cultural/historical  remnants  w ould be included  under 
1.3.1 if defined by relevant law s. 

Findings 

Scheme info 

Covered 

Examples  of means  of verification (2.1.1): 
”Internet  research, GIS  maps of HCV  areas, 
Interview s, Regional,  publicly available  data from 
a credible  third party, and The  existence of a 
strong legal  framew ork in the region.” 

Guidance  on sources of information:  “The High 
Conservation  Value Netw ork 
(http://w ww.hcvnetwork.org/), IUCN 
(http://w ww.iucnredlist.org/) , SFI  Section  6: 
Guidance  to SFI  2015-2019  Standard,  January 6. 
2014 Forests w ith Exceptional  Conservation 
Value (http://w ww.sfiprogram.org/files/pdf/draftsfi-
2015-2019-Standard-section-6/),  NatureServe 
(http://w ww.natureserve.org/), and The  Global 
Forestry Risk  Register 
(http://w ww.globalforestregistry.org/).  

Justification 

The  Risk  Assessment for relevant region  shall 

 
 
 
 
 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1.3.3  Environmental 
requirements 

A.1.3.3.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  related  to 
environmental  impact 
assessment in 
connection  w ith 
harvesting, acceptable 
levels of damage  and 
disturbance of buffer 
resources, 
establishment  of buffer 
zones (e.g. along 
w atercourses, open 
areas, breeding  sites), 
maintenance  of retained 
trees on felling sites, 
seasonal limitations  on 
harvesting, and 
environmental 
requirements  for forest 
machinery. 

specify risks related  to areas w ith high conservation 
values. If risks are identified  in the supply base, 
risks must  be mitigated  by the BP. 

Standard  1 

Findings 

Covered 

Principle  1: Biomass  feedstock is legally  sourced 

Scheme info 

Criterion  1.3: There is compliance  w ith the 
requirements  of local,  national  and applicable 
international  law s, and the law s applicable  to 
Forest Management. 

Indicator  1.3.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that feedstock is legally  harvested and 
supplied  and is in compliance  w ith EUTR  legality 
requirements. 

Principle  2: Biomass  feedstock is sustainably 
sourced 

Criterion  2.2: Management  of the forest ensures 
that ecosystem function is assessed and 
maintained,  through  both the conservation/set-
aside of key ecosystems or habitats in their 
natural  state, and the maintenance  of existing 
ecosystem functions throughout  the forest 

Indicator  2.2.1:  The BP  has implemented 
appropriate  control systems and procedures to 
verify that feedstock is sourced from forests 
w here there is appropriate  assessment of 

743 

Guidance  1.3.1:  “There should be evidence that 
systems are in place to ensure forestry operations 
are legal”.  Applicable  legislation  covers, for 
example,  “Environmental  impacts (w ater and soil 
protection)”. 

Examples  of means  of verification for 2.2.1: 
“Regional  Best Management  Practices, Supply 
contracts, Assessment of potential  impacts  at 
operational  level, Assessment of measures  to 
minimise  impacts,  Monitoring  results.” 

Guidance  includes  w hat happens outside of the 
area of operation,  e.g. dow nstream. 

Guidance  on 2.2.2: “Potential  impacts  of 
feedstock harvesting on soil should be identified, 
w ith mitigation  measures  implemented  in the field 
as necessary. Impacts  should be monitored  and 
there should be a mechanism  to feed monitoring 
results back into operational  practice. 

BPs  may require suppliers and forest ow ners to 
adopt specific Best Management  Practices  and to 
be certified for certain tasks. These should be 
specified in purchasing  or procurement  policies.” 

 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1.3.4  Health  and 

safety 

A.1.3.4.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
Health  & Safety 
legislation. 

impacts,  and planning,  implementation  and 
monitoring  to minimise  them. 

Indicator  2.2.2:  The BP  has implemented 
appropriate  control systems and procedures for 
verifying that feedstock is sourced from forests 
w here management  maintains  or improves  soil 
quality. 

Standard  1 

Principle  2: Biomass  feedstock is sustainably 
sourced 

Criterion  2.8: Appropriate safeguards are in place to 
protect the health  and safety of forest w orkers 

Indicator  2.8.1:  The BP  has implemented 
appropriate  control systems and procedures for 
verifying that appropriate  safeguards are put in 
place to protect the health  and safety of forest 
w orkers. 

Criterion  2.7: The basic labour  rights of forest 
w orkers are safeguarded 

Indicator  2.7.1:  The BP  has implemented 
appropriate  control systems and procedures for 
verifying that Freedom  of Association and the 
effective recognition  of the right to collective 

744 

Justification 

The  Risk  Assessment for relevant region  shall 
specified risks related to environmental  impact  in 
connection  to harvest. If risks are identified  in the 
supply base, risks must be mitigated  by the BP,  but 
BPs  must alw ays follow  the requirements  in 
Standard  1 even though they are classified as low  
risk. 

Findings 

Scheme info 

Covered 

Examples  of means  of verification (2.8.1): 
Existing  legislation,  Course curricula from safety 
trainings,  Training  records, Personal  Protective 
Equipment  available  to w orkers at job sites, 
Records of BPs’  field inspections and Safety Risk 
Assessments. 

In  addition,  the ILO  conventions are mentioned  in 
several places in Standard  1. For example,  in 
relation  to indigenous  and tribal peoples’  rights 
(Criterion  2.5), and requirements  relayed to the 
basic labour  rights of forest w orkers (Criterion 
2.7). 

The  SBP  Standard  1 covers all types of forest 
w orkers. Guidance  for indicator  2.7.1: “In this 
Standard  the term “forest w orkers” includes 
contractors.” 

 
 
 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

bargaining  are respected. 

A.1.3.5  Legal 

employment 

Justification 

The  Risk  Assessment for relevant region  shall 
specified risks related to health  and safety 
legislation.  If risks are identified  in the supply  base, 
risks must  be mitigated  by the BP. 

A.1.3.5.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  for 
employment  of 
personnel  involved in 
harvesting (and in-
forest processing) 
activities including  but 
not limited  to 
requirements  for: 
contracts and w orking 
permits,  obligatory 
insurances, certificates 
of competence  and 
other training 
requirements,  and 
payment  of social and 
income  taxes.  

Standard  1 

Principle  2: Biomass  feedstock is sustainably 
sourced 

Criterion  2.7: The basic labour  rights of forest 
w orkers are safeguarded 

Findings 

Scheme info 

Covered 

All legislation  regarding employment  is covered by 
criteria under 2.7 and any risks should be caught in 
the Risk  Assessment.  

Indicator  2.7.1:  The BP  has implemented 
appropriate  control systems and procedures for 
verifying that Freedom  of Association and the 
effective recognition  of the right to collective 
bargaining  are respected. 

Guidance  examples:  Minimum  requirements  for pay 
and employment  conditions  should be based on 
local best practice (as defined and ratified by 
relevant employers’  associations and trade unions) 
even if this exceeds legal  minimum  levels. 

Indicator  2.7.2:  The BP  has implemented 
appropriate  control systems and procedures for 
verifying that feedstock is not supplied  using any 
form of compulsory  labour. 

Indicator  2.7.3:  The BP  has implemented 
appropriate  control systems and procedures to 
verify that feedstock is not supplied  using child 
labour. 

Examples  of means  of verifications: Existing 
legislation,  Level of enforcement,  Employment 
contracts, Company  policies,  Interview s w ith HR, 
Interview s w ith staff, Supply contracts, Records of 
BPs  field inspections, and Payroll  records. 

Justification 

Indicator  2.7.4:  The BP  has implemented 
appropriate  control systems and procedures for 
verifying that feedstock is not supplied  using 

Although  many of the requirements  pointed  out 
under this criterion are not explicitly mentioned  in 
the SBP  indicator  guidance,  risks related  to legal 

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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1.3.5.2  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  for minimum 
w orking age and 
minimum  age for 
personnel  involved in 
hazardous w ork, 
legislation  against 
forced and compulsory 
labour,  and 
discrimination  and 
legislation  allow ing f or 
freedom of association. 

labour w hich is discriminated  against in respect 
of employment  and occupation. 

Indicator  2.7.5:  The BP  has implemented 
appropriate  control systems and procedures for 
verifying that feedstock is supplied  using labour 
w here the pay and employment  conditions  are 
fair and meet,  or exceed, minimum  requirements. 

Standard  1 

Principle  2: Biomass  feedstock is sustainably 
sourced 

Criterion  2.7: The basic labour  rights of forest 
w orkers are safeguarded 

Indicator  2.7.1:  The BP  has implemented 
appropriate  control systems and procedures for 
verifying that Freedom  of Association and the 
effective recognition  of the right to collective 
bargaining  are respected. 

Indicator  2.7.2:  The BP  has implemented 
appropriate  control systems and procedures for 
verifying that feedstock is not supplied  using any 
form of compulsory  labour. 

Indicator  2.7.3:  The BP  has implemented 
appropriate  control systems and procedures to 
verify that feedstock is not supplied  using child 
labour. 

Indicator  2.7.4:  The BP  has implemented 
appropriate  control systems and procedures for 

746 

employment  are covered by criterion 2.7. The Risk 
Assessment shall  address any risks related  to this 
w ithin the supply base and these risks must be 
mitigated  by the BP. 

Findings 

Scheme info 

Minimum  age: 

Covered 

Indicator  2.7.3:  The BP  has implemented 
appropriate  control systems and procedures to 
verify that feedstock is not supplied  using child 
labour. 

Guidance:  ILO  Convention  138 & Recommendation 
146 (Minimum  Age and Recommendation). 

Forced and compulsory  labour: 

Indicator  2.7.2:  The BP  has implemented 
appropriate  control systems and procedures f or 
verifying that feedstock is not supplied  using any 
form of compulsory  labour. 

Guidance:  ILO  Conventions  29 and 105 (Forced & 
Bonded  Labour) 

Discrimination: 

Indicator  2.7.4:  The BP  has implemented 

 
 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

verifying that feedstock is not supplied  using 
labour w hich is discriminated  against in respect 
of employment  and occupation. 

747 

appropriate  control systems and procedures for 
verifying that feedstock is not supplied  using labour 
w hich is discriminated  against in respect of 
employment  and occupation. 

Guidance:  ILO  Conventions  100 (Equal 
remuneration  for male  and female  w orkers for w ork 
of equal value) and 111 (Discrimination) 

Freedom  of association: 

Indicator  2.7.1:  The BP  has implemented 
appropriate  control systems and procedures for 
verifying that Freedom  of Association and the 
effective recognition  of the right to collective 
bargaining  are respected. 

Guidance  (2.7.1): ILO  Declaration  on Fundamental 
Principles  and Rights  at Work  (1998) based on the 
eight  ILO  Core Labour Conventions,  ILO 
Convention  98 (Right  to Collective  Bargaining),  ILO 
Convention  87 (Freedom  of Association), and ILO 
Convention  135 (Workers Representatives 
Convention. 

Means  of verification for 2.7.1-2.7.4:  Existing 
legislation,  Level of enforcement,  Employment 
contracts, Company  policies,  Interview s w ith HR, 
Interview s w ith staff  Supply contracts, Records of 
BPs  field inspections, Monitoring  records, 
Operational  assessment of measures designed  to 
minimise  impacts on the values identified,  Payroll 
records and Company  policies indicating  that the 
requirements  are met. 

 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

Guidance  for 2.7.1-2.7.4:  The follow ing ILO 
conventions have not been  ratified in all  countries. 
The  Indicator  must be met  in all countries, w hether 
the ILO  conventions are ratified or not. 

Justification 

The  Risk  Assessment for relevant region  shall 
specified risks related to employment  legislation. 
If risks are identified  in the supply base, risks 
must  be mitigated  by the BP. 

A.1.4 Third parties’ legal rights 
concerning use and tenure that are 
affected by tim ber harvesting 

A.1.4.1  Customary 

rights 

A.1.4.1.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
respect for customary 
tenure rights relevant to 
forest harvesting 
activities. 

Standard  1 

Principle  2: Biomass  feedstock is sustainably 
sourced 

Criterion  2.5: Management  of the forest ensures 
that legal,  customary and traditional  tenure and use 
rights of indigenous  peoples and local communities 
related  to the forest, are identified,  documented  and 
respected. 

Indicator  2.5.1:  The BP  has implemented 
appropriate  control systems and procedures for 
verifying that legal,  customary and traditional  tenure 
and use rights of indigenous  people  and local 
communities  related  to the forest, are identified, 
documented  and respected. 

748 

Findings 

Scheme info 

Covered 

Means  of verification for indicator 2.5.1: Customary 
and traditional  tenure and use rights are identified 
and documented,  Interview s w ith indigenous 
peoples,  local communities  and other stakeholders, 
indicate  that their rights are being respected, 
Appropriate mechanisms  exist to resolve disputes, 
and Agreements  exist regarding  these rights. 

Means  of verification for indicator 2.5.2: 
Interview s w ith local communities  and other 
stakeholders  indicate  that subsistence needs are 
not endangered,  and Agreements  exist on 
resource rights, w here these impact  on the needs 

 
 
 
 
 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1.4.1.2  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legal  obligations 
concerning benefit 
sharing they have 
negotiated  w ith 
communities  or 
customary users. E.g. 
social agreements  or 
social responsibility 
agreements  or cahier 
de charges, dependent 
on the country. 

Indicator  2.5.2:  The BP  has implemented 
appropriate  control systems and procedures for 
verifying that production  of feedstock does not 
endanger  food, w ater supply or subsistence means 
of communities,  w here the use of this specific 
feedstock or w ater is essential  for the fulfilment  of 
basic needs. 

of communities 

Justification 

The  Risk  Assessment for relevant region  shall 
specified risks related to customary tenure rights. 
If risks are identified  in the supply base, risks 
must  be mitigated  by the BP. 

Standard  1 

Principle  2: Biomass  feedstock is sustainably 
sourced 

Criterion  2.5: Management  of the forest ensures 
that legal,  customary and traditional  tenure and use 
rights of indigenous  peoples and local communities 
related  to the forest, are identified,  documented  and 
respected. 

Indicator  2.5.1:  The BP  has implemented 
appropriate  control systems and procedures for 
verifying that legal,  customary and traditional  tenure 
and use rights of indigenous  people  and local 
communities  related  to the forest, are identified, 
documented  and respected. 

Indicator  2.5.2:  The BP  has implemented 
appropriate  control systems and procedures for 
verifying that production  of feedstock does not 
endanger  food, w ater supply or subsistence means 
of communities,  w here the use of this specific 
feedstock or w ater is essential  for the fulfilment  of 

749 

Findings 

Scheme info 

Covered 

Means  of verification for indicator 2.5.1: Customary 
and traditional  tenure and use rights are identified 
and documented,  Interview s w ith indigenous 
peoples,  local communities  and other stakeholders, 
indicate  that their rights are being respected, 
Appropriate mechanisms  exist to resolve disputes, 
and agreements  exist regarding these rights. 

Guidance:  “Indigenous  people’s  and local 
communities’  legal  rights concerning use and 
tenure, w hich are affected by timber  harvesting, 
must  be identified,  and mechanisms  put in place to 
ensure these rights are respected. The requirement 
includes ILO  convention 169, w hich relates to the 
rights of indigenous  and tribal peoples. 

Appropriate mechanisms  should be in place to 
allow : Resolution  of disputes over tenure claims  and 
use rights, and Indigenous  peoples  and local 
communities  to be fully compensated  for 
appropriation  of traditional  community  know ledge or 

 
 
 
 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

basic needs. 

intellectual  property. 

Substantial  disputes involving  multiple  interests w ill 
normally  prevent this Indicator  from being 
considered low  risk.” 

Means  of verification for indicator 2.5.2: 
Interview s w ith local communities  and other 
stakeholders  indicate  that subsistence needs are 
not endangered,  and Agreements  exist on 
resource rights, w here these impact  on the needs 
of communities 

Justification 

The  Risk  Assessment for relevant region  shall 
specified risks related to indigenous  peoples’  and 
local communities’  rights. If risks are identified  in 
the supply base, risks must  be mitigated  by the 
BP. 

If agreements  w ith affected indigenous  peoples 
and local communities  are required by legislation, 
this is included  in indicator 1.3.1. 

A.1.4.2  Free, Prior  and 

Informed 
Consent 

A.1.4.2.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
the internationally 
adopted  principles of 
'Free,  Prior and 
Informed  Consent'  in 
connection  w ith 

Standard  1 

Findings 

Principle  1: Biomass  feedstock is legally  sourced 

Scheme info 

Partially 
Covered 

Criterion  1.3: There is compliance  w ith the 
requirements  of local,  national  and applicable 
international  law s, and the law s applicable  to 
Forest Management. 

Indicator  1.3.1 covers applicable  forest legislation. 
Guidance  covers applicable  legislation  related  to: 
“Third  parties’ legal  rights concerning  use and 
tenure that are affected by timber  harvesting”. 

Indicator  1.3.1:  The BP  has implemented 

Examples  of means  of verification for indicator 

750 

 
 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

granting  rights to forest 
management. 

2.5.1: Customary  and traditional  tenure and use 
rights are identified  and documented,  Interview s 
w ith indigenous  peoples, local  communities  and 
other stakeholders,  indicate  that their rights are 
being  respected, Appropriate  mechanisms  exist to 
resolve disputes,  and Agreements  exist regarding 
these rights. 

Examples  of means  of verification for indicator 
2.6.1: Existing  legal  systems, Level of 
enforcement,  Regional  Best Management 
Practices,  Supply contracts, Records of 
grievances and the outcomes  from internal 
investigations,  Interview s w ith stakeholders  and 
local community  members,  and Interview s w ith 
staff. 

Justification 

The  Risk  Assessment for relevant region  shall 
specified risks related to indigenous  peoples’  and 
local communities’  rights. If risks are identified  in 
the supply base, risks must  be mitigated  by the 
BP.  How ever, the standard does not mention 
FPIC. 

appropriate  control systems and procedures to 
ensure that feedstock is legally  harvested and 
supplied  and is in compliance  w ith EUTR  legality 
requirements. 

Principle  2: Biomass  feedstock is sustainably 
sourced 

Criterion  2.5: Management  of the forest ensures 
that legal,  customary and traditional  tenure and 
use rights of indigenous  peoples and local 
communities  related  to the forest, are identified, 
documented  and respected. 

Indicator  2.5.1:  The BP  has implemented 
appropriate  control systems and procedures for 
verifying that legal,  customary and traditional 
tenure and use rights of indigenous  people  and 
local communities  related to the forest, are 
identified,  documented  and respected. 

Criterion  2.6: Appropriate mechanisms  are in place 
for resolving grievances and disputes, including 
those relating  to tenure and use rights, to Forest 
Management  practices and to w ork conditions. 

Indicator  2.6.1:  The BP  has implemented 
appropriate  control systems and procedures for 
verifying that appropriate  mechanisms  are in place 
for resolving grievances and disputes, including 
those relating  to tenure and use rights, to forest 
management  practices and to w ork conditions. 

751 

 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1.4.3 

Indigenous  and 
traditional 
peoples'  rights 

A.1.4.3.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
national  legislation  and 
international 
conventions ratified that 
respect the tenure 
rights of indigenous  and 
tribal  peoples to forest 
land as w ell as their 
right to FPIC. 

Standard  1 

Findings 

Covered 

Principle  1: Biomass  feedstock is legally  sourced 

Scheme info 

Criterion  1.3: There is compliance  w ith the 
requirements  of local,  national  and applicable 
international  law s, and the law s applicable  to 
Forest Management. 

Indicator  1.3.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that feedstock is legally  harvested and 
supplied  and is in compliance  w ith EUTR  legality 
requirements. 

Principle  2: Biomass  feedstock is sustainably 
sourced 

Criterion  2.5: Management  of the forest ensures 
that legal,  customary and traditional  tenure and 
use rights of indigenous  peoples and local 
communities  related  to the forest, are identified, 
documented  and respected. 

2.5.1: The  BP  has implemented  appropriate  control 
systems and procedures for verifying that legal, 
customary and traditional  tenure and use rights of 
indigenous  people and local  communities  related to 
the forest, are identified,  documented  and 
respected.  

Guidance  1.3.1:  Third parties’  legal  rights 
concerning use and tenure that are affected by 
timber  harvesting. 

Examples  of means  of verification for indicator 
2.5.1: “Customary  and traditional  tenure and use 
rights are identified  and documented,  Interview s 
w ith indigenous  peoples, local  communities  and 
other stakeholders,  indicate  that their rights are 
being  respected, Appropriate  mechanisms  exist to 
resolve disputes,  and Agreements  exist regarding 
these rights.” 

Guidance:  “In  particular, rights should be identified, 
documented  and respected in  relation  to: Trade  and 
customs, Legal,  customary and traditional  tenure 
and use. The  requirement  includes ILO  convention 
169, w hich relates to the rights of indigenous  and 
tribal  peoples.” 

Examples  of means  of verification for indicator 
2.5.2: Interview s w ith local communities  and 
other stakeholders  indicate  that subsistence 
needs are not endangered,  and Agreements  exist 
on resource rights, w here these impact  on the 
needs of communities. 

Justification 

2.5.2: The  BP  has implemented  appropriate  control 
systems and procedures for verifying that 

The  Risk  Assessment for relevant region  shall 
specified risks related to tenure rights of indigenous 

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production  of feedstock does not endanger food, 
w ater supply or subsistence means  of communities, 
w here the use of this specific feedstock or w ater is 
essential  for the fulfillment  of basic needs. 

and tribal peoples’  rights. If risks are identified  in the 
supply base, risks must be mitigated  by the BP.  The 
ILO  convention  related to this area is adopted. 

A.1.5 Trade and custom s, in so far as the 
forest sector is concerned 

A.1.5.1  Classification 

of species, 
quantities, 
qualities 

A.1.5.1.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  regulating 
how  harvested material 
is classified in terms of 
species, quantities  and 
qualities  in connection 
w ith trade and 
transport.  

Standard  1 

Findings 

Covered 

Principle  1: Biomass  feedstock is legally  sourced 

Scheme info 

Criterion  1.1: The Supply  Base is defined 

Indicator  1.1.2:  Feedstock  can be traced back to the 
defined Supply  Base. 

Means  of verification for indicator 1.1.2: Feedstock 
inputs, including  species and volumes,  are 
consistent w ith the defined Supply Base, and 
Transport documentation  and goods-in records are 
consistent w ith the defined Supply Base. 

Guidance:  Feedstock  claimed  to have originated 
from the Supply  Base can be traced back to that 
Supply  Base. 

Justification 

The  Risk  Assessment for relevant region  shall 
specified risks related to classification of quantities 
and species. How ever, species that are sourced 
shall be available  in the BP’s  supply base report. If 
risks are identified  in the supply base, risks must  be 
mitigated  by the BP. 

A.1.5.2  Trade  and 

transport 

A.1.5.2.1  The Scheme 
shall include 
requirements  that 

Standard  1 

Findings 

Covered 

Principle  1: Biomass  feedstock is legally  sourced 

Scheme info 

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ensure compliance  w ith 
legally  required trading 
permits  as w ell as 
legally  required 
transport documents 
that accompany 
transport of w ood from 
forest operations. 

Criterion  1.3: There is compliance  w ith the 
requirements  of local,  national  and applicable 
international  law s, and the law s applicable  to 
Forest Management. 

Indicator  1.3.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that feedstock is legally  harvested and 
supplied  and is in compliance  w ith EUTR  legality 
requirements. 

Means  of verification 1.1.2:  Feedstock  can be 
traced back to the defined Supply Base. includes:   

-Feedstock  inputs, including  species and volumes, 
are consistent w ith the defined Supply  Base 

-Transport documentation  and goods-in records are 
consistent w ith the defined Supply Base 

Means  of verification  for indicator 1.3.1: Existing 
legislation,  Level of enforcement,  etc.  

Guidance:  Applicable  legislation  includes that in 
force in the country of harvest, covering the 
follow ing aspects: Trade and customs, in so far as 
the forest sector is concerned. 

See also findings in A.1.5.1.1 above. 

Justification 

The  Risk  Assessment for relevant region  shall 
specified risks related to legally  required trade and 
transport documents  from forest operations. If risks 
are identified  in the supply base, risks must be 
mitigated  by the BP.  How ever, no mention  of 
transport documents  and trading permits. 

A.1.5.3  Offshore 

trading  and 
transfer pricing 

A.1.5.3.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  regulating 
offshore trading and 
transfer pricing.   

Standard  4 

6.1 EUTR  compliance 

Findings 

Scheme info 

Not 
Covered 

6.1.2 SBP  certificate holders exporting SBP-
certified biomass  to countries under the scope of 
the EUTR  shall exercise due diligence  to ensure 
that these feedstock do not contain  illegally 
harvested timber. 

6.1.3 SBP  certificate holders shall support their 
customers in applying  their due diligence 
systems, as required in the EUTR. 

There  is no requirement  w ithin the SBP 
Standards to control illegal  activities related to 
offshore trading and transfer pricing.  There are 
tw o requirements  that aims  at covering EUTR  in 
a general  w ay in Standard  4 (6.1.2 and 6.1.3) and 
one requirement  that attempts  to cover all 
applicable  law s in the country w here the 
certificate holder  conduct its business (Standard 
4, 6.3.3). How ever, these requirements  are 

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6.3.3 The  legal  ow ner shall determine  and 
implement  effective arrangements  to comply  w ith 
all applicable  law s, rules and regulations  in 
countries w here it conducts business activities. 

general  and not comprehensive  enough to cover 
specific issues like  offshore trading and transfer 
pricing w ithout further specifications or 
guidelines. 

Direct interviews / discussions / Stakeholder  input 

SBP  response: Clauses  6.1.2, 6.1.3 and 6.3.3 in 
Standard  4 cover all applicable  EUTR 
requirements.  In our opinion  it w ould be 
redundant  to copy and paste each EUTR  clause 
into the SBP  normative  documents  and hence 
SBP  is compliant  in this regard. 

Justification 

Available  Standard  requirements  are too general  to 
be considered to cover specific issues like  offshore 
trading  and transfer pricing w ithout further 
specifications or guidelines.   

A.1.5.4  Customs 

regulations 

A.1.5.4.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  covering 
areas such as 
export/import  licenses, 
and product 
classification related to 
customs (codes, 
quantities,  qualities  and 
species). 

Standard  4 

6.1 EUTR  compliance 

Findings 

Scheme info 

Covered 

6.1.4: SBP  certificate holders shall comply  w ith 
all trade and customs requirements  including 
payment  of any fees and duties. 

Requirement  6.1.4 addresses “all trade and 
customs requirements”  w hich w ould include 
information  such as HS-codes, quantities, 
qualities  and species. 

Species that are sourced shall be available  in the 
BP’s  supply base report. Traders shall know  w ho 
they bought  biomass  from and should  find this 
report on SBP’s  or the BP’s  w ebsites. 

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A.1.5.5  CITES 

A.1.5.5.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  related  to 
CITES  permits  (the 
Convention  on 
International  Trade  in 
Endangered  Species  of 
Wild  Fauna  and Flora, 
also know n as the 
Washington 
Convention). 

Justification 

There  is a requirement  addressing trade and 
customs requirements. 

Standard  1 

Criterion  1.5: There is compliance  w ith the 
requirements  of CITES 

Findings 

Scheme info 

Covered 

Indicator  1.5.1:  The BP  has implemented 
appropriate  control systems and procedures to 
verify that feedstock is supplied  in compliance  w ith 
the requirements  of CITES. 

Means  of verification for indicator 1.5.1: List of 
species purchased by BP,  Records of field 
inspections,  Assessment of risk that CITES  species 
may be mixed  in w ith non-CITES  species in the 
supply chain, Interview s demonstrate  that the 
CITES  requirements  are understood,  CITES 
species are know n and identified,  Where  relevant, 
the operation  possesses permits  for harvest and 
trade in any CITES  species. 

Guidance:  It  should be verified that tree species 
purchased by BPs are not listed in CITES  or have 
been purchased w ith the appropriate  permits  and 
approvals. 

CITES  and IUCN  red listed  species present in the 
supply base must  be declared  in the BP’s  supply 
base report.  

Justification 

The  Risk  Assessment for relevant region  shall 
specified risks related to CITES  and the 
documentation  needed  if CITES  are sourced. If risks 
are identified  in the supply base, risks must be 
mitigated  by the BP.   

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A.1.5.6  Legislation 

requiring  due 
diligence  / due 
care 
procedures 

A.1.5.6.1  The scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  covering due 
diligence/due  care 
procedures, including 
e.g. due diligence/due 
care systems, 
declaration  obligations, 
and /or the keeping  of 
trade related 
documents,  legislation 
establishing  procedures 
to prevent trade in 
illegally  harvested 
timber  and products 
derived from such 
timber,  etc. 

Standard  4 

6.1 EUTR  compliance 

Findings 

Scheme info 

Covered 

Requirements  under 6.1 (Standard 4) covers the 
important  parts of a due diligence  system (DDS) 
for all  biomass  not classified as SBP-compliant 
(i.e. SBP-controlled). 

SBP-compliant  biomass  is controlled  through all 
Standard  requirements  in Standard  1 and must 
have a high level  of traceability.  It also relates to 
a Risk  Assessment and risk mitigation  measures 
must  be implemented  w here risks are detected. 
Procedures  are covered in the BP’s  management 
system and supplier verification program. 

Guidance  for indicator 1.1.2 (Standard  1): 
Feedstock  claimed  to have originated  from the 
Supply  Base can be traced back to that Supply 
Base. 

Justification 

There  is a requirement  related  to DDS.  SBP-
compliant  biomass  is considered to cover this 
requirement  through all  requirements  in Standard  1. 
SBP-controlled  biomass  is subject to all 
requirements  under 6.1 EUTR  compliance,  w hich 
covers this requirement. 

6.1.1: All inputs dow nstream of the biomass 
production  process w here mixing  of SBP-compliant 
biomass  w ith non-SBP  compliant  biomass  takes 
place, shall have been determined  to be EUTR 
compliant  and shall have been subjected to ‘due 
diligence’.   

Note:  The  core of the ‘due diligence’  notion  is that 
legal  ow ners undertake a risk management  exercise 
so as to minimise  the risk of placing  illegally 
harvested timber,  or, timber  products containing 
illegally  harvested timber  on the EU  market. 

The  three key elements  of the ‘due diligence 
system’ are:  

• Information:  The legal  ow ner must have access to 
information  describing the timber  and timber 
products, country of harvest, species, quantity, 
details  of the supplier and information  on 
compliance  w ith national  legislation. 

• Risk  Assessment: The legal  ow ner should assess 
the risk of illegal  timber  in his supply chain, based 
on the information  identified  above and taking  into 
account criteria set out in the regulation. 

• Risk  mitigation:  When  the assessment show s 
that there is a risk of illegal  timber  in the supply 
chain that the risk can be mitigated  by requiring 
additional  information  and verification from the 

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supplier. 

6.1.2 SBP  certificate holders exporting SBP-certified 
biomass  to countries under the scope of the EUTR 
shall exercise due diligence  to ensure that these 
feedstock do not contain illegally  harvested timber. 

6.1.3 SBP  certificate holders shall support their 
customers in applying  their due diligence 
systems, as required in the EUTR. 

Standard  1 

Principle  1: Biomass  feedstock is legally  sourced 

Criterion  1.1: The Supply  Base is defined 

Indicator  1.1.2:  Feedstock  can be traced back to the 
defined Supply  Base. 

A.2 Legal requirements for supply chain entities  

This section shall apply to  Certificate  Holders  - or other entities  subject to the normative  requirements  of the Scheme  (e.g. included  w ithin the scope of a certified due diligence 
system) - w ithin the Country  of Harvest. 

A.2.1. Legal registration 

A.2.1.1  Legal 

Registration 

A.2.1.1.1  The scheme 
shall include 
requirements  that 
ensure the existence of 
legal  business 

Standard  1 

Findings 

Covered 

Principle  1: Biomass  feedstock is legally  sourced 

Scheme info 

Criterion  1.2: The forest ow ner and manager  hold 

In  the country of harvest w hen sourcing feedstock, 

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registration,  and other 
relevant legally  required 
licenses. 

legal  use rights to the forest.  

the same findings as in  A.1.1.1.3 above applies. 

Indicator  1.2.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that legality  of ow nership and land  use can 
be demonstrated  for the Supply Base. 

For all certificate holders, the Certification 
Trademark  Licence Agreement  must be signed 
before certificates are issued. This document 
contains the business registration  number  and 
details  about the legal  entity. 

Criterion  1.3: There is compliance  w ith the 
requirements  of local,  national  and applicable 
international  law s, and the law s applicable  to Forest 
Management. 

No  requirement  regarding legal  business 
registration  or and other relevant legally  required 
licenses is found in the SBP  Standards. 

Indicator  1.3.1:  The BP  has implemented 
appropriate  control systems and procedures to 
ensure that feedstock is legally  harvested and 
supplied  and is in compliance  w ith EUTR  legality 
requirements. 

SBP  Certification  Trade  Mark  Licence Agreement 

Direct interviews / discussions / Stakeholder  input 

SBP  response: The  SBP  scheme  requires all 
Certificate  Holders  to enter into a Trade Mark 
Licence Agreement  w ith SBP  (Standard 3 clause 
13.4) and certification agreement  w ith a 
Certification  Body (Standard  3 section 13). 
Signing  both documents  include  verification of a 
Certificate  Holder’s  legal  registration  and hence 
SBP  is compliant  in this regard. 

Justification 

The  Risk  Assessments investigate w here risks are 
and w here risk mitigation  measures must  be put in 
place. The  means  of verification and guidance 
covers the practical implementation  of the Standard 
requirements.  These indicators  also include  other 
relevant legally  required  licenses. 

For all certificate holders, SBP  informs that they 
control that all certificate holders are legally 
registered w hen signing  the trademark  license 

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agreement.  The  certification bodies most likely  do 
the same w hen signing  certification agreements  w ith 
certificate applicants.  The  indicator is partially 
covered. 

A.2.2 Taxes and fees 

A.2.2.1  Payment  of 

taxes, royalties 
and fees 

A.2.2.1.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  covering 
payment  of all legally 
required taxes, royalties 
and fees. 

Standard  4 

6.1 EUTR  compliance 

Findings 

Scheme info 

Partially 
Covered 

6.1.4: SBP  certificate holders shall comply  w ith 
all trade and customs  requirements  including 
payment  of any fees and duties. 

Requirement  6.1.4 is applicable  for all certificate 
holders. 

Direct interviews / discussions / Stakeholder  input 

SBP  response: Clause  6.1.4 in Standard  4 
regarding  all applicable  trade and customs 
requirements  requires the Certificate  Holder  to 
pay all  relevant taxes and hence SBP  is 
compliant  in this regard. 

Justification 

There  is a requirement  for payment  of any fees and 
duties, but taxes are not explicitly  mentioned  in this 
requirement.   

A.2.2.2  Value-added 

taxes and other 
sales taxes 

A.2.2.2.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  covering 
different types of sales 
taxes that apply to the 
material  being  sold, 

Standard  1 

Criterion  1.4: All applicable  royalties and taxes 
have been paid 

1.4.1 The  BP  has implemented  appropriate 
control systems and procedures to verify that 
payments  for harvest rights and timber,  including 

Findings 

Scheme info 

Partially 
Covered 

Standard  1 (1.4.1) covers that duties, fees and 
taxes shall be paid on the forest level up to the 
BP.  The  CoC  Standard  (4) requires control of 
incoming  and outgoing  invoices but does not 

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including  selling 
material  as grow ing 
forest (standing  stock 
sales). 

duties, relevant royalties and taxes related  to 
timber  harvesting,  are complete  and up to date. 

Standard  4 

5.4 Outputs 

5.4.1 Biomass  supplied  w ith an SBP  claim  shall, 
in addition  to meeting  the requirements  specified 
in the SBP-approved  CoC  system being 
implemented,  be supplied  w ith the follow ing 
information: 

reference VAT or other types of sales taxes. 
Quantities  shall be controlled  on invoices. There 
is a requirement  for payment  of any fees and 
duties, but VAT or other types of sales taxes are 
not explicitly mentioned  in this requirement. 

Direct interviews / discussions / Stakeholder  input 

SBP  response: Clause  6.1.4 in Standard  4 
regarding  all applicable  trade and customs 
requirements  requires the Certificate  Holder  to 
pay all  relevant taxes and hence SBP  is 
compliant  in this regard. 

a) The  name  and address of the buyer; 

Justification 

The  CoC  Standard  requires control of incoming  and 
outgoing  invoices and payment  of any fees and 
duties, but does not explicity refer to VAT or other 
types of sales taxes. Since there are no scheme 
guidance  that w ould further indicate  that VAT and 
other sales taxes are fully covered by requirements 
in Standard  4, this requirement  is considered to be 
partially  (or potential)  covered. 

b) The  date on w hich the invoice w as issued; 

c) A description  of the product  – this must 
correspond to the description of the product 
given in the input and output records 

d) The  quantity of the products sold w ith specific 
batch data 

6.1 EUTR  compliance 

6.1.4: SBP  certificate holders shall comply  w ith 
all trade and customs requirements  including 
payment  of any fees and duties. 

A.2.3 Trade and transport 

A.2.3.1  Classification 

of species, 

A.2.3.1.1  The Scheme 
shall include 

Standard  4 

Findings 

Covered 

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quantities, 
qualities 

requirements  that 
ensure compliance  w ith 
legislation  regulating 
how  products are 
classified in terms  of 
species, volumes  and 
qualities  in connection 
w ith trade and 
transport.  

5.4 Outputs 

Scheme info 

5.4.1 Biomass  supplied  w ith an SBP  claim  shall, 
in addition  to meeting  the requirements  specified 
in the SBP-approved  CoC  system being 
implemented,  be supplied  w ith the follow ing 
information: 

a) The  name  and address of the buyer; 

b) The  date on w hich the invoice w as issued; 

c) A description  of the product  – this must 
correspond to the description of the product 
given in the input and output records 

d) The  quantity of the products sold w ith specific 
batch data 

Standard  5 

Instruction  Document  5E:  Collection  and 
Communication  of Energy  and Carbon  Data 

5.1 Transaction  Claim  requirements 

5.1.1 All transactions shall be recorded in the 
DTS. 

The  CoC  Standard  requires control of incoming 
and outgoing  invoices, including 
quantities/volumes  and a description of the 
product (Standard 4: 5.4.1). Quantities/volumes 
w ith SBP-claims  must  be transferred through 
SBP’s  Data  Transfer System (DTS)  (5E:  5.1.1), 
and traders can only sell the same amount  as 
they purchased even though it can be split to 
different customers. 

Transportation  documents  are not  explicitly 
mentioned. 

Species that are sourced shall be available  in the 
BP’s  supply base report. Traders shall know  w ho 
they bought  biomass  from and should  find this 
report on SBP’s  or the BP’s  w ebsites. 

Justification 

SBP  Standard 4 and 5 covers relevant  parts of 
this requirement.  Although transportation 
documentation  is not explicitly  mentioned  in any 
requirement,  the Data  Transfer System  (DTS)  is 
a system that ensure trades can be traced and 
monitored. 

A.2.3.2  Trade  and 

transport 

A.2.3.2.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
required trading  permits 
as w ell as legally 

Standard  4 

6.1 EUTR  compliance 

Findings 

Scheme info 

Partially 
Covered 

6.1.1: All inputs dow nstream of the biomass 
production  process w here mixing  of SBP-compliant 

For transport of w ood from the forest to the BP,  see 
1.5.1.1  above (Standard  1, Criterion  1.1, Indicator 

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1.1.2). In  this requirement  feedstock claimed  to 
have originated  from the Supply  Base can be traced 
back to that Supply  Base. 

Regarding  the supply chain after the BP,  Standard  4 
has requirements  relating  to EUTR  compliance, 
w hich indirectly w ould cover trade and transport. 

Justification 

From  the forest to the BP:  The Risk  Assessment 
for relevant region  shall specified risks related to 
trade and transport from the forest to the BP.  If 
risks are identified  in the supply base, risks must 
be mitigated  by the BP. 
Trades betw een BPs  and customers:  SBP 
Standard  4 and 5 covers relevant parts of this 
requirement.  Although  transportation 
documentation  is not explicitly  mentioned  in any 
SBP  requirement,  the Data  Transfer System 
(DTS)  monitor  and control trades w ith SBP-
claims. 

The  SBP  standard does not directly  mention  any 
legally  required documents. 

required transport 
documents  that 
accompany  transport of 
w ood. 

biomass  w ith non-SBP  compliant  biomass  takes 
place, shall have been determined  to be EUTR 
compliant  and shall have been subjected to ‘due 
diligence’.   

Note:  The  core of the ‘due diligence’  notion  is that 
legal  ow ners undertake a risk management  exercise 
so as to minimise  the risk of placing  illegally 
harvested timber,  or, timber  products containing 
illegally  harvested timber  on the EU  market. 

The  three key elements  of the ‘due diligence 
system’ are:  

• Information:  The legal  ow ner must have access to 
information  describing the timber  and timber 
products, country of harvest, species, quantity, 
details  of the supplier and information  on 
compliance  w ith national  legislation. 

• Risk  Assessment: The legal  ow ner should assess 
the risk of illegal  timber  in his supply chain, based 
on the information  identified  above and taking  into 
account criteria set out in the regulation. 

• Risk  mitigation:  When  the assessment show s 
that there is a risk of illegal  timber  in the supply 
chain that the risk can be mitigated  by requiring 
additional  information  and verification from the 
supplier. 

Standard  5 

Instruction  Document  5E:  Collection  and 

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A.2.3.3  Offshore 

trading  and 
transfer pricing 

A.2.3.3.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  regulating 
offshore trading.  

Communication  of Energy  and Carbon  Data 

5.1 Transaction  Claim  requirements 

5.1.1 All transactions shall be recorded in the 
DTS. 

Standard  4 

6.1 EUTR  compliance 

Findings 

Scheme info 

Not 
Covered 

6.1.2 SBP  certificate holders exporting SBP-
certified biomass  to countries under the scope of 
the EUTR  shall exercise due diligence  to ensure 
that these feedstocks do not contain illegally 
harvested timber. 

6.1.3 SBP  certificate holders shall support their 
customers in applying  their due diligence 
systems, as required in the EUTR. 

6.3.3 The  legal  ow ner shall determine  and 
implement  effective arrangements  to comply  w ith 
all applicable  law s, rules and regulations  in 
countries w here it conducts business activities. 

There  is no requirement  w ithin the SBP 
Standards to control illegal  activities related to 
offshore trading and transfer pricing.  There are 
tw o requirements  that aims  at covering EUTR  in 
a general  w ay in Standard  4 (6.1.2 and 6.1.3) and 
one requirement  that attempts  to cover all 
applicable  law s in the country w here the 
certificate holder  conduct its business (Standard 
4, 6.3.3). How ever, these requirements  are 
general  and not comprehensive  enough to cover 
specific issues like  offshore trading and transfer 
pricing w ithout further specifications or 
guidelines. 

Direct interviews / discussions / Stakeholder  input 

SBP  response: Clauses  6.1.2, 6.1.3 and 6.3.3 in 
Standard  4 cover all applicable  EUTR 
requirements.  In our opinion  it w ould be 
redundant  to copy and paste each EUTR  clause 
into the SBP  normative  documents  and hence 
SBP  is compliant  in this regard. 

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Findings and Justification 

Conclusion 

A.2.3.3.2  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  regulating 
transfer pricing. 

Standard  4 

Justification 

Available  Standard  requirements  are too general 
to be considered to cover specific issues like 
offshore trading and transfer pricing  w ithout 
further specifications or guidelines.   
Findings 

Not 
Covered 

6.1 EUTR  compliance 

Scheme info 

6.1.2 SBP  certificate holders  exporting SBP-
certified biomass  to countries under the scope of 
the EUTR  shall exercise due diligence  to ensure 
that these feedstock do not contain  illegally 
harvested timber. 

6.1.3 SBP  certificate holders shall support their 
customers in applying  their due diligence 
systems, as required in the EUTR. 

6.3.3 The  legal  ow ner shall determine  and 
implement  effective arrangements  to comply  w ith 
all applicable  law s, rules and regulations  in 
countries w here it conducts business activities. 

There  is no requirement  w ithin the SBP 
Standards to control illegal  activities related to 
offshore trading and transfer pricing.  There are 
tw o requirements  that aims  at covering EUTR  in 
a general  w ay in Standard  4 (6.1.2 and 6.1.3) and 
one requirement  that attempts  to cover all 
applicable  law s in the country w here the 
certificate holder  conduct its business (Standard 
4, 6.3.3). How ever, these requirements  are 
general  and not comprehensive  enough to cover 
specific issues like  offshore trading and transfer 
pricing w ithout further specifications or 
guidelines. 

Direct interviews / discussions / Stakeholder  input 

SBP  response: Clauses  6.1.2, 6.1.3 and 6.3.3 in 
Standard  4 cover all applicable  EUTR 
requirements.  In our opinion  it w ould be 
redundant  to copy and paste each EUTR  clause 
into the SBP  normative  documents  and hence 
SBP  is compliant  in this regard. 

Justification 

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A.2.3.4  Customs 

regulations 

A.2.3.5  CITES 

A.2.3.4.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  covering 
areas such as 
export/import  licenses, 
and product 
classification related to 
customs (codes, 
quantities,  qualities  and 
species). 

A.2.3.5.1  The Scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  related  to 
CITES  permits  (the 
Convention  on 
International  Trade  in 
Endangered  Species  of 
Wild  Fauna  and Flora, 
also know n as the 
Washington 
Convention). 

Standard  4 

Available  Standard  requirements  are too general 
to be considered to cover specific issues like 
offshore trading and transfer pricing  w ithout 
further specifications or guidelines.   
Findings 

Covered 

6.1 EUTR  compliance 

Scheme info 

6.1.4: SBP  certificate holders shall comply  w ith 
all trade and customs requirements  including 
payment  of any fees and duties. 

The  requirement  6.1.4 covers export/import 
licenses, and product classification related  to 
customs. 

Standard  1 

Justification 

There  is a requirement  related  to customs 
applicable  to the supply chain.   
Findings 

Criterion  1.5: There is compliance  w ith the 
requirements  of CITES. 

Scheme info 

Partially 
Covered 

Indicator  1.5.1:  The BP  has implemented 
appropriate  control systems and procedures to 
verify that feedstock is supplied  in compliance  w ith 
the requirements  of CITES. 

Means  of verification for indicator 1.5.1: List of 
species purchased by BP,  Records of field 
inspections,  Assessment of risk that CITES  species 
may be mixed  in w ith non-CITES  species in the 
supply chain, Interview s demonstrate  that the 
CITES  requirements  are understood,  CITES 
species are know n and identified.  Where  relevant, 
the operation  possesses permits  for harvest and 
trade in any CITES  species. 

Guidance:  It  should be verified that tree species 
purchased by BPs are not listed in CITES  or have 
been purchased w ith the appropriate  permits  and 

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approvals. 

Justification 

The  Risk  Assessment has defined w here risks are 
at the forest level. These must  be mitigated  by 
Biomass  Producers.  How ever, there is no 
requirement  in Standard  4 that covers export or 
import  of biomass  containing  CITES  species.  

A.2.3.6  Legislation 

requiring  due 
diligence  / due 
care 
procedures 

A.2.3.6.1  The scheme 
shall include 
requirements  that 
ensure compliance  w ith 
legislation  covering due 
diligence/due  care 
procedures, including 
e.g. due diligence/due 
care systems, 
declaration  obligations, 
and /or the keeping  of 
trade related 
documents,  legislation 
establishing  procedures 
to prevent trade in 
illegally  harvested 
timber  and products 
derived from such 
timber,  etc. 

Standard  4 

6.1 EUTR  compliance 

Findings 

Scheme info 

Covered 

6.1.1: All inputs dow nstream of the biomass 
production  process w here mixing  of SBP-compliant 
biomass  w ith non-SBP  compliant  biomass  takes 
place, shall have been determined  to be EUTR 
compliant  and shall have been subjected to ‘due 
diligence’.   

Note:  The  core of the ‘due diligence’  notion  is that 
legal  ow ners undertake a risk management  exercise 
so as to minimise  the risk of placing  illegally 
harvested timber,  or, timber  products containing 
illegally  harvested timber  on the EU  market. 

The  three key elements  of the ‘due diligence 
system’ are:  

• Information:  The legal  ow ner must have access to 
information  describing the timber  and timber 
products, country of harvest, species, quantity, 
details  of the supplier and information  on 
compliance  w ith national  legislation. 

Requirement  6.1.1 covers biomass  that are SBP-
controlled,  w hile requirement  6.1.2 covers SBP-
certified biomass  that are exported a country that 
implements  the EUTR.  It  is not clear from 
requirements  6.1.2 if certificate holders only have 
to exercise due diligence  to ensure that timber 
w as legally harvested, or if they have to include 
all EUTR  requirements  related to trade and 
transport, health and safety, etc. Most of these 
requirements  w ould, how ever, already be 
covered for certified biomass. 

Justification 

There  are requirements  that covers that both SBP-
controlled  and SBP-complain  biomass  must  be 
exposed to due diligence  if exported to a country 
under the scope of EUTR. 

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• Risk  Assessment: The legal  ow ner should assess 
the risk of illegal  timber  in his supply chain, based 
on the information  identified  above and taking  into 
account criteria set out in the regulation. 

• Risk  mitigation:  When  the assessment show s that 
there is a risk of illegal  timber  in the supply chain 
that the risk can be mitigated  by requiring  additional 
information  and verification from the supplier. 

6.1.2 SBP  certificate holders exporting SBP-certified 
biomass  to countries under the scope of the EUTR 
shall exercise due diligence  to ensure that these 
feedstock do not contain illegally  harvested timber. 

6.1.3 SBP  certificate holders shall support their 
customers in applying  their due diligence  systems, 
as required in the EUTR. 

A.3 Requirements for material control 

A.3.1 Material  control  

A.3.1.1  Material  origin 
and 
identification 

A.3.1.1.1  The Scheme 
shall require systematic 
processes to enable  the 
identification  of the 
country of harvest of the 
material,  and w here 
applicable  to a higher 
level of detail,  such as 
the sub-national  region 
or concession level.  

Standard  1 

Standard  2 

Standard  4 

Standard  5 

Instruction  Document  5E:  Collection  and 
Communication  of Energy  and Carbon  Data 

768 

Findings 

Scheme info 

Covered 

Standard  1 & 2: The  BP  must know  w here the 
feedstock comes  from through mapping  the supply 
base in a Supply Base Report.  SBP  defines the 
supply base as the area “encompassing  all places 
w here pre-consumer feedstock w as harvested from 
(i.e. the location  of the tree stump).” 

This should  also cover prospective future harvesting 

 
 
 
 
 
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Conclusion 

areas in order to cover areas that is currently not yet 
in the supply base, but can be in the future. 

This means  that the BP  must  be able  to show  to 
auditors w here all biomass  w as harvested. 

Standard  4 & 5: When  biomass  is sold, the only 
w ay to make  valid  transactions is through the 
Data  Transfer System  (DTS).  Transactions also 
require a Production  Batch ID  w hich relates to the 
production  data for the biomass.  This Batch ID 
relates to a specific period  of processing at the 
BP  and the BP  should therefore be able to show  
its supply base  for that period retrospectively. 

Justification 

SBP  uses an electronic transaction  system w hich 
minimizes  risk of false claims.  The  BP  declare its 
supply base including  areas dow n to similar  risks. 
The  Supply Base Report  is alw ays available  on the 
BP’s  w eb page. 

Auditors check the traceability  during audits and 
have access to all  transactions in DTS. 

A.3.1.1.2  The Scheme 
shall require systematic 
processes to enable  the 
identification  of the 
species included  in 
materials  or products 
included  in the scope of 
certification. 

Standard  2 

7 Supply  Base Report 

Findings 

Scheme info 

Covered 

7.3 The SBR  shall be completed  using the latest 
version of the SBR  template,  w hich is available  from 
the SBP  w ebsite. 

Standard  2: The  BP  must declare species mix in its 
supply base report. 

“Supply-Base-Report-Template-for-BPs-v1.3-
Apr20-FINAL” 

Standard  4 & 5: When  biomass  is sold, the only w ay 
to make  valid transactions is through  the Data 
Transfer System  (DTS).  Transactions also require a 

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Production  Batch ID  w hich relates to the production 
data for the biomass.  This  Batch ID  relates to a 
specific period of processing at the BP  and the BP 
should therefore be able to show  its supply base for 
that period retrospectively. 

Justification 

The  BP  declare its supply base including  species 
mix  in a Supply Base Report  w hich is alw ays 
available  on the BP’s  w eb page. 

Auditors check the traceability  during  audits and 
have access to all  transactions in DTS. 

Findings 

Scheme info 

Covered 

SBP  trusts input  from the “SBP-approved  CoC 
system” (FSC,  PEFC  and SFI),  including  their 
system for controlling  uncertified material. 

Specified risks in terms of the SBP  requirements  in 
Standard  1 (including  illegal  harvest) is detected 
and mitigated  under Standard 1 and 2 and its 
related  Risk  Assessment. The  mitigation  measures 
for risks are addressed in the BP’s  Supplier 
Verification Programme  and is audited. 

Mixing  other biomass  w ith SBP-compliant  or SBP-
controlled  biomass  is not allow ed. 

Standard  1 

Standard  2 

Standard  4 

A.3.1.1.3  The Scheme 
shall include  clear and 
effective measures  to 
prevent material  from 
non-negligible  risk, 
unverified or potentially 
illegal  sources from 
entering  the supply 
chain and mixed  w ith 
conforming  material. 

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Conclusion 

Justification 

The  Risk  Assessment and Supplier  Verification 
Programme  has been through  stakeholder 
consultation  and is considered robust enough  to 
justify that this requirement  is covered. 

Findings 

Scheme info 

Covered 

Standard  1 & 2: The  BP  must know  w here the 
feedstock comes  from through mapping  the supply 
base. SBP  defines the supply base as the area 
“encompassing  all  places w here pre-consumer 
feedstock w as harvested from (i.e. the location  of 
the tree stump).” 

This should  also cover prospective future harvesting 
areas in order to cover areas that is currently not yet 
in the supply base, but can be in the future. 

This means  that the BP  must  be able  to show  w here 
all biomass  w as harvested through a traceability 
system. 

Also for secondary feedstock (e.g. saw dust from a 
saw mill), the BP  needs to show  traceability back to 
the forest of origin. 

There  are tw o types of tertiary feedstock: 1) pre-
consumed  tertiary feedstock (e.g. saw dust from 
secondary processing) should  be treated as primary 
or secondary feedstock and  show  compliance 
against all  indicators in Standard  1 and the location 

Standard  1 

Standard  2 

Standard  4 

Standard  5 

Instruction  Document  5E:  Collection  and 
Communication  of Energy  and Carbon  Data 

A.3.1.1.4  Where 
applicable,  the Scheme 
shall require the 
segregation  and 
tracking  of certified 
(according to each 
individual  claim  type) or 
verified legal  w ood 
along  the supply chain, 
using appropriate 
inventory methods  and 
documented  controls 
w here necessary to 
ensure that risks of 
mixing  are identified, 
managed  and mitigated. 

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of the tree stump  must be know n to be w ithin the 
supply base, and 2) post-consumed  tertiary 
feedstock must  follow  the requirements  in 
Instruction  Note  4A and be proven to be post-
consumed.   

SBP-biomass  and feedstock shall  alw ays be 
separated from non-SBP  biomass  or feedstock, but 
can physically contain  both SBP-compliant  or SBP-
controlled  biomass/feedstock.  The  ratio of different 
type of biomass  that is mixed  must  be show n at all 
times  (similar  to a credit system), but there is no 
claim  that ensures that the biomass  contains 100% 
SBP-compliant  biomass.  The SBP-controlled 
biomass  comes from SBP-approved  certification 
schemes and is out of scope for this evaluation.   

Standard  4 & 5: When  biomass  is sold, the only w ay 
to make  valid transactions is through  the Data 
Transfer System  (DTS).  Transactions also require a 
Production  Batch ID  w hich relates to the production 
data for the biomass.  This  Batch ID  relates to a 
specific period of processing at the BP.  The BP 
should therefore be able to show  its supply base for 
that period retrospectively. 

Justification 

SBP  uses an electronic transaction  system w hich 
minimizes  risk of false claims.  The  BP  declare its 
supply base including  areas dow n to similar  risks. 
The  supply base report is alw ays available  on the 

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Conclusion 

A.3.2 Recycled m aterial  

A.3.2.1  Waste material 

A.3.2.1.1  The Scheme 
shall have a definition  of 
w aste material  w hich at 
least covers the 
definition  of w aste 
material  as described 
by the EUTR  Guidance 
document. 

BP’s  w ebpage. 

Auditors check the traceability  for all types of 
feedstock during  audits and have access to all 
transactions in DTS.  SBP-compliant  biomass  can 
physically contain SBP-controlled  biomass.  This 
biomass  comes from SBP-approved  certification 
schemes and is out of scope for this evaluation. 

Standard  4 

Instruction  document  4A: SBP  tertiary feedstock 
requirement 

Findings 

Scheme info 

Covered 

SBP  separate post-consumed  and pre-consumed 
tertiary feedstock. Only post consumed  feedstock is 
included  in this instruction document. 

The  BP  must verify that biomass  that is claimed  as 
post-consumed  tertiary feedstock also is post-
consumed  and not pre-consumed. 

Visual inspection  of the feedstock is required 
upon receipt. Evidence  must be kept to audits. 

Justification 

Instruction  note 4A cover the part that there must be 
evidence to prove that the feedstock is post-
consumed.  This  is in line w ith EUTR  guidance.  This 
material  can be mixed  w ith SBP-biomass,  but 
verification of it is needed  during audit. 

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A.3.2.1.2  The Scheme 
shall require systematic 
processes to enable  the 
identification  of w aste 
material  that has 
completed  its life cycle 
and to differentiate this 
material  from virgin or 
material  that are by-
products of a 
manufacturing  process 
w hich has not 
completed  its lifecycle 
as defined by the 
EUTR. 

A.3.2.1.3  The Scheme 
shall include  clear and 
effective measures  to 
prevent “timber  products 
of a kind  covered by the 
Annex of the EUTR”, 
produced from i) reclaimed 
material  that has NOT 
completed  its lifecycle and 
w ould otherw ise have 
been discarded as w aste”, 
ii) unverified or iii) virgin 

Standard  4 

Instruction  document  4A: SBP  tertiary feedstock 
requirement 

Findings 

Scheme info 

Covered 

SBP  separate post-consumed  and pre-consumed 
tertiary feedstock. Only post consumed  feedstock is 
included  in this instruction document. 

The  BP  must verify that biomass  that is claimed  as 
post-consumed  tertiary feedstock also is post-
consumed  and not pre-consumed. 

Visual inspection  of the feedstock is required 
upon receipt. Evidence  must be kept to audits. 

Justification 

Instruction  note 4A cover the part that there 
must  be evidence to prove that the feedstock is 
post-consumed.  This  is in line w ith EUTR 
guidance.  This material  can be mixed  w ith SBP-
biomass,  but verification of it is needed  during 
audit. 
Findings 

Covered 

Standard  4 

Instruction  document  4A: SBP  tertiary feedstock 
requirement 

Scheme info 

SBP  separate post-consumed  and pre-consumed 
tertiary feedstock. Only post consumed  feedstock is 
included  in this instruction document. 

The  BP  must verify that biomass  that is claimed  as 
post-consumed  tertiary feedstock also is post-
consumed  and not pre-consumed. 

Visual inspection  of the feedstock is required 

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material  (as defined by the 
EUTR)  from, entering  the 
supply chain.  

A.4 General requirements for Certificate Holders 

upon receipt. Evidence  must be kept to audits. 

Justification 

Instruction  note 4A cover the part that there must 
be evidence to prove that the feedstock is post-
consumed.  This  is in line w ith EUTR  guidance. 
This material  can be mixed  w ith SBP-biomass, 
but verification of  it is needed  during audit. 

A.4.1 

Conflict 
resolution 

A.4.1.1 The  Scheme 
shall include 
requirements  that 
ensure that disputes are 
identified,  recorded and 
managed,  in a w ay that: 

i) ensures there is a 
transparent ongoing 
process to address the 
issue 
ii) requires for the 
exclusion from the 
scope of the certificate 
situations  or areas or 
forest w here the legality 
of tenure or 
management/harvesting 
is not defined or is 
unclear and disputed. 
iii) ensures respect for 
legally-enshrined 
customary tenure rights 

Standard  2 

20 Comments  or complaints 

Findings 

Scheme info 

Covered 

20.1: The  BP  shall ensure that all  comments  or 
complaints  regarding  any aspect of the SBR,  SBE 
and SBP  certification are documented  and promptly 
investigated,  w ith remedial  action being taken 
w here appropriate. 

Depending  on the scope of the certificate, the 
certificate holder  must have one or tw o 
complaints  procedures. For BPs,  requirements 
from Standard 2 must be fulfilled. 

20.2: The  BP  shall inform SBP  of any substantiated 
complaints  w ithin 30 days of the completion  of the 
BP’s  analysis of the complaint. 

Standard  4 

6.4 Complaints 

6.4.1: The  legal  ow ner shall determine  and 
implement  effective arrangements  for 
communicating  in relation  to feedback, including 

For traders, only requirements  from Standard  4 is 
applicable.  How  this requirement  shall  be 
addressed depends on w hich SBP-approve 
certification system the certificate holder use as 
basis for its SBP  certification (FSC,  PEFC  or 
SFI).  For example,  if a certificate holder relies on 
its FSC-certification,  the complains  procedures 
must  live up to requirement  1.5 in FSC-STD-40-
004 V3-0 (and the biomass  type registered as a 
product group under the FSC  scheme). 

Justification 

All certificate holders must be certified under FSC, 
PEFC  and SFI  and have the biomass  product group 

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of local communities. 

customer and third-party complaints. 

included  in that certificate. This  means that their 
complaint  system needs to live up to the 
requirements  specified in that schemes. 

BPs  must have a more  extensive procedure 
related  to their sourcing of biomass  (SBE  and 
SBR). 
Findings 

Covered 

Corruption   

A.4.1.2 The  scheme shall 
include  requirements  to 
ensure that certificate 
holders do not engage  in 
corrupt practices related  to 
illegal  harvesting. 

Standard  4 

6.3 Business integrity, social, health  and safety 
requirements  in CoC 

Scheme info 

6.3.2: The  legal  ow ner shall determine  and 
implement  effective arrangements  against 
corruption, proportionate  to the nature and the  scale 
of organisation. 

SBP  Certification  Trade  Mark  Licence Agreement 

Requirement  6.3.2 usually results in a company 
corruption policy. 

SBP  also have several points in their Trademark 
License Agreement  (that all certificate holder 
need to sign) that take the certificate holder’s 
behaviour  and reputation  in to account. 

For example,  it is stated that “The  Licensee shall 
not do, or omit  to do, or permit  to be done, any 
act that w ill or may w eaken, damage  or be 
detrimental  to the Certification  Mark  or the 
reputation  or goodw ill associated w ith the 
Certification  Mark  or the Licensor or any member 
of the Licensor’s Group,  or that may invalidate  or 
jeopardise  any registration  of the Certification 
Mark.” 

Justification 

The  SBP  scheme  relies on certificate holder’s ow n 
policies  related to corruption, w hich should reflect 
the activities the certificate holder w orks w ithin. In 
addition,  SBP’s  Trademark  license agreement  need 

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A.5 Quality and procedural requirements for Certificate Holders 

to be signed by all  certificate holders and this 
agreement  contains points related  to reputational 
behaviour  and complying  w ith applicable  legislation. 

A.5.1 

Internal 
procedures for 
Certificate 
Holders 

A.5.1.1 The  Scheme 
shall include 
requirements  for the 
Certificate  Holders  to 
have in place - and 
implement  - systems 
and procedures 
covering all 
requirements  of the 
Scheme. 

Standard  2 

15 Management  system 

Findings 

Scheme info 

Partially 
Covered 

15.1 The  BP  shall implement  a management  and 
monitoring  system to maintain  compliance  w ith the 
requirements  of this and all other relevant SBP 
Standards,  together w ith a process of review  and 
feedback into planning  (CPET  S6b1). 

Standard  4 

5.1 CoC  system requirements 

5.1.1 The  legal  ow ner shall be certified against an 
SBP-approved  Chain  of Custody  (CoC)  system and 
hold a valid certificate. 

5.1.2 The  legal  ow ner shall implement  all aspects of 
the SBP-approved  CoC  system requirements  for the 
SBP  feedstock and biomass.  Where there is a 
conflict betw een the requirements  in the SBP-
approved CoC  system requirements  and those 
specified in the SBP  standards, the SBP  standards 
shall have precedence. 

Note:  SBP  feedstock or biomass  w ill not necessarily 
enter into the scope of the SBP-approved  CoC 

It is specified that BPs  must have a management 
system (i.e. procedures), to maintain  compliance 
to all relevant SBP  Standards. 

No  similar  requirement  can be found for the rest 
of the supply chain in Standard  4, but the SBP-
approved certification schemes should all  have 
this requirement  included.  The certificate holders 
must  implement  all applicable  CoC-requirements 
from the SBP-approved  certification schemes it 
basis its SBP  system on. All SBP  products must 
be include the SBP-product  group and in the 
product group of the SBP-approved  CoC-scheme 
the certificate holder is certified to. The SBP  has 
in that w ay made sure all  requirements  for the 
SBP-approved  certification schemes must  be 
applied  on the SBP  scope. How ever, since SBP 
is missing  w ritten procedures for how  they 
approve other certification schemes, this 
requirement  cannot be considered fully covered, 
but one need to look  at  the requirement  of the 
approved scheme  the specific certificate holder  is 
implementing.   

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system certification, but the SBP-approved  CoC 
system CoC  processes and requirements  shall 
extend to SBP  feedstock and biomass. 

Justification 

This requirement  is covered for BPs  through 
Standarxd 2. For traders there is a gap in the 
SBP  systems, since SBP  is missing  w ritten 
procedures for how  they approve other 
certification schemes (see C.2.4.1  below ). This 
means  one need to look  at the requirement  of the 
approved scheme  a specific certificate holder is 
implementing  before this requirement  can be 
considered fully covered. 

A.5.1.2 The  Scheme 
shall include 
requirements  for the 
Certificate  Holders  to 
regularly review  the 
proper functioning of 
their ow n procedures. 

Standard  2 

15 Management  system 

Findings 

Scheme info 

Partially 
Covered 

Instruction  Note  2A: Supplier  Verification 
Programme  – Requirements  for Biomass  Producers 

For BPs  w ith a Supplier  Verification Program  in 
scope (i.e. Standard  1 in scope), the BP  must 
monitor  and control its suppliers  (requirement  1.1.2). 

1.1.2: Annual or more frequent monitoring  visits to a 
sample  of suppliers to verify their continuing 
compliance  w ith all  requirements  of the applicable 
SBP  Standards, and w ith any additional 
requirements  stipulated  by the BP.   

Instruction  Note  2C:  Supply Base Report  – 
Requirements  for Biomass  Producers 

Standard  4 

5.3 Chain  of Custody control system 

For BPs  in general: All Supply  Base reports must  be 
updated  annually  (2C: 5.1), and the BP  shall 
implement  a management  review  system, w hich has 
the authority to make  appropriate  improvements  to 
the management  system (2: 15.6). 

No  other requirements  for internal  audits or 
controls are specified in the SBP  Standards, but 
Standard  4 relies on the SBP-approved  CoC 
systems (FSC  or PEFC-endorsed  schemes) 
w hich may require more.  (See FSC  and PEFC 
assessments for more  information). 

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Justification 

There  is no requirement  for Certificate  Holders to 
internally  regularly review  the proper functioning  of 
their ow n procedures if the certificate holder is not a 
BP.  How ever, annual  audits are performed  by the 
certification body so the certificate holder’s 
compliance  w ith the SBP  Standards w ill be 
evaluated  annually. 

Standard  2 

12 Competence  to undertake  Supply  Base 
Evaluations 

Findings 

Scheme info 

Covered 

A.5.2 

Qualification 
and 
competence 

A.5.2.1 The  Scheme 
shall include 
requirements  that 
ensure that certified 
organisations  have 
personnel  w ith sufficient 
qualifications  and 
competencies  to 
consistently and 
effectively implement 
Scheme  requirements. 

SBP  has a number  of requirements  for personnel 
that undertakes  the supply base evaluation  (i.e. Risk 
Assessment and Supplier  Verification Programme). 
These include  local know ledge, languages, 
know ledge w ithin law s/regulations and forest 
ecosystems, etc. (12.1). 

A justification of the skills and evaluation  team  shall 
be provided to the CB  (12.3). 

There  are no specified requirements  for Personnel 
involved in CoC. 

Justification 

Reasonable  skills  are required for personnel 
covering the critical part of an SBP  evaluation. 
Finding and Justification 

There  is no w ay for non-certified or controlled 
material  to enter the SBP-system,  apart from w hat is 
included  in the SBP  certification. Post-consumed 

Not 
Applicable 

A.5.3 

Risk  based 
approaches to 
sourcing, trade 
or production 

A.5.3.1 If the Scheme 
includes an option  to 
implement  a risk based 
approach to sourcing non-

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certified material  (Due 
Diligence  System),  it shall: 
i) contain  clear 
requirements  and ii) 
ensure consistent 
implementation  of the Due 
Diligence  System,  for all 
activities, materials  and 
suppliers included  w ithin 
the scope of the 
certification. 
A.5.3.2 The  Scheme 
shall include 
requirements  that 
ensure that w henever 
there is a change in the 
risk related to illegal 
harvest, trade or 
transport in a supply 
chain – or a supply 
chain covered by a 
DDS  – the risk shall be 
assessed and mitigated 
prior to shipping  and 
sale. 

tertiary feedstock must be verified as such. Pre-
consumed  tertiary feedstock is accepted as input if 
controlled  or certified under another  SBP-approved 
scheme. 

Standard  2 

Findings 

Covered 

17 Supply Base Evaluation  interval 

Scheme info 

17.1 The  SBE  shall be undertaken  at least every 
five years and the SBR  review ed for accuracy and 
completeness  prior to each annual  audit. 

17.2 The  SBE  shall be modified  in accordance w ith 
changes in the SB. 

17.3 Any significant changes likely  to affect the SBE 
shall result in an immediate  review , and, if required, 
revision of the SBE  by the BP,  to ensure that the 
SBE  risk rating  remains  accurate. 

Standard  4 

6.1 EUTR  compliance 

For material  sourced under the SBP-scheme  (i.e. 
Standard  1 is applicable),  Risk  Assessments are 
the base for sourcing risks. Risks must  be 
mitigated.  The Supply  Base Evaluation  (SBE), 
w hich includes the Risk  Assessment, must be 
review ed at least every five years (before re-
certification). The Supply  Base Report  (SBR) 
must  be review ed annually  (before annual 
audits). The  SBE  must  cover the Supply  Base. 
When  there are significant changes in risks, the 
SBE  must be revised accordingly. 

In  Standard 4, certificate holders must  implement 
a DDS  of the SP-biomass  if the biomass  is 
exported to the EU. 

Justification 

6.1.2 SBP  certificate holders exporting SBP-certified 
biomass  to countries under the scope of the EUTR 

The  SBP  scheme  require DDS  and changes w hen 
regional  risk profiles or supply bases changes. All 

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shall exercise due diligence  to ensure that these 
feedstock do not contain illegally  harvested timber. 

certificate holders need to conduct DDS  of material 
exported to the scope of EUTR. 

A.5.3.3 In  cases w here 
other 3rd party schemes 
permitted  to be used by 
the due diligence 
system as meeting 
specific due diligence 
requirements,  the 
scheme  shall include 
requirements  that 
ensure that it is clear: 
i) on w hat basis 
recognition  is made 
and;  
ii) how  it is verified that 
other Schemes  ensure 
conformance w ith the 
specific due diligence 
requirements. 

Standard  2 

8 Determining  the need for a Supply Base 
Evaluation 

8.2 The follow ing types of feedstock may be 
excluded from a SBE: 

• Feedstock  received w ith an  SBP-approved  Forest 

Management  Scheme  claim. 

• Feedstock  received w ith an SBP-approved  Forest 

Management  Scheme  partial  claim. 

• Feedstock  received w ith an SBP-approved  Chain 

of Custody (CoC)  System  claim. 

• Feedstock  received w ith an SBP-approved 

Controlled  Feedstock  System  claim. 

• Feedstock  received w ith an SBP-approved 

recycled claim. 

• Feedstock  sourced w ithin the scope of the BP's 
ow n SBP-approved  Chain  of Custody (CoC) 
System  certification, for example,  non-certified 
reclaimed  feedstock sourced in compliance  w ith 
FSC-STD-40-007:  FSC  Standard  for Sourcing 
Reclaimed  Material  for Use in FSC. 

• Feedstock  sourced w ithin the scope of the BP’s 

ow n SBP-approved  Controlled  Feedstock  System 
certification, for example,  non-certified feedstock 

781 

Findings 

Scheme info 

Not 
Covered 

Feedstock  from the follow ing schemes mentioned 
in requirement  8.2 are exempt  from Supply Base 
Evaluation  (SBE)  and thus are their systems 
recognized as sufficient to mitigate  risks and 
traceability:  FSC,  PEFC  and PEFC-endorsed 
certification schemes. 

There  are no w ritten procedures for how  SBP 
recognize other certification schemes, but 
according to SBP  this w ill be done in the near 
future. Since SBP  first recognized other schemes 
in 2015, there has only been recognition  of FSC, 
PEFC  and PEFC-endorsed  certification schemes. 
According to SBP,  no other schemes are 
currently under review . 

How ever, all material  exported to a country under 
the scope of EUTR  must  perform due diligence 
(Standard  4, requirements  under 6.1). 

Direct interviews / discussions / Stakeholder  input 

SBP  response: SBP  acceptance of FSC  and 
PEFC  certification scheme  claims  w as part of the 
SBP  standard-setting process in 2014, including 
the public consultation  and standard-setting 
process that applied  to the full standards, and 
follow ed requirements  now  specified in the ISEAL 

 
 
 
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sourced in compliance  w ith the FSC®  Standard 
for Company  Evaluation  of FSC®  Controlled 
Wood,  FSC-STD-40-005. 

Standard-Setting  Code  v6 – Interpretation  of 
6.4.3 Final  Version 1 – February, 2016. The 
relevant ISEAL  interpretation  reads as follow s: 

• Post-consumer  tertiary feedstock sourced 

follow ing the requirements  of Instruction  Note  4A, 
SBP  tertiary feedstock requirements. 

“Scenario 1 (applies to recognition of global and 
local standards) 

Standard  4 

6.1 EUTR  compliance 

6.1.1: All inputs dow nstream of the biomass 
production  process w here mixing  of SBP-compliant 
biomass  w ith non-SBP  compliant  biomass  takes 
place, shall have been determined  to be EUTR 
compliant  and shall have been subjected to ‘due 
diligence’.   

Where the standard-setting organisation 
incorporates part or all of an existing standard 
directly into its standard, these activities take 
place during the regular standard-setting or 
revision process. As such, any decision to 
reference another standard will be subject to the 
same standard-setting consultation and decision-
making procedures normally used by the 
standard-setting organisation. Therefore, no 
additional steps are required to ensure 
equivalence. Care should be taken to abide by 
any copyright restrictions that arise from the 
referencing or integration of another standard.” 

Note:  The  core of the ‘due diligence’  notion  is that 
legal  ow ners undertake a risk management  exercise 
so as to minimise  the risk of placing  illegally 
harvested timber,  or, timber  products containing 
illegally  harvested timber  on the EU  market. 

As part of the current standard development 
process, SBP  w ill consider options for developing 
equivalence  requirements  and revising the list of 
recognised schemes and claims  in line  w ith 
ISEAL  requirements. 

The  three key elements  of the ‘due diligence 
system’ are:  

Justification 

• Information:  The legal  ow ner must have access to 

information  describing the timber  and timber 
products, country of harvest, species, quantity, 
details  of the supplier and information  on 
compliance  w ith national  legislation. 

SBP  has no clear procedures on how  to recognize 
other certification schemes. This is considered a 
major  gap since material  from other schemes can 
enter the supply chain through the use of their ow n 
DDS. 

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• Risk  Assessment: The legal  ow ner should assess 
the risk of illegal  timber  in his supply chain, based 
on the information  identified  above and taking  into 
account criteria set out in the regulation. 

• Risk  mitigation:  When  the assessment show s that 
there is a risk of illegal  timber  in the supply chain 
that the risk can be mitigated  by requiring 
additional  information  and verification from the 
supplier. 

6.1.2 SBP  certificate holders exporting SBP-certified 
biomass  to countries under the scope of the EUTR 
shall exercise due diligence  to ensure that these 
feedstock do not contain illegally  harvested timber. 

A.5.3.4 The  Scheme 
shall include 
requirements  to ensure 
that the DDS 
comprises,  at a 
minimum,  the follow ing 
elements:  i) a quality 
management  system, ii) 
procedures for 
obtaining  access to 
information  pertinent  to 
the identification  of risk; 
iii) Risk  Assessments, 
and iv) the 
implementation  of 
mitigations  measures 
w hen risks are 
identified. 

Standard  4 

6.1 EUTR  compliance 

Findings 

Scheme info 

Covered 

6.1.1: All inputs dow nstream of the biomass 
production  process w here mixing  of SBP-compliant 
biomass  w ith non-SBP  compliant  biomass  takes 
place, shall have been determined  to be EUTR 
compliant  and shall have been subjected to ‘due 
diligence’.   

All important  elements  are included  in 
requirement  6.1.1. How ever, it is not clear if 
material  exported to a country under the scope of 
EUTR  (6.1.2) also must  implement  6.1.1. For 
SBP-compliant  biomass,  the requirement  only 
include  that DDS  shall be exercised. 

Note:  The  core of the ‘due diligence’  notion  is that 
legal  ow ners undertake a risk management  exercise 
so as to minimise  the risk of placing  illegally 
harvested timber,  or, timber  products containing 
illegally  harvested timber  on the EU  market. 

The  three key elements  of the ‘due diligence 

Justification 

The  level of information  regarding  a due diligence 
system is considered sufficient. They due 
diligence  system itself is considered a quality 
system. 

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system’ are:  

• Information:  The legal  ow ner must have access to 

information  describing the timber  and timber 
products, country of harvest, species, quantity, 
details  of the supplier and information  on 
compliance  w ith national  legislation. 

• Risk  Assessment: The legal  ow ner should assess 
the risk of illegal  timber  in his supply chain, based 
on the information  identified  above and taking  into 
account criteria set out in the regulation. 

• Risk  mitigation:  When  the assessment show s that 
there is a risk of illegal  timber  in the supply chain 
that the risk can be mitigated  by requiring 
additional  information  and verification from the 
supplier. 

6.1.2 SBP  certificate holders exporting SBP-certified 
biomass  to countries under the scope of the EUTR 
shall exercise due diligence  to ensure that these 
feedstock do not contain illegally  harvested timber. 

B. Requirements for Certification Bodies 

Scheme requirements for Certification Bodies shall be clear and unambiguous and allow the Scheme  owner to verify the level o f conformance of each Certification Body to these requirements. 

B.1 General Certification Body requirements 

B.1.1 

Competence 
and 
qualifications 

B.1.1.1  The  Scheme 
shall have mechanisms 
to ensure that auditors, 
and other relevant 

Standard  3 

8 Competences 

Findings 

Scheme info 

Covered 

8.2: The personnel  shall be competent  for the 

SBP  requires that personnel  involved in the audit 

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personnel  of the 
Certification  Body, are 
qualified  and competent 
to evaluate 
organisations’ 
compliance  w ith specific 
Scheme  requirements. 

functions they perform, including  making  required 
technical  judgments,  defining policies  and 
implementing  them. 

8.3: The CB  shall implement  the requirements  of 
ISO/IEC  17065:2012(E)  section 6.1.2 Management 
of competence  for personnel  involved in the 
certification process. 

or review  process has relevant skills, at least on 
an audit team  level. 

SBP  implements  the ISO  requirements  from 
17065:2012,  w hich also includes  both auditors 
and review ers. 

Justification 

SBP  requires that personnel  involved in the audit 
or review  process has relevant skills, at least on 
an audit team  level.   

8.4: The CB  shall ensure that the audit team 
undertaking  an audit of a BP  has the combined 
necessary know ledge and experience to evaluate 
against the SBP  Feedstock  Compliance  Standard  in 
the local context of the Supply Base (SB), including: 

• Know ledge of ecological  and social values 

associated w ith the SB 

• Know ledge of applicable  law s and regulations 

• Know ledge of business management  practices 

• Know ledge of operation  of suppliers, including 

management  systems and products 

• Know ledge of the local forest resource 

• Language  skills  appropriate  to all  stakeholders 

8.5: The CB  shall ensure that the audit team 
undertaking  an audit against any SBP  Standard  has 
the combined  necessary know ledge and experience 
to evaluate against  that Standard. 

8.6: Lead auditors and personnel  in the review  and 
certification decision-making  process shall be 

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B.1.1.2  If the Scheme 
includes an option  for 
the Certificate  Holder  to 
implement  a Due 
Diligence  System,  the 
scheme  shall ensure 
that  the auditors and 
other relevant 
personnel  of the 
Certification  Body are 
qualified  and competent 
to evaluate 
organisations’ 
compliance  w ith related 
Scheme  requirements. 

B.1.2.1  The  scheme 
shall include 
requirements  to ensure 
that auditors, and other 
personnel  relevant to 
the conformance 
evaluation  of an 
organisation  shall  be 
impartial  to the entity(-
ies) under evaluation. 

approved by SBP  for their tasks at the time  of 
undertaking  those tasks. 

Standard  3 

8 Competences 

Findings 

Scheme info 

Covered 

8.3: The CB  shall implement  the requirements  of 
ISO/IEC  17065:2012(E)  section 6.1.2 Management 
of competence  for personnel  involved in the 
certification process. 

Auditors must  have the combined  skills  to 
evaluate  Standards under the certificate scope. 
Personnel  involved in the certification decision-
making  process and review  are also included  in 
the ISO  requirements  from 17065:2012. 

8.5: The CB  shall ensure that the audit team 
undertaking  an audit against any SBP  Standard  has 
the combined  necessary know ledge and experience 
to evaluate against  that Standard. 

Justification 

There  are qualification  requirements  regarding  on 
skills relevant  to evaluate  due diligence,  since SBP 
requires that personnel involved  in the audit  or 
review  process has relevant  skills, at least on an 
audit  team  level. 

Standard  3 

5 Accreditation  requirements 

Findings 

Scheme info 

Covered 

5.3 CBs shall operate  SBP  certification in 
compliance  w ith the requirements  of ISO/IEC 
17065:2012  Conformity  assessment – 
Requirements  for bodies  certifying products, 
processes and services. 

CB  shall implement  all relevant  requirements  from 
ISO/IEC  17065:2012.  This Standard  includes 
requirements  for impartiality  (requirement  5.2 
“Mechanism  for safeguarding impartiality”). 
Justification 

Impartiality  requirements  are covered through 
Standard  ISO/IEC  17065:2012. 

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B.1.2.2  The  Scheme 
shall include 
requirements  that 
ensure that the 
certification decision 
process is;  
i) w ell defined and; 
ii) ensures that the 
decision on certification 
is conducted by 
positions/bodies  that 
are impartial  to the 
auditee. 

Standard  3 

Instruction  Note  3A: General  Surveillance  - SBP 
requirements  for CBs 

2: The CB  shall assign one or more persons w ho 
w ere independent  of the audit to decide w hether to 
continue,  suspend or w ithdraw  certification based 
on their review  of surveillance activities. 

Findings 

Scheme info 

Covered 

Personnel  that w ere independent  of the audit 
process shall be assigned  the review  and 
decision-making. 

Justification 

Review er / decision-maker  shall be independent 
from the audit  itself. 

B.2 Certification Body requirements for auditing and certification 

B.2.1 

Auditing 
process 

B.2.1.1  The  Scheme 
shall include 
requirements  that 
ensure that Certification 
Bodies  apply a 
documented 
methodology  for the 
evaluation 
(assessments and 
audits) of clients.   

Standard  3 

10 Certification  Body reporting 

Findings 

Scheme info 

Covered 

10.2: CBs  shall dow nload and use the current 
version of reporting templates  as listed  by SBP  on 
the SBP  w ebsite. 

SBP  creates and updates the report template  that 
all CB  shall use. All relevant  requirements  must 
be evaluated  and recorded in this template.   

Note:  The  listing of a reporting  template  on the SBP 
w ebsite shall  mean  that its use is mandatory.   

7 Basic principles 

7.2 In order to provide such an assurance, the CB 
shall: 

b) Confirm  that the organisation’s  management 
system is capable  of ensuring that all  requirements 
of the Standards  are implemented  across the entire 

The  CB shall  analyse and describe all relevant 
requirements  w hen auditing  a certificate holder. 
This includes  “to confirm that the organisation’s 
management  system is capable of ensuring that 
all requirements  of the Standards  are 
implemented  across the entire scope of the 
evaluation”  (7.2 b). 

Justification 

SBP  decides the documented  format CBs  shall 

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B.2.1.2  As a minimum, 
this methodology  shall 
include  procedures for 
the follow ing activities: 
i) Evaluation  of 
conformity of 
organisations  to the 
Schemes  (e.g. audit of 
sites, or inspection of 
records or of self -
assessment 
declarations); 
ii) Review  and 
certification decision; 
iii) Issuance  of a 
certificate; and 
iv)  Periodic  re-
assessment. 

scope of the evaluation. 

report their audit findings in. 

Standard  3 

7 Basic principles 

Findings 

Scheme info 

Covered 

7.2 In order to provide such an assurance, the CB 
shall: 

Evaluation  of conformity (i): 

c) Conduct  adequate  and appropriate  sampling  and 
review  of sites, documents,  management  records, 
interview s, consultations  w ith stakeholders  and 
direct observations, in order to verify that there is 
full conformance w ith the performance thresholds 
specified in the applicable  Standards. 

Included  in the basic principles: The  CB  shall 
analyse and describe all  relevant requirements 
w hen auditing  a certificate holder  including: 
Conducting  adequate  and appropriate  sampling  and 
review  of sites, documents  (including  records), and 
other relevant aspects of the scope of the audit (7.2 
c). 

Instruction  Note  3A 

Review  and certification decision (ii): 

2 The  CB  shall assign one or more persons w ho 
w ere independent  of the audit to decide w hether or 

Review  shall be done of all audit reports by person 
that is independent  of the audits  process (3A: 2). 

not to continue,  suspend or w ithdraw  certification 
based on their review  of surveillance activities. 

Issuance of a certificate (iii): 

Instruction  Note  3C 

1.2 The CB  shall carry out a surveillance evaluation 
to monitor  the certificate-holder’s continued 
compliance  w ith the applicable  requirements  of the 
relevant SBP  certification Standard(s) at least 
annually. 

Certificates are issued and re-issued every five 
years. 

Periodic  re-assessment (iv): 

Surveillance  evaluation  of  the relevant SBP 
certification Standard(s) must be done at least 
annually  (3C: 1.2).  

Justification 

The  methodology  described for CBs  to conduct 

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B.2.1.3  The  Scheme 
shall include 
requirements  that 
ensure that Certification 
Bodies  have in place  - 
and implement  – 
specific procedures for 
audits that include  at 
least the follow ing: 
i) frequency of audits; 
(no longer  than every 
12 months); 
ii) requirements  for on-
site (field) visits w here 
applicable; 
iii) sampling  protocol for 
audits (if applicable); 
iv) structure and 
competencies  of the 
audit  team; 
v) the minimum  set of 
aspects that need to be 
checked in every audit; 
vi) minimum  content of 
audit  reports, including 
non-conformances, 
clarification of scope, 
audit  process and 
evaluation  findings. 
vii) ability  for 
unannounced  or short-
notice audits in case of 

Standard  3 

5 Accreditation  requirements   

5.3 CBs shall operate  SBP  certification in 
compliance  w ith the requirements  of ISO/IEC 
17065:2012  Conformity  assessment  – 
Requirements  for bodies  certifying products, 
processes and services. 

audits covers requirements  i-iv. 

Findings 

Scheme info 

Frequency of audits (i):  

Surveillance  evaluation  of the relevant SBP 
certification Standard(s) must be done at least 
annually  (3C: 1.2). 

Covered 

7 Basic principles 

Requirements  for on-site (field) visits (ii): 

7.1 An SBP  certificate issued by a CB provides a 
credible  assurance that there is no major  failure in 
conformance w ith the requirements  of the 
applicable  SBP  Standard  across the entire  scope of 
the certificate. 

CB  shall visit BPs annually  (i.e. every 12 months) 
(3A: 1). Certificate  holders w ithout physical 
possession can be made  desk-based. Surveillance 
audits can be w aived if no SBP-activities  has taken 
place (i.e. no production, labelling  or sale of 
biomass)  (3C: 1.2.2). 

7.2 In order to provide such an assurance, the CB 
shall: 

Sampling  protocol for audits  (iii):   

a) Analyse and describe any and all of the follow ing 
that apply to the organisation: 

• Structure, operation,  inputs and outputs 

• CoC  system 

• Critical  control points 

CB  shall “conduct adequate  and appropriate 
sampling  and review  of sites, documents, 
management  records, interview s, consultations  w ith 
stakeholders  and direct observations, in order to 
verify that there is full conformance  w ith the 
performance thresholds specified in the applicable 
Standards” (7.2 c). 

• Greenhouse  gas (GHG)  data collection 

Content  of audit  reports (iv): 

• The  Supply Base Evaluation  (SBE),  including  SBE 

See B.1.1.1  above. SBP  requires that personnel 
involved in the audit  or review  process has relevant 

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skills,  at least on an audit  team  level. 

Aspects that need to be checked in every audit (v): 

Described  in Standard 3 under “7 Basic principles”. 
See also B.2.1.2  above. The methodology 
described for CBs  to conduct audits covers relevant 
aspects of an audit. 

vi) See B.2.1.1  above. All requirements  in vi is 
included  in the SBP  template  and must  be 
completed  before the audit report is considered 
finished. 

vii) In  ISO  17065 it is addressed that CBs  have the 
ability  to make  unannounced  or short-notice audits 
(5.3). 

Justification 

The  requirements  described for CBs  to conduct 
audits covers requirements  i-vii. The  accreditation 
body ASI w ill confirm the sampling  method  during 
CB  audits. 

substantiated  claims  or 
for other reasons.  

scope 

• Implementation  of the Instructions  for Biomass 
Producers for the development  of Locally 
Applicable  Verifiers. 

• Risk  scoring of each Indicator  at both Risk 

Assessment (RA) and Supplier  Verification 
Programme  (SVP) stages 

• Effectiveness of any mitigation  measures 

implemented  as part of the SBE 

• Staff competence  in meeting  SBP  requirements 

• Competence  of the organisation  responsible for 

conducting  the SBE  (w hether internal  or 
external). 

b) Confirm  that the organisation’s  management 
system is capable  of ensuring that all  requirements 
of the Standards  are implemented  across the entire 
scope of the evaluation. 

c) Conduct  adequate  and appropriate  sampling  and 
review  of sites, documents,  management  records, 
interview s, consultations  w ith stakeholders  and 
direct observations, in order to verify that there is 
full conformance w ith the performance thresholds 
specified in the applicable  Standards. 

Instruction  Note  3A 

2 The  CB  shall assign one or more persons w ho 

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w ere independent  of the audit to decide w hether or 
not to continue,  suspend or w ithdraw  certification 
based on their review  of surveillance activities. 

Instruction  Note  3C 

1.2 The CB  shall carry out a surveillance evaluation 
to monitor  the certificate-holder’s continued 
compliance  w ith the applicable  requirements  of the 
relevant SBP  certification  Standard(s) at least 
annually. 

1.2.2 Surveillance  evaluations  may be w aived for 
operations  that have not produced, labelled  or sold 
any biomass  w ith an SBP-claim  since the previous 
audit. 

B.2.2 

Stakeholder 
consultation 

B.2.2.1  The  Scheme 
shall include 
mechanisms  to ensure 
that Certification  Bodies 
conduct consultation 
w ith stakeholder 
(including  rights 
holders) as appropriate 
in relation  to audits 
(only applicable  w here 
necessary** for 
evaluating  compliance 
of certificate holders).  

The  scheme shall 
ensure that the 
certification holder has 
a proper stakeholder 

Standard  3 

Findings 

Covered 

9 Certification  Body stakeholder  consultation 

Scheme info 

9.1 During  the main  audit  of the BP  and the re-
certification audit,  the CB  shall undertake  a 
stakeholder  consultation  process. 

The  Certification  Body must conduct stakeholder 
consultation  for BPs  for the main  assessment and 
re-certification. 

9.2 During  the stakeholder  consultation  process, the 
CB  shall identify relevant individuals  and 
organisations  interested  in and affected by the 
operation  of the applicant  BP.  CBs are not expected 
to identify and consult all possible  stakeholders,  but 
shall consult w ith a sufficient number  of affected 
stakeholders  in order to verify that management 
systems (documented  or undocumented)  are 
w orking effectively and consistently under the full 
range of conditions  present in the area under 

Stakeholders  shall have at least 1 month’s  notice for 
comments  and all submissions  must  be recorded 
and actions must be documented. 

Any stakeholder  comments  received during 
surveillance  audits must be recorded, but there is no 
requirement  to conduct stakeholder  consultations 
for annual  audits. 

BPs  w ith Supply Base Evaluations  shall  also involve 
stakeholders  at least 1 month  before the end of the 

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initial  Supply Base Evaluation  process and at re-
evaluation  (13.1). FSC-STD-20-006  (V3-0) EN  are 
recommended  as good practice (2B: 13.3). 

BPs  shall follow  the requirements  in  Instruction  Note 
2B. 

Justification 

Consultation  of relevant  stakeholders  are 
required for all BPs.  When BPs  are sourcing 
directly from the forest (i.e. w hen Standard  1 and 
Supply  Base Evaluations  (SBE)  are in scope of 
the certificate), additional  stakeholder 
consultation  is required  for the SBE  and SBR.   

consultation  process in 
place. 

evaluation. 

9.3 The CB  shall consult w ith stakeholders  included 
in the BPs SBE  consultation  and the Locally 
Applicable  Verifiers (LAVs) process. As a part of the 
CB  consultation  the CB shall  determine  if 
stakeholders’  comments  w ere adequately 
addressed by the BP. 

9.4 The CB  shall give stakeholders  at least one 
month’s  notice of the audit.  Notification  shall  include 
adequate  information  to enable  stakeholders  to 
make  informed  comments,  but shall  not include 
sensitive or commercially  confidential  information. 

9.5 The CB  shall encourage  stakeholders to submit 
relevant information  to the CB,  in order to evaluate 
compliance  of the BP  w ith SBP  requirements. 

9.6 During  the audit process, the CB shall  review  all 
submissions  and evaluate  those that are relevant. 
All submissions  shall be recorded and the CB shall 
document  actions taken  in relation  to relevant 
submissions,  and the conclusions of the CB 
regarding  compliance  of the BP  w ith the Standards. 

9.7 CBs are not required  to undertake  a stakeholder 
consultation  process during surveillance  audits. 
How ever, all submissions  received by the CB 
regarding  the compliance  of a certified BP,  shall be 
recorded. If submissions  contain information 
relevant to compliance  w ith SBP  requirements,  the 
CB  shall evaluate  the comments  as they affect the 
certification, during  or prior to the next audit,  as 

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appropriate. 

9.8 Records of evaluations  and outcomes  of all 
stakeholder  consultations  shall be maintained  for at 
least five years. 

Standard  2 

13 Stakeholder  consultation 

13.1 Stakeholder  consultation  is required at the 
initial  SBE  and at the five-yearly re-evaluation. 

Instruction  Note  2B: Supply Base Evaluation 
Stakeholder  Consultation  – Requirements  for 
Biomass  Producers 

1 General  Requirements 

1.1 The BP  shall  proactively and transparently 
engage  affected stakeholders  in its SBE  planning 
and monitoring  processes, proportionate  to the 
scale, intensity and risk of management  activities. It 
shall engage  interested stakeholders  on request. 

1.2 Affected stakeholders shall be notified in 
advance of the SBE  if feedstock harvesting is likely 
to negatively impact  on them.  They  shall also be 
provided w ith opportunities  for engagement  in order 
to identify w ays to avoid or reduce any negative 
impacts. 

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1.3 Interested  stakeholders  shall be notified at least 
one month  in advance of the end of the SBE,  and 
shall be provided w ith opportunities  for engagement 
in management  planning  and monitoring  processes 
likely  to impact  on their interests. 

Adapted from Reference Source: FSC-STD-20-002 
(V3-0) EN.  Structure, content and local adaptation 
of Generic Forest Stew ardship Standards 

2 Stakeholder  Concerns 

2.1 The BP  is not required  to reach a consensus 
w ith stakeholders,  but shall consider relevant 
stakeholder  concerns. 

3 Records 

3.1 The BP  shall  keep the follow ing records: 

a) Lists of individuals/organisations  invited to 
comment 

b) Copies  of any correspondence and comments 
received. 

B.2.2 

Corruption 

B.2.2.2  The  Scheme 
shall include 
mechanisms  to identify 
(or for the Certification 
Body to do so) 
companies  sanctioned 
for engagement  in 
corrupt practices 

SBP  Standard 4 includes clause about follow ing the 
law s and also having  mechanisms  against 
corruption. 

Findings 

Scheme info 

Covered 

6.3.2 The  legal  ow ner shall determine  and 
implement  effective arrangements  against 
corruption, proportionate  to the nature and the scale 
of organisation.   

6.3.3 The  legal  ow ner shall determine  and 

Requirement  6.3.2 usually results in a company 
corruption policy. 

Justification 

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relevant to the forest 
sector. 

implement  effective arrangements  to comply  w ith all 
applicable  law s, rules and regulations  in countries 
w here it conducts business activities. 

SBP  directly includes  evaluation  of the risk of 
corrupt practices.. 

C. Requirements for Certification Schemes 

In  case there is a violation  of these requirements, 
SBP  has the right to suspend or terminate  the 
Trade  Mark  License Agreement 

C.1 Transparency 

C.1.1 

Transparency 

SBP’s  w ebsite 

C.1.1.1 Scheme 
requirements  for both 
Certificate  Holders  and 
Certification  Bodies 
shall be publicly 
available  online.   

Findings 

Scheme info 

Covered 

All the SBP  Standards,  Instruction  Notes, guidance 
documents  and templates  are available  on SBP’s 
w ebsite: https://sbp-cert.org/documents/   

In  addition,  all  public summary  reports are 
available  on SBP’s  w ebsite. These  include main 
results, evaluation  process, any stakeholder 
consultations  that has taken  place, and any open 
non-conformities. 

Justification 

All SBP  Standards  and requirements  are available 
on SBP’s  w ebsite. 

C.1.1.2 Schemes  shall 
include  requirements 
that ensure that 

SBP’s  w ebsite 

Findings 

Scheme info 

Covered 

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relevant information 
about the follow ing is 
freely available: 
i) development  and 
content of the Scheme; 
ii) how  the system is 
governed;  
iii) w ho is evaluated  and 
under w hat process;  
iv) impact  information 
and the various w ays in 
w hich stakeholders  can 
engage. 

C.1.1.3 The  Scheme 
shall include 
requirements  that 
ensure that an up-to-
date register of 
certified/verified 
organisations  is publicly 
available. 

i) Available  on SBP’s  w ebsite: https://sbp-
cert.org/Standards-development/about-the-process/   

ii) Available  on SBP’s  w ebsite: https://sbp-
cert.org/about-us/how -w e-operate/  

iii) All current, terminated  and suspended  certificate 
holders are available  on the SBP  w ebsite: 
https://sbp-cert.org/accreditations-and-
certifications/certificate-holders/   

iv) How  to get involved as a stakeholder  can be 
found on SBP’s  w ebsite: https://sbp-
cert.org/Standards-development/get- involved/     

SBP  tries to include impact  information  in their 
Annual SBP  reports: https://sbp-
cert.org/documents/annual-review s/   

Justification 

Relevant  information  about  the SBP  scheme  is 
freely available  on SBP’s  w ebsite. 

SBP’s  w ebsite 

Findings 

Scheme info 

Covered 

All current, terminated  and suspended certificate 
holders are available  on the SBP  w ebsite: 
https://sbp-cert.org/accreditations-and-
certifications/certificate-holders/ 

This includes,  certification code, certificate scope, 
overview  of the organization,  its biomass  activities 

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SBP’s  w ebsite 

C.1.1.4 The  Scheme 
shall make  summaries 
(or full reports) w ith 
relevant findings from 
audits available  on the 
internet. 

and the certificate validity period. 

The  supply base report is also available  on this 
w ebsite, w hich declare the sourcing area, number 
of suppliers, type of biomass  sources and 
relevant forest resource information  relevant for 
that area. 

Justification 

Relevant  information  about  certificate holders is 
available  on SBP’s  w ebsite. As soon as a certificate 
is not active, the (previous) certificate holder w ill not 
be able to transfer SBP-claims  in DTS.  According to 
SBP,  the w ebsite is updated  w ithin tw o days. 

Findings 

Scheme info 

Covered 

All certificate holders have the latest public 
summary  report available  on SBP’s  w ebsite. These 
include  main  results, evaluation  process, any 
stakeholder  consultations  that has taken  place, and 
any open non-conformities.   

The  supply base report is also available  on this 
w ebsite, w hich declare the sourcing area, number  of 
suppliers, type of biomass  sources and relevant 
forest resource information  relevant for that area. 
There  is no full list of sites, but the supply base 
report declares the sourcing areas. SBP  is a product 
certification and not bound to specific sites. The 
sites that are used to source SBP  biomass  is 

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sampled  during audits. 

The  status and scope are also available  directly on-
line,  w ithout having to open any reports. 

https://sbp-cert.org/accreditations-and-
certifications/certificate-holders/   

Justification 

Public  summary  reports and Supply  Base Reports 
are available  on-line  on SBP’s  w ebsite. 

C.1.2 

Impartiality 

C.1.2.1 Procedures  for 
handling  complaints 
and grievances shall  be 
in place, made  publicly 
available  and 
implemented.  The 
procedures shall  be 
clearly publicized, 
making  it easy for 
stakeholders  to submit 
comments  or 
complaints  w here 
applicable. 

Standard  2 

20 Comments  or complaints 

Findings 

Scheme info 

Covered 

20.1: The  BP  shall ensure that all  comments  or 
complaints  regarding  any aspect of the SBR,  SBE 
and SBP  certification are documented  and promptly 
investigated,  w ith remedial  action being taken 
w here appropriate. 

SBP  has complaints  requirements  in several 
Standards.  For BPs (2), certificate holders 
implementing  the CoC-Standard  (4) and in the 
Standard  for certification bodies (3). 

20.2: The  BP  shall inf orm SBP  of any substantiated 
complaints  w ithin 30 days of the completion  of the 
BP’s  analysis of the complaint. 

Standard  3 

Instruction  Note  3B 

1.1.5 The  CB shall  have documented  procedures 
for surveillance  w hich include: 

Depending  on the scope of the certificate, the 
certificate holder  must have one or tw o complaints 
procedures.  

For BPs,  requirements  from Standard  2 must  be 
fulfilled. 

For traders, only requirements  from Standard  4 is 
applicable.  How  this requirement  shall  be addressed 
depends on w hich SBP-approve  certification system 
the certificate holder use as basis for its SBP 
certification (FSC,  PEFC  or SFI).  For example,  if a 
certificate holder  relies on its FSC-certification,  the 
complains  procedures must  live up to requirement 

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b) Review  of any complaints  or allegations  of non-
compliance  w ith any aspect of the applicable  SBP 
Standards 

1.5 in FSC-STD-40-004  V3-0 (and the biomass  type 
registered as a product group under the FSC 
scheme). 

1.2 Review  of documentation  and records 

1.2.1 The  CB shall  review : 

c) Complaints  received 

Instruction  Note  3C 

1.3 Surveillance  evaluations  shall include: 

b) Review  of any complaints,  disputes or allegations 
of non-compliance  regarding  any applicable  aspect 
of the relevant SBP  certification Standard(s) 

Standard  4 

6.4 Complaints 

6.4.1: The  legal  ow ner shall determine  and 
implement  effective arrangements  for 
communicating  in relation  to feedback, including 
customer and third party complaints. 

All certificate holders must implement  Standard  4 
and the complaints  requirement  in this Standard  is 
not very specific and rely on the implemented  SBP-
approved CoC  scheme (FSC,  PEFC  or SFI): 

The  CB must  review  any complains  or allegations 
during surveillance  audits (3B: 1.1.5b & 1.2.1c, and 
3C:  1.3b). 

SBP  has a w ay on their w ebpage to get in 
contact w ith them  in case of any comments  on 
Standard  development  or a specific topic: 
https://sbp-cert.org/Standards-development/get-
involved/ 

Justification 

All certificate holders must be certified under FSC, 
PEFC  and SFI  and have the biomass  product group 
included  in that certificate. This  means that their 
complaint  system needs to live up to the 
requirements  specified in that schemes. 

BPs  must have a more  extensive procedure related 
to their sourcing of biomass  (SBE  and SBR). 

SBP  has a w ay to get in contact and leave 
comments  to them.   

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C1.3 

Conflict  of 
interest and 
corruption 

C.1.3.1  The 
Certification  Scheme 
shall have in place 
requirements  at all 
levels of the scheme 
(normative 
requirements  for CHs, 
requirements  for CBs, 
and for the scheme 
functioning) to manage 
risks of corruption and 
conflict of interest. 

Standard  2 

11 Rating  of risk 

11.2 The  evaluation  of risk begins w ith an 
evaluation  of regional  rather than at an individual 
forest level  or land unit. Credible  information  of low -
risk is required and this should include  regulatory 
requirements  and evidence of compliance  w ith 
regulatory requirements.  The  Transparency 
International  corruption perception  index 
http://w w w.transparency.org/ will be one important 
information  source. 

Standard  4 

6.3 Business integrity, social, health  and safety 
requirements  in CoC 

6.3.2: The  legal  ow ner shall determine  and 
implement  effective arrangements  against 
corruption, proportionate  to the nature and the scale 
of organisation. 

Findings 

Scheme info 

For certificate holders: 

Covered 

Corruption  in the Supply  Base shall be considered 
in the risk rating  in the Risk  Assessment included  in 
the Supply Base Evaluation  (Standard 2). 

For corruption w ithin CBs,  the external 
accreditation  body should  monitor  this. 

Justification 

There  are requirements  for management  of risk of 
corruption both for Certificate  Holders  and CBs. 
How ever, for CBs, there are no requirement  in  SBP 
Standards,  but this w ill be monitored  by the 
accreditation  body (ASI). 

C.2 Scheme & Standard scope 

Note:  section C2 is not specifically referring to EUTR  issues but has been included  as part of the evaluation  of schemes to understand scheme  structures. 

C.2.1 

Standard 
adaptation  to 
the national 
or 
subnational 
context 

C.2.1.1 International 
Standards shall  be 
adapted  to the national 
or subnational  context 
in w hich they are being 
implemented  and 
contain a list of 

Standard  1 

Findings 

Principle  1. Biomass  feedstock is legally  sourced. 

Scheme info 

Partially 
Covered 

Criterion  1.3: There is compliance  w ith the 
requirements  of local,  national  and applicable 
international  law s, and the law s applicable  to Forest 

For BPs,  the Supply Base Evaluation  including  risk 
rating of all the parameters  in Standard  1, is done 

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applicable  legislation,  or 
the Scheme  shall 
enable/require  detailed 
evaluation  of applicable 
legislation  in a national 
context. 

Management 

for each country or region w ith different legislation. 

Instruction  Note  1A: Instructions  for Biomass 
Producers for the development  of Locally  Applicable 
Verifiers 

3.1 The BP  w ill review  the SBP  Feedstock 
Compliance  Standard (SBP  Standard 1) to: 

c) Add specific indicators  (w ith appropriate means 
of verification, if required) and/or cross-references 
to appropriate  documentation,  in order to conform 
w ith relevant national  and local forest law s or 
administrative  requirements. 

The  locally applicable  verifiers are created to catch 
differences betw een countries and regions  w here 
the indicators in Standard  1 are not addressed in an 
adequate  w ay (Instruction Note  1A). Criterion  1.3 in 
Standard  1 also refers to local,  national  and 
applicable  international  law s applicable  to Forest 
Management,  meaning  they have to be locally 
adapted. 

The  SBP  Standards  themselves  are international 
and the same for all countries, but the Risk 
Assessments, risk ratings and supplier verification 
programme  w here risk mitigation  takes place 
depends on the country and to applicable  legislation 
in that country (or region). 

The  BPs shall  have access to applicable  legislation 
and CBs are auditing  relevant parts of this. 

Not  all certificate holders have Standard  1 in 
scope, but then relies on rules in SBP-approved 
CoC-system  (FSC/PEFC/SFI). 

Justification 

The  SBP  Standards  are international,  but law s 
referred to in requirements  (especially on forest 
level) are adapted  to the region  context in the case 
of risk assessments. How ever, for Supply Base 
Evaluations  w here there is no risk assessment,  SBP 
does not provide the BP  w ith a list of applicable 
legislations,  but the list is developed  by the BP  to 

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C.2.2 

International 
conventions 
and treaties 

Standard  1 

C.2.2.1 The  Scheme  shall 
include  a list of the 
relevant international 
conventions to w hich the 
country has ratified, and 
w hich hold legal  force in 
the country. 

develop  that list using Standard  1. 

Findings 

Scheme info 

Partially 
Covered 

Different ILO  conventions shall be adopted  by 
Certificate  Holders  of indicators in Standard  1. See 
also A.1.3.4.1. 

The  SBP  scheme  leaves it to the Risk  Assessment 
and BP  to have access to relevant legislation  or 
legally  binding  conventions  w ithin the supply base. 
There  is no specific country of harvest, but the BP 
must  adapt the SBE  to the circumstances in that 
specific country/region. 

Justification 

In  SBP  Standards  there are no specific country of 
harvest, but area w ithin the scope of certification 
depends on the BP’s  supply base. The  SBE  must 
be adapted to this supply base w hich may include 
one or more  countries/regions.  The SBP  does not 
specifically list other international  conventions that 
must  be included  other than ILO. 

C.2.3 

Use of 
contractors 

C.2.3.1 The 
requirements  for forest 
managers  and supply 
chain entities  shall be 
applicable  to the 
organisation’s 
contractors and 
outsourcing facilities. 

Standard  1 

Criterion  2.7: The basic labour  rights of forest 
w orkers are safeguarded 

2.7.1: The  BP  has implemented  appropriate 
control systems and procedures for verifying that 
Freedom  of Association and the effective 
recognition  of the right to collective bargaining 

Findings 

Scheme info 

Covered 

Labour rights of forest w orkers: 

Standard  1, Guidance  2.7.1: In this Standard  the 
term  “forest w orkers” includes contractors. Thus, the 
Risk  Assessments and indicators in Standard  1 

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are respected. 

covers this on the forest level. 

In  SBP,  outsourcing  can look  very different than in 
many  other forest related business. For example, 
the w hole biomass  production  can be outsourced. It 
w ould then fall under the normal  scope of the 
certificate and be fully included  in the evaluation. 

When  storage or re-packing  take place, the SBP-
approved CoC  requirements  for outsourcing must 
be implemented  (including  outsourcing 
agreements). 

Visits of ports w here biomass is stored is part of the 
scope of SBP  (sample-based  visits). 

Justification 

The  requirements  applicable  to BPs and supply 
chain entities  also covers any forest contractors or 
outsourcing facilities. 

Findings 

Scheme info 

Not 
Covered 

The  SBP  first recognized  other schemes in 2015. 
Since then, there has only been recognition  of 
FSC,  PEFC  and PEFC-endorsed  certification 
schemes. According to SBP,  no other schemes 
are currently under review . 

How ever, there are currently no w ritten 
procedures on how  SBP  approves other 
certification schemes. According to SBP,  the 
scheme  is currently w orking on development  of a 

803 

C.2.4 

Endorsing 
and 
recognising 
of other 
Schemes  and 
systems 

C.2.4.1 If the Scheme 
includes the recognition 
or endorsement  of other 
schemes or systems, it 
shall ensure coverage 
and consistent 
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scheme  benchmarking  methodology  and process 
to meet  ISEAL  Assurance Code  requirements. 
This process is planned  to be completed  in 2021, 
but is not yet in place. 

Direct interviews / discussions / Stakeholder  input 

SBP  response: SBP  acceptance of FSC  and 
PEFC  certification scheme  claims  w as part of the 
SBP  standard-setting process in 2014, including 
the public consultation  and standard-setting 
process that applied  to the full standards, and 
follow ed requirements  now  specified in the ISEAL 
Standard-Setting  Code  v6 – Interpretation  of 
6.4.3 Final  Version 1 – February, 2016. The 
relevant ISEAL  interpretation  reads as follow s: 

“Scenario 1 (applies to recognition of global and 
local standards) 

Where the standard-setting organisation 
incorporates part or all of an existing standard 
directly into its standard, these activities take 
place during the regular standard-setting or 
revision process. As such, any decision to 
reference another standard will be subject to the 
same standard-setting consultation and decision-
making procedures normally used by the 
standard-setting organisation. Therefore, no 
additional steps are required to ensure 
equivalence. Care should be taken to abide by 
any copyright restrictions that arise from the 
referencing or integration of another standard.” 

As part of the current standard development 

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C.3 Accreditation and oversight 

C.3.1 

Accreditation 

C.3.1.1 The  Scheme  shall 
include  a system for 
accreditation  or oversight 
of Certification  Bodies  to 
ensure that CBs  have in 
place the required 
procedures, capacity and 
competencies. 

process, SBP  w ill consider options for developing 
equivalence  requirements  and revising the list of 
recognised schemes and claims  in line  w ith 
ISEAL  requirements. 

Justification 

SBP  has no clear procedures on how  to recognize 
other certification schemes and the conclusion is 
therefore that this requirement  is not covered. 

Standard  3 

5 Accreditation  requirements 

Findings 

Scheme info 

Covered 

Certification  bodies must be accredited by an 
accreditation  body. The accreditation  body may 
depend  on the scope of certification provided by the 
certification body. I.e. not all  certification bodies are 
accredited against supply base evaluations 
(Standard  1 in scope), and the geographical  scope 
of Supply Base Evaluations  can be limited.   

The  certification body must  have all applicable 
forest management  and/or CoC  accreditations to 
become  accredited to SBP.  ASI  is the 
accreditation  body for SBP. 

Justification 

SBP  har included  requirements  for accreditation  and 
w hich accreditation  body that shall be used. ASI is 
the accreditation  body for SBP.  ASI follow s their 

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Standard  3 

C.3.1.2 The  Scheme  shall 
ensure that the 
requirements  and process 
for accreditation  is publicly 
available. 

SBP’s  w ebsite 

C.3.1.3 The  Scheme  shall 
make  publicly available, 
an up-to-date list and 
details  of all  accredited 
Certification  Bodies 

procedures w hen evaluating  CBs. 

Findings 

Scheme info 

Covered 

Standard  3 is the accreditation  Standard 
describing the requirements  for certification 
bodies. This  Standard  is available  on-line  for free. 
Accredited certification bodies  and their scope is 
available  on SBP’s  w ebsite:  https://sbp-
cert.org/accreditations-and-
certifications/accredited-certification-bodies/ 

Justification 

Requirements  and process for accreditation  is 
publicly  available. 

Findings 

Scheme info 

Covered 

Accredited certification bodies  and their scope is 
available  on SBP’s  w ebsite:  https://sbp-
cert.org/accreditations-and-certifications/accredited-
certification-bodies/ 

There  are currently 5 certification bodies 
accredited for various parts of SBP  scheme. 

Justification 

Accredited certification bodies  and their scope are 

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C.3.1.4 The  Accreditation 
Body shall have 
mechanisms  to ensure 
that relevant personnel  are 
qualified  and competent  to 
evaluate  Certification 
Body’s performance in 
relation  to Scheme 
requirements. 

ASI’s w ebpage: 

“Competence”  [February  23, 2017]:  http://w ww.asi-
assurance.org/s/post/a1J1H000002Jea3UA C/p0164   

publicly  available. 

Findings 

Scheme info 

Covered 

ASI has established  internal  procedures 
describing the qualification,  experience, and 
competence  requirements  of ASI staff and 
contractors. These documents  also describe the 
processes for recruitment,  initial  training, 
mentoring,  ongoing  training  and ongoing 
performance monitoring  through self -evaluation 
and peer monitoring.  Additionally,  ASI maintains 
a documented  quality  management  system that 
contains competence  criteria of different 
assessment scopes per accredited program. 

Justification 

ASI has procedures in place to specify, maintain 
and monitor  relevant qualification  requirements  of 
their assessors. These are accessed to be sufficient 
to classify this requirement  as covered.  

C.3.2 

Oversight 
mechanism 

C.3.2.1 The  Scheme 
shall ensure that the 
competence  and 
consistent performance 
of Certification  Bodies  is 
regularly evaluated.   

Performance  shall 
employ  both desk-

ASI Accreditation requirements 

Standard  3 

7 Basic principles   

7.2 In order to provide such an assurance, the CB 
shall: 

Findings 

Scheme info 

Covered 

Certification  bodies  performance is assessed 
annually  by the accreditation  body. There  are 3 
w itness audits of CB  auditors and 1 office-audit. 

c) Conduct  adequate  and appropriate  sampling  and 

It includes  the certifications body’s performance in 
stakeholder  consultancy, auditor field performance 

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based AND  field 
approaches, including: 
i) Stakeholder 
consultation 
ii) In-field  evaluation  of 
the performance of the 
Certification  Body, 
w hether via on-site 
inspections of certified 
forests/ supply chain 
entities  or w itness 
audits of audit 
personnel. 

(in the forest and at BP’s  facilities), and auditor 
competence  assurances such as w itness audits.   

It should  be noted  that forest inspections w ould be 
of suppliers or different sites harvested by the BP 
itself since there is no certified forest in the SBP 
system. Biomass  already certif ied by an SBP-
approved certification system is controlled  under 
that scheme and is not part of the SBP  scope 
(except purchase documents  and proof of 
certification status of the certified material). 

The  accreditation body set deadlines  for non-
conformances and accept/reject any follow -up the 
certification body implements  to address these. 

The  basic principles  section in Standard  3 
includes requirements  for certification bodies  to 
control during audits (7). For example,  review  of 
sites, documents,  management  records, 
interview s, consultations  w ith stakeholders  and 
direct observations (7.2c). 

Justification 

The  SBP  scheme  ensure that the competence  and 
consistent performance of Certification  Bodies  is 
regularly evaluated  through ASI  audits. ASI conduct 
both office (documented)  audits and field 
assessments of certification bodies  annually. 

review  of sites, documents,  management  records, 
interview s, consultations  w ith stakeholders  and 
direct observations, in order to verify that there is 
full conformance w ith the performance thresholds 
specified in the applicable  standards. 

ASI Accreditation Procedure: ASI-PRO-20-101-
Accreditation-V5.0  
“14.2 Upon receipt of the completed checklists and 
documentation, ASI shall conduct three types of 
Assessments,  in the sequence specified below: 
1) Desk  Review of the CAB application and 
documentation 
… 
2) Office Assessment(s)  (Head Office (HO) and Affiliate 
Office (AO)) 
… 
3) Witness Assessment(s)  for each Scope of 
Accreditation.” 

“17.1 To ensure that an accredited CAB continues to 
operate in compliance with the Accreditation 
Requirements, ASI monitors and evaluates the CAB’s 
competence and Conformity throughout the five-year 
Accreditation Cycle via survei llance Assessments.” 

“17.4 Annual surveillance includes: 
1) Assessment  of HO and a sample of AOs; 
2) Witness and/or Compliance Assessment(s); 
3) Any other Assessments  such as  Desk  Review, 
incident follow-up and NC verification as considered 
necessary by ASI to confirm that the CAB is operating 
in accordance with the Accreditation Requirements.” 

“17.7 ASI publishes announcements of surveillance 
Assessments  for accredited CABs on its website and 
carries out Stakeholder consultation for some 
Assessment  types. If Stakeholder comments are 

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received, they are considered by ASI during the 
Assessment  and responded to in the Assessment 
Report while ensuring Stakeholder confidentiality.” 

“17.8 ASI may conduct Extra Assessments in addition 
to the ASI surveillance Assessment program to 
investigate Incidents and/or Complaints or the outcome 
of an earlier Assessment or under other circumstances 
as deemed necessary by ASI.” 

“17.9 ASI may conduct Unannounced Assessments as 
part of or outside of its surveillance Assessment 
program in order to address heightened risk or 
allegations of serious violations or negligence of 
Accreditation Requirements.” 

Procedure for Witness and Compliance Assessments: 
ASI-PRO-20-111-Witness & Compliance Assessments-
V2.1 
7.2 Prior to any assessment,  ASI may request 
stakeholders to submit comments about the CAB and 
the CH and may inform them about the assessment 
date, type and location as mandated by SO 
requirements or at the discretion of ASI. 

C.3.2.2 The  Scheme 
shall include 
requirements  that 
ensure that the 
oversight mechanism 
applies  a clear basis 
for:  
i) establishing 
conformance;  
ii) raising corrective 
actions for non-
conformance, and 

Standard  3 

Findings 

Partially 
Covered 

Instruction  Note  3D:  Non-compliance  – SBP 
requirements  for CBs 

1.3 The CB  shall identify and evaluate  each non-
compliance  to determine  w hether it constitutes a 
minor  or major  non-compliance.  Non-compliances 
shall result in corrective action requests, and, in 
some  cases, suspension or w ithdraw al of the 
certificate. 

The  basis for establishing  conformance is not 
detailed,  how ever, Clause  7.2 of ASI’s  Findings 
procedure (ASI-PRO-20-106)  notes that objective 
evidence shall be recorded. 

ii) ASI has a clear procedure for communicating 
findings w ith Certification  Bodies (ASI-PRO-20-
106). This includes  audit findings and findings 
from other sources, such as ‘Complaint,  Integrity 
and Traceability’  investigations.  Section  11 

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ensuring closure w ithin 
timeframes  to avoid 
legal  non-compliance, 
and;  
iii) certification issue (or 
maintenance)  decision 
making. 

1.5 A non-compliance  may be considered minor  if: 

a) It  is a temporary  lapse OR 

b) It  is unusual/non-systemic  OR 

c) The  impacts  of the non-compliance  are limited  in 
their scale and duration  AND 

d) It  does not result in failure to meet  the relevant 
requirement. 

1.6 A non-compliance  shall be considered major  if, 
either alone  or in combination  w ith further 
noncompliances,  it results in, or is likely  to result in, 
a fundamental  failure to meet  the relevant 
requirement(s)  for operation(s) w ithin the scope of 
the evaluation. 

Such failure shall be indicated  by non-compliance(s) 
w hich: 

a) Continue  over a long period of time,  OR 

b) Are repeated or systematic,  OR 

c) Affect a w ide range of the production,  OR 

d) Are not corrected or adequately  addressed by the 
responsible  managers,  once they have been 
identified. 

1.7 The CB  shall consider the impact  of a non-
compliance  on the integrity  of the affected SBP-
certified products and the credibility  of the SBP 
trademarks,  w hen evaluating  w hether a non-

details  the timelines  associated w ith corrective 
actions: CBs normally  have three months  for 
addressing Major  nonconformities  and 12 months 
for Minors  (Clause  11.2).   

Certification  bodies shall define a timeframe  (up 
to 3 months  for major  non-conformities  and up to 
the next audit  for minor  non-conformities)  in the 
case of initial  assessments (minor  non-
conformities  only) and surveillance  audits (minor 
and major  non-conformities).  There  is a potential 
risk that a non-conformity may  represent an 
infringement  of legislation  and that, as a result, 
illegal  w ood may enter the EU  market  w ithout 
mitigation  measures  to prevent this from 
occurring for a period of up to 3 or 12 months. 

iii) Section  10 of ASI’s  Accreditation Procedure 
(ASI-PRO-20-101)  covers ‘Accreditation 
Decisions’,  setting out the process by w hich an 
Accreditation Committee  (Clause  10.1) bases 
their decision on an Accreditation Report 
prepared by ASI (Clause  10.2). To gain 
accreditation  a Certification  Body must comply 
w ith all  relevant requirements  and any identified 
nonconformities  shall be closed (Clause  15.2). 
Regarding  maintenance  of accreditation:  Section 
21 covers ‘Sanctions’,  w hich are issued for 
noncompliance  and breach of contract (Clause 
21.1). A table is included  (Table  1) giving 
examples  of situations leading  to Sanctions,  of 
w hich tw o refer to corrective actions. Suspension 
and w ithdraw al decisions are also made  by the 
Accreditation Committee  based on 
recommendations  made  in ASI reports (Clauses 

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compliance  results in, or is likely  to result in, a 
fundamental  failure to meet  the relevant 
requirement. 

10.1, 10.2, 22.6 and 23.2). 

Justification 

ASI Findings: ASI-PRO-20-106-ASI Findings-V6.1 

“6.1 ASI findings may be identified during Assessments 
(irrespective of the scope evaluated) or as a result of 
other sources of information (for example Complaint, 
Integrity and Traceability investigations).” 

The  SBP  scheme  ensure ASI continuously  evaluate 
CBs’  performances, including  reporting  of non-
conformities  and timelines  for follow -up on these. 
CB’s  must follow -up on non-conformities,  or they get 
suspended. 

This indicator  has been evaluated  as Partially 
Covered.  Requirements  for non-conformities  are 
structured in a w ay that there is a potential  risk 
that a non-conformity  may represent an 
infringement  of legislation  and that, as a result, 
illegal  w ood may enter the EU  market  w ithout 
mitigation  measures  to prevent this from 
occurring for a period of up to 3 or 12 months 

“6.2 ASI findings shall be raised if objective evidence of 
Conformity with an Accreditation Requirement is not 
provided by the CAB when requested.” 

“7.2 For each NC, the following information shall be 
recorded in the SOF: 
7.2.1 The specific Accreditation Requirement that the 
CAB was  not able to demonstrate conformity with. 
7.2.2 An informative subject that refers directly to the 
issue in question. 
7.2.3 Proposed grading of the finding. 
7.2.4 Description of how the CAB has failed to 
demonstrate Conformity with the Accreditation 
Requirement cited. 
7.2.5 Objective Evidence that demonstrates how the 
CAB was  not able to demonstrate Conformity with the 
Accreditation Requirement (including a grading 
justification in the case of Major NCs). 
7.2.6 Timelines within which the CAB must address the 
NC.” 

“11.2 The default timeline within which ASI NCs must 
be addressed and closed shall be 3 months for Major 
NCs  and 12 months for Minor NCs from the date the 
final Assessment Report is shared with the CAB.” 

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ASI Accreditation Procedure: ASI-PRO-20-101-
Accreditation-V5.0 
“10.1 Accreditation Decisions (decisions Granting, 
renewing, Extending and Reducing technical Scope, 
Suspending and/or Withdrawing Accreditation for all or 
part of the requested Scope) are made by the ASI 
Accreditation Committee (AC) unless otherwise 
specified in this Accreditation Procedure. When making 
an Accreditation Decision, the AC acts as a 
representative of ASI, and the decision is consequently 
attributed to ASI. No legal or contractual relationship is 
established between the AC (or any subset thereof) 
and a CAB. The AC shall have access to all 
Assessment  Reports and Nonconformities (NCs) 
issued, including ASI and CAB responses to these.” 

“10.2 An Accreditation Decision made by the AC is 
based on an Accreditation Report prepared by ASI for 
the AC. The Accreditation Report may include a 
recommendation on how to decide, but any such 
recommendation is non-binding for the AC. The 
decision-making process starts  with the preparation of 
the Accreditation Report.” 

“15.1 If, after the completion of the initial Accreditation 
Assessments,  ASI concludes that the CAB’s 
Certification system meets all Accreditation 
Requirements, including closure of all major NCs, ASI 
prepares an Accreditation Report for the AC, 
recommending initial Accreditation.” 

“21.1 If a CAB fails to comply with the Accreditation 
Requirements or is/has been in breach of the terms of 
the ASI Service Agreement, ASI can impose Sanctions 
on the CAB. ASI further reserves the right to exercise 
any rights provided by the law or by the Service 
Agreement or any other agreement concluded with the 
CAB.” 

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“22.6 For each Suspension decision (except for non-
payment of fees - see section 24), ASI shall prepare an 
Accreditation Report for the AC explaining the reasons 
leading to Suspension, a justification of the scope 
(technical and/or geographical) proposed for 
Suspension, the conditions for lifting the Suspension 
and any other relevant information considered material 
for the recommendation.” 

“23.2 ASI shall prepare an Accreditation Report for the AC 
explaining the reasons leading to Withdrawal and any 
other relevant information considered material for the 
recommendation.” 

C.3.2.3 The  Scheme 
shall specify the 
approach to be used in 
oversight, ensuring that 
the oversight 
mechanism  is 
independent  of the 
Certification  Bodies 
being  assessed.  

C.3.2.4 The  Scheme 
shall define the 
frequency of oversight 
or the procedure for 
determining  the 
frequency, applicable  in 
the case of risk-based 
oversight. 

Standard  3 

5 Accreditation  requirements 

Findings 

Scheme info 

Covered 

SBP  has delegated  the w ork of oversight of 
certification bodies to its accreditation  body ASI. 
This means  that the monitoring  of certification 
bodies is independent  and SBP  is not involved  in 
the process.  
Justification 

Monitoring  of certification bodies is independent  and 
SBP  is not involved in the process. 
Findings 

Covered 

ASI Procedure  on Surveillance  & Sampling:  ASI-
PRO-20-105-Surveillance  & Sampling-V6.4 

Scheme info 

5.1.1 At least once per calendar year, ASI shall 
review  all assessment  results and other relevant 
information  (e.g. complaints,  incidents,  stakeholder 
input,  business profile, etc.) for each CAB, since the 
date of the previous review . 

The  accreditation Body Assurance Services 
International  (ASI) (full member  of the ISEAL 
Alliance) is the accreditation  body for SBP 
certification. Their  procedures can be found here: 

5.1.2 ASI shall  modify and adjust the annual 

ASI Procedure  on Surveillance  & Sampling:  ASI-
PRO-20-105-Surveillance  & Sampling-V6.4 

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sampling  plan  based on the results of the CAB 
Performance  Review . 

5.2.1 Follow ing  the CAB Performance  Review , ASI 
shall prepare an assessment plan for the 
forthcoming  year for each CAB, follow ing the 
sampling  design described in this procedure. 

C.4 Certification process 

C.4.1 

Compliance 
evaluation 

Standard  3 

Instruction  Note  3D:  Non-compliance  – SBP 
requirements  for CBs 

1.3 The CB  shall identify and evaluate  each non-
compliance  to determine  w hether it constitutes a 
minor  or major  non-compliance.  Non-compliances 
shall result in corrective action requests, and, in 
some  cases, suspension or w ithdraw al of the 
certificate. 

C.4.1.1 The  Scheme 
shall include 
requirements  that 
ensure that the 
Certification  Bodies 
applies  a clear basis 
for:  
i) establishing 
conformance;  
ii) raising corrective 
actions for non-
compliance,  and;  
iii) certification decision 
making. 

814 

Certification  Bodies performance is assessed 
annually  by the accreditation  body. There  are 3 
w itness audits of CB  auditors and 1 office-audit. The 
frequency is decided by the accreditation  body. 

Justification 

There  are procedures for determining  the frequency 
of oversight, but these are decided  by ASI and not 
SBP.  Since ASI is a w ell-know n accreditation  body, 
this is seen as acceptable. 

Findings 

Scheme info 

Covered 

This is ensured through  requirements  in the 
accreditation  Standard  3. 

Non-conformances  shall be addressed and the 
process for it is described in  Instruction  Note 3D. 
This Note  describes how  the level of non-
conformances shall be set, timeframes  for corrective 
actions and if the actions are adequately  addressed. 
The  effect of non-conformances on the certificate is 
also described in this Instruction  Note.  See, for 
example,  requirement  1.3 in Instruction  Note 3D. 

Justification 

The  accreditation Standard  addresses how  CBs 
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C.4.1.2 The  Scheme 
requirements  for 
establishing 
conformance should 
enable  comparison  w ith 
the definition  of 
negligible  and non-
negligible  risk as 
outlined  in the EUTR 
and associated guides.   

relevant Standards,  issuing non-compliance  and 
evaluate  corrective actions. It  is also described how  
certification decisions shall be made.   

Standard  3 

7 Basic principles   

Findings 

Scheme info 

Partially 
Covered 

7.2 In order to provide such an  assurance, the CB 
shall: 

c) Conduct  adequate  and appropriate  sampling  and 
review  of sites, documents,  management  records, 
interview s, consultations  w ith stakeholders  and 
direct observations, in order to verify that there is 
full 

Both the performance of certificate holders and how  
they have built  up their management  system is 
evaluated  in the SBP  scheme.  Any non-
conformances are recorded in the evaluation  report 
and all open non-conformances  at the closure of the 
annual  audit can be found in the public  summary 
report on SBP’s  w ebsite under each certificate 
holder. 

For BPs  w ith supply base evaluations  in scope, their 
risk rating and supplier verification program 
including  risk mitigation  measures  is monitored  by 
the certification body. 

The  basic principles  section (7) in Standard  3 
includes requirements  for certification bodies  to 
control during audits.  For example,  “review  of sites, 
documents,  management  records, interview s, 
consultations  w ith stakeholders  and direct 
observations” (7.2c). 

Certification  bodies define a timeframe  (up to 3 
months  for major  non-conformities  and up to the 
next audit  for minor  non-conformities)  in the case 
of initial  assessments (minor  non-conformities 
only) and surveillance  audits (minor  and major 
non-conformities).  There  is a potential  risk that a 

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non-conformity  may represent an infringement  of 
legislation  and that, as a result, illegal  w ood may 
enter the EU  market  w ithout mitigation  measures 
to prevent this from occurring for a period  of up to 
3 or 12 months. 

Justification 

This indicator  has been evaluated  as Partially 
Covered.  Requirements  for non-conformities  are 
structured in a w ay that there is a potential  risk that 
a non-conformity  may represent an infringement  of 
legislation  and that, as a result, w ood may  enter the 
EU  market  that could be interpreted  as illegal  or 
non-negligible  risk. 

C.4.1.3 The  Scheme 
shall include 
requirements  that 
ensure that the above 
requirements  are in line 
w ith the requirements  of 
the EUTR  to prohibit 
illegal  material  or 
material  w ith a non-
negligible  risk category 
being  placed on the EU 
market. 

Standard  4 

6.1 EUTR  compliance 

Findings 

Scheme info 

Partially 
Covered 

6.1.2 SBP  certificate holders exporting SBP-certified 
biomass  to countries under the scope of the EUTR 
shall exercise due diligence  to ensure that these 
feedstock do not contain illegally  harvested timber. 

The  SBP  scheme  has, in several places, 
requirements  related to legality  in harvest related 
activities. For example,  in several indicators  in 
Standard  1. Requirement  6.1.2 in Standard  4 is 
the most general  requirement  and includes all 
biomass  exported to a country that implements 
the EUTR.  This requirement  is also applicable  to 
all certificate holders. 

Certification  bodies define a timeframe  (up to 3 
months  for major  non-conformities  and up to the 
next audit  for minor  non-conformities)  in the case 
of initial  assessments (minor  non-conformities 
only) and surveillance  audits (minor  and major 

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non-conformities).  There  is a potential  risk that a 
non-conformity  may represent an infringement  of 
legislation  and that, as a result, illegal  w ood may 
enter the EU  market  w ithout mitigation  measures 
to prevent this from occurring for a period  of up to 
3 or 12 months. 

Justification 

This indicator  has been evaluated  as Partially 
Covered.  Requirements  for non-conformities  are 
structured in a w ay that there is a potential  risk 
that a non-conformity  may represent an 
infringement  of legislation  and that, as a result, 
non-negligible  w ood may  enter the EU  market 
w ithout mitigation  measures  to prevent this from 
occurring for a period of up to 3 or 12 months. 

C.4.1.4 The  Scheme 
shall include 
requirements  that 
ensure that the decision 
process to certify 
organisations,  or 
maintain  certification of 
CHs,  is free from 
conflict of interest and 
includes checks and 
balances. 

Standard  4 

Standard  5 

Findings 

Scheme info 

Covered 

Material  balances are monitored  through the DTS 
w here claims  of biomass  are transferred. Biomass 
balances are also controlled  during  audits at BPs. 
They must  report losses due to drying of biomass  or 
other reason. The  production  of biomass  is 
compared  to be consistent w ith inputs. 

Purchase  and sales documents  are also controlled, 
but the place w here this shall be recorded is in DTS. 
This system gives auditors a good overview  and is 
simple  to summaries  in relevant w ays. 

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ANNEX 6 : SCHEME ASSESSMENT REPORT – SUSTAINABLE BIOMASS PROGRAM 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

Conflict  of interest is accessed by the certif ication 
body before the auditor  assess a certificate holder. 
This is an accreditation  requirement  (ISO/IEC 
17065:2012).   
Justification 

The  SBP  system includes requirements  that ensure 
the decision-making  process is not affected by 
conflicts of interests.  Transactions  of SBP-biomass 
is alw ays made  through DTS  and balances 
controlled  during audits. 

818 

 
 
 
 
 
ANNEX 6 : SCHEME ASSESSMENT REPORT – SUSTAINABLE BIOMASS PROGRAM 

Annex 1. References 

Agros, Human / VPRO (authors: Catherine Joie, Piret Reiljan, Paul Toetzke, Sophie Blok, 
Burn. 
Ties  Gijzel, 
https://www.vpro.nl/argos/lees/onderwerpen/money-to-burn/interactive  

Sheffield).  Money 

Silvia  Nortes 

and  Hazel 

To 

Altinget, 2020. https://www.altinget.dk/foedevarer/artikel/dn-om-brug-af-biomasse-vi-roser-
ministeren-for-at-tage-problemet-alvorligt   

ASI (Assurance Services International): http://www.asi-assurance.org  

Bioenergy Europe, 2020. A recent project titled “Money to Burn” investigates the bioenergy 
industry, putting forward some oversimplified and misleading claims. In addition to the well -
known  emotive  claims,  it  is  important  to  address  some  fundamental  misconceptions 
presented.  
https://bioenergyeurope.org/index.php?option=com_content&view=article&id=280    

Biomass UK, 2020.  How sustainable biomass works  – a response to the "Money to Burn" 
report.  
https://www.biomass-uk.org/post/how-sustainable-biomass-works-a-response-to-the-money-
to-burn-report   

Earthsight,  2018.  COMPLICIT  IN  CORRUPTION  -  How  billion-dollar  firms  and  EU 
governments are failing Ukraine’s forests. 
https://www.earthsight.org.uk/news/investigations/complicit-in-corruption-report   

Estonian  Fund  for  Nature  (ELF),  2020.  Hidden  inside  a  wood  pellet:  Intensive  logging 
impacts in Estonian and Latvian forest.  https://elfond.ee/biomassreport   

ING  (author:  Jacob  Christian  Eriksen),  2021. Danmark fyrer med biomasse fra beskyttet 
natur i Estland og Letland.  
https://ing.dk/artikel/danmark-fyrer-med-biomasse-beskyttet-natur-estland-letland-
242776?utm_source=nyhedsbrev&utm_medium=email&utm_campaign=ing_daglig   

ISEAL Alliance: https://www.isealalliance.org/about-iseal/who-we-are   

Forest 

Destruction 

NRDC, (author: Debbie Hammel), 2017. The Sustainable Biomass Program: A Smokescreen 
for 
Non-accountability. 
and 
https://www.nrdc.org/resources/sustainable-biomass-program-smokescreen-forest-
destruction-and-corporate-non, 
https://www.nrdc.org/sites/default/files/sustainable-biomass-program-partnership-project-
ip.pdf and  
https://www.nrdc.org/sites/default/files/sustainable-biomass-program-partnership-project-
fs.pdf   

Corporate 

SBP (Sustainable Biomass Program): https://sbp-cert.org/   

819 

 
ANNEX 6 : SCHEME ASSESSMENT REPORT – SUSTAINABLE BIOMASS PROGRAM 

SBP,  2019.  Sustainable  Biomass  Program  Annual  Review  2019:  The  promise  of  good 
biomass. https://sbp-cert.org/wp-content/uploads/2020/04/SBP_AR2019_FINAL-1.pdf   

TV2,  2020.  Alvorlig  kritik  af  klima-kontrol:  Det  er  svært  at  have  tillid  til  den  ordning. 
https://nyheder.tv2.dk/samfund/2020-02-25-alvorlig-kritik-af-klima-kontrol-det-er-svaert-at-
have-tillid-til-den-ordning  

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ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

Annex 7: International Standard Assessment 
Report 
ISO 38200:2018 

821 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

Table of Contents 

Executive summary ................................................................................................. 823 

Introduction............................................................................................................... 827 

Acronyms ................................................................................................................. 828 

1.  Overview of ISO ............................................................................................... 829 

Governance of ISO .............................................................................................. 829 

The Chain of custody of wood and wood-based  products: ISO Standard 
38200:2018........................................................................................................... 830 

Scope of this evaluation....................................................................................... 834 

2.  Overview of the certification standards used for this analysis  ....................... 835 

3.  Evaluation methodology................................................................................... 836 

4.  Overview of findings ......................................................................................... 837 

5.  Evaluation ......................................................................................................... 840 

A. Requirements for Certificate Holders  ............................................................. 840 

A.1 Legal Requirements at the forest level......................................................... 840 

A.2 Legal requirements for supply chain entities ............................................... 856 

A.3 Requirements for material control ................................................................ 861 

A.4 General requirements for Certificate Holders  .............................................. 867 

A.5 Quality and procedural requirements for Certificate Holders ...................... 868 

B. Requirements for Certification Bodies ............................................................ 871 

B.1 General Certification Body requirements ..................................................... 871 

B.2 Certification Body requirements for auditing and certification  .................... 874 

C. Requirements for Certification Schemes ....................................................... 878 

C.1 Transparency................................................................................................. 878 

C.2 Scheme & standard scope............................................................................ 880 

C.3 Accreditation and oversight .......................................................................... 882 

C.4 Certification process...................................................................................... 887 

Annex 1. References ............................................................................................... 890 

822 

 
 
 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

Executive summary 

The standard “ISO 38200:2018 Chain of custody of wood and wood-based products” sets 
requirements  for  a  chain  of  custody  system  to  enable  the  exchange  and  tracking  of 
information on wood and wood-based products throughout a supply chain.  

It includes traceability measures (CoC) as well as due diligence requirements to ensure 
that only legal input material is included in the CoC system.  

ISO 38200 is an international standard and not a forest certification scheme. This means 
there are no normative requirements developed for the accreditation of certification bodies 
certifying  against  the  standard,  and  it  is  important  to  note,  that  the  standard  is  not 
intended for certification only. The Standard is intended to be used for several purposes: 

– 

facilitate business-to-business communications by providing a common framework 
that allows businesses to “speak the same language” when describing their chain 
of custody system (regardless of company size) 

–  For  purchasers  to  evaluate the information they receive from suppliers to help 

identify suitable input material 

–  For other standards and certification schemes to use the ISO 38200:2018 as a 

reference regarding chain of custody systems 

The  due  diligence  system  of  ISO  38200  shall  include  the  elements  of  information 
gathering,  risk  assessment  and  mitigation  measures.  The  organization  must  develop 
documented  procedures,  as well as document and keep records of their implemented 
mitigation measures. Annexes with guidance on applicable legislation, risk indicators and 
description of CoC is included, but are not mandatory to follow.  

All input material covered by the chain of custody system of ISO 38200 will have to be 
assessed  following  the requirements of the standard and the ones established by the 
organisation responsible for the CoC Input material shall be classified as verified (by the 
due diligence system, certified, specified (verified material classified following additional 
requirements established by the organisation), as well as recycled material. For recycled 
material  it  shall  be  verified  that  it  is  material that has been recovered from the waste 
stream, either from the manufacturing process [i.e. post-industrial recycled materials, but 
not in-house scrap] or after consumer use. 

Considering  that  ISO  adopts  the  neutrality  principle  when  it  comes  to  conformity 
assessment, its International Standards, such as ISO 38200, must allow that 1st, 2nd and 
3rd  parties  are  able  to  evaluate  their  implementation.  In  practice  this  means  that  an 
organization  can  claim  compliance  with  the  standard  without  a  3rd  party  conformity 
assessment. Certification against the standard can only be issued by a 3rd party, but the 
accreditation  of  the  certification  body,  although  a  normal  practice  worldwide,  is  not 
required.  

Overall findings 

ISO  38200  generally  partially  cover  the  indicators  of  the  evaluation  framework.  48 
indicators of the evaluation framework are partially covered, while 11 are covered, 25 are 
not covered. Below is a written summery of the evaluation findings split into requirements 
for  the  certificate  holders,  which  will  also  apply  for  non-certified  companies  claiming 
compliance with the Standard. 

Information, such as common name of tree species (or scientific name if needed), country 
of harvest, and evidence that applicable legal requirements are fulfilled shall be collected 
for input material, except recycled and certified material. There are clear requirements for 
DDS  to  be  conducted  when  information  is  changed.  According  to  the  EUTR  certified 

823 

 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

material  is  not  exempt  from  the  requirement  of  applying  due  diligence,  including  the 
requirement to gather information on species and origin or evidence of legal compliance. 
However, this information is not required to be collected for certified material under the 
ISO 38200 standard. So, while information to be collected for non -certified material is in 
conformance with the EUTR, this is not the case for certified material.  

The standard is clear in requiring that only legally harvested and legally procured material 
can enter the chain of custody system of a company. To avoid illegally harvested and 
procured material a risk assessment shall be developed based on relevant risk indicators, 
and  illegal  harvesting  of  CITES  listed  or  nationally  protected  species  are  specifically 
mentioned. Other relevant categories of law are listed in annexes that provide general 
guidance  on  identifying applicable legislation. The legality definition of Annex E of the 
standard is a replication of the definition of applicable legislation found in the EU T imber 
Regulation (Regulation 995/2010). However, these annexes are informative and therefore 
not mandatory to follow. 

The organisation must identify the legal requirements applicable to their supply chain and 
document how the requirements are addressed. The coherence of these processes is 
checked during audits. The risk assessment process itself is generally in compliance with 
the EUTR, but it is unclear how it is implemented in practice, as there is little guidance in 
place  for  organisations  (and  for  certification  bodies)  on  how  to  interpret  legislation, 
evaluate risks and apply risk mitigation.  

In  the  following  sections,  this  executive  summary  highlights  only  areas  of  significant 
strength in the scheme or areas where significant gaps or areas of lower coverage were 
identified. 

It  should  be  noted  that this report reflects an evaluation that has only considered the 
normative  and  guidance  documents  relevant  to  the  scheme.  Consideratio n  of impact 
studies  and  other  information  relating  to  the  performance  of  certification  schemes  in 
general, are included in a Meta-report which brings together findings in relation to all five 
schemes.  

Coverage by the scheme of legal requirements at the forest level  

For users inside the EU it is expected that they meet legal requirements (also the EUT R) 
according to Section 5.3.2 of the standard, and therefore use the definition of legality of 
the  EUTR.  However,  for  ISO  38200  certificates  originating  outside  the  EU,  different 
definitions of the applicable legislation may have been used in the due diligence system, 
which means that there cannot be made a firm conclusion on the legality definition being 
applied on material sourced outside the EU under an ISO 38200 certification. Also, there 
is  no  requirement  in the standard for the organisation buying material certified to ISO 
38200 to evaluate the legality definition being used by suppliers.  

This fact constitutes a potential gap in the ISO 38200:2018 certif ied supply chain, that 
could allow material with an inadequate legality definition in the due diligence system, to 
enter the EU market with a certified claim. The standard leaves room for companies to 
define  the  categories  of  relevant  legislation  against  which  they evaluate legality risks 
under  their  due  diligence  system  that  are  not  necessarily  in  conformance  with  the 
categories of law defined under the EUTR.  

Thus, to know which legislation is evaluated under a company’s due diligence system it is 
necessary to look into each organisation’s specific due diligence system. 

The main issue in making an overall conclusion on what the scope will cover and how the 
standard is implemented relate to lack of specification of the mandatory requirements on 
what types of legislation shall be considered under the due diligence system, as well as 
detailed  guidance  to  interpret  the  standard  and  the  requirements.  The  Technical 

824 

 
 
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Committee ISO PC 287 is currently working on developing further guidance related to the 
due diligence implementation. 

The scheme has a definition of recycled material that correspond with the EUTR and there 
are  requirements  in  place  to  ensure  that  evidence  is  collected  to  show  that  input  is 
recycled material and has been legally procured. The definition and handling of recycled 
material are considered to be in conformance with the EUTR.  

System requirements 

The  system  requirements  for  certificate  holders (or companies in compliance with the 
Standard)  that  are  considered  fully  covered  by the standard relates to having a CoC 
system  (including  a  due  diligence  system)  in  place  to  ensure  compliance  with  the 
requirements of the standard. The organisation shall carry out annual audits to make sure 
that both the requirements of the standard and the organisations own requirements are 
well in place. Also, the organisation shall have the competence needed across all relevant 
personnel and suppliers.  

if  sourcing  certified  material  from  3rd  party  systems,  it  must  be  confirmed  that  the 
certification scheme has requirements to evaluate legality in forest management that is 
broad enough to cover the organization’s DDS. Evaluation of supply chain risks are not 
mentioned, and it is therefore unclear how supply chain risks on trade and taxes are to be 
covered by certification. 

The risk assessment process is generally in compliance with the EUTR but it is unclear 
how it is implemented in practice as there is a lack of detailed requirements/guidance on 
the evaluation of risks and applying the risk assessment process.  

The  standard  does  not  specifically  mention  that  the  organisation  shall  avoid  getting 
involved  in  corruption,  or  handling of disputes and conflicts. However, there are clear 
requirements for he company to operate legally.  

Requirements for Certification Bodies and Certification Schemes 

ISO 38200 is a standard and not a scheme, and there is therefore no mechanism with 
normative requirements in place related to the ISO 38200 standard on how certification 
bodies are accredited and managed. It should be underlined that the ISO 38200 was not 
developed  with  the  purpose  of  certification  of  wood-based  products,  but  as  an 
international standard that can be used for several purposes, including use by certification 
schemes as a reference to CoC systems, and for companies to communicate in the same 
language. 

As ISO 38200:2018 is no scheme, there is no mechanism with normative requirements in 
place related to the ISO 38200 standard on how certification bodies are accredited and 
managed. Certification bodies can operate without an accreditation. Also, it is voluntary for 
accreditation bodies to accredit against ISO standards on conformity assessments. T his 
means that there is no streamlined approach for the implementation of ISO 38200, and it 
is not possible to evaluate the global application/implementation of the standard through 
publicly available documents. Therefore, there can be differences in the requirement for 
accreditation and for CBs certifying against ISO 38200, both from country to country, as 
well as between certification bodies within one country.  

This  can  allow for a more flexible use of the standard and provides for alternatives to 
companies who want an alternative to other CoC certification schemes. 

The standard considers outsourcing in terms of the organisations Co C system and clear 
identification of the material being handled under outsourcing. Beyond that, there are no 
mandatory  scheme  requirements  in  place  to  manage  the  process  of  certification. 
According to the Technical Committee, certification bodies commonly use ISO standards 

825 

 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

for developing their systems, but it is not possible to make such conclusion based on this 
standard evaluation.  

There is no international oversight mechanism of the ISO 38200 standard implementation. 
ISO  38200  does  not  define  an  overall  system  in  place  to  monitor  the  overall 
implementation,  and  there  is  no  list  of  CBs  or  certificate  holders  available  at  an 
international level.   

The lack of guidelines and limited information on applying the standard means that it is not 
possible  to  make  an  overall  conclusion on the overall implementation of the standard 
related to this evaluation framework. This also relate to how competence of certification - 
and accreditation bodies are ensured.   

826 

 
 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

Introduction 

The  objective  of  the  Study is to create a  resource of knowledge and reference for all 
interested and concerned parties in the forest and wood-based products sector. It should 
help  Competent  Authorities,  Operators  and  Monitoring  Organisations  covered  by  the 
EUTR  in  their  understanding  of potential  benefits and shortcomings of certification, in 
particular  in  the  context  of  the  implementation  of  the EUTR. As such, one part of the 
overall  objectives  is  to  create  an  overview  of  existing  certificates,  third -party  verified 
schemes and certifying bodies issuing certificates with regard to forests and wood -based 
products  and to evaluate their respective strengths and weaknesses in respect to the 
EUTR obligations. This should, in turn, encourage stronger standards and transparency of 
certification and third part verification schemes. 

It should be underlined that it is NOT the intention of the study to create a compliance 
checklist  of  certification  schemes.  The  EUTR  continues  to  recognise  third  party 
certification as an important potential tool for risk assessment and risk mitigation but does 
not  recognise  certification  as  proof  of  compliance. This will not change based on this 
study. 

As part of the above objective, this framework has been developed to allow evaluation of 
the  differences  and  uniformities  between  certificates  and certifying bodies. It includes 
requirements  to  assess  to  which  degree different forest certification schemes provide 
assurance of low (negligible) risk of ‘legal non-compliance’ of certified material.  

The  Framework  aligns  with  the  definitions  and  approach  to  certification  schemes  as 
described within the EU Timber Regulation (No. 995/2010) and the associated Guidance 
Document,  along  with  additional  requirements  for  the  use  of  third  party  certification 
schemes as outlined in the Commission implementing Regulation (EU) No 607/2012 and 
specifically Article 4 in the Commission Implementing Regulation (EU) No 607/2012.  

The Framework takes into account verifiers for Article 6 in the EUTR, and documentation 
for  Article  4  of  the  Implementing  Regulation,  as  well  as  a  wide  array  of sustainability 
standards and benchmarks used in the areas of forest and wood -based products, among 
other resources identified under References. 

The  Framework  aligns  with  the  definitions  and  approach  to  certificatio n  schemes  as 
described within the EU Timber Regulation (No. 995/2010) and the associated Guidance 
Document,  along  with  additional  requirements  for  the  use  of  third  party  certification 
schemes as outlined in the Commission implementing Regulation (EU) No 60 7/2012 and 
specifically Article 4 in the Commission Implementing Regulation (EU) No 607/2012.  T he 
Scheme  Assessment  Framework  has  been  developed  by  Preferred  by  Nature  as  a 
comprehensive  interpretation  of  the  EUTR  legality  definition  to  provide  the  abilit y  to 
evaluate in detail the different aspects of legality covered by the schemes included in this 
study.  

It  should  therefore  be  underlined  that  the  legality  definition  used  in  the  Assessment 
Framework is a comprehensive interpretation of the EUTR intended  to expand on the five 
legality categories included in the Regulation.   

The current report contains an assessment of the ISO 38200 Chain of custody of wood 
and wood-based products, and related standards. 

Note: ISO standards are copywrite protected and owned by ISO. It is prohibited to copying 
of it in whole or in parts without the permission from ISO. In this report, relevant indicators 
and headings of the standards evaluated have been listed. Only direct replication from the 
evaluated  ISO  standards  is  the  description  of  input  material  from  ISO 38200:2018, 3 
Terms and definitions used in “Overview of ISO”, p. 14 and in indicator A.3.1.1.3. The 
level of replication is considered fair use. 

827 

 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

Acronyms 

CB 

CASCO 

CoC 

Certification body 

Committee on Conformity Assessment 

Chain of Custody 

COPOLCO 

Committee on consumer policy 

CPAG   

CSC/SP 

CSC/FIN 

CSC/NOM 

CSC/OVE 

DEVCO 

ISO 

ITSAG  

TMB 

Commercial Policy Advisory Group 

Council Standing Committee on Strategy and Policy 

Council Standing Committee on Finance 

Council Standing Committee for Review of Nominations 

Council Standing Committee on Oversight 

Committee on developing country matters  

International Organization for Standardization 

Information Technology Strategy Advisory Group  

Technical management Board  

828 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

44.  Overview of ISO 

ISO  is  the  International  Organization  for  Standardization. It was set up in 1947 and is 
located  in  Geneva,  Switzerland.  Its  purpose  is  to  facilitate  and  support  national  and 
international trade and commerce by developing standards that people everywhere wo uld 
recognize and respect.  

ISO  develops  standards  that  can  be  applied  on  a  voluntary  basis.  Standards  are 
developed  for  different  kinds  of  goods,  services  and  systems  through  the  different 
technical  committees  that  constitutes  of  experts  within  the  field  for  which  they  are 
developing standards (iso.org, N.Y(e)). ISO is not a certification scheme.  

Governance of ISO 

ISO achieves this purpose through the participation and support of its members. These 
members come from 165 national standards bodies. 

ISO standards are developed by technical committees. The people who serve on these 
technical  committees  come  from  national  standards organizations. Consequently, ISO 
standards  tend  to  have  worldwide  support.  Currently,  ISO  has  250  active  technical 
committees, 510 subcommittees, and 2478 working groups. 

The General Assembly is the overarching organ and ultimate authority of ISO (ISO.org, 
N.Y(c)). The ISO Council is the core governance body of the Organization and reports to 
the  General  Assembly  where  the  member  organizations  meet  annually.  A  Technical 
Management  Board  (TMB)  is  responsible  for  the  technical  committees  that  lead  the 
standard development and reports to the Council. The Central Secretariat in Geneva, 
Switzerland coordinates the ISO system and runs day-to-day operations. 

There are three member categories within ISO. Each has a different level of access and 
influence over the ISO system (Copied from ISO.org, N.Y(b)).  

 

“Full  members  (or  member  bodies)  influence  ISO  standards  development  and 
strategy  by  participating  and  voting  in  ISO  technical  and  policy  meetings. Full 
members sell and adopt ISO International Standards nationally. Full members are 
referred  to as national standards bodies. There is only one national standards 
body per country, and the NSB will be appointed by the respective government.  

  Correspondent members observe the development of ISO standards and strategy 
by  attending  ISO  technical  and  policy  meetings  as  observers.  Correspondent 
members  that  are  national  entities  sell  and  adopt ISO Inter national Standards 
nationally. Correspondent members in the territories that are not national entities 
sell ISO International Standards within their territory. 

  Subscriber members keep up to date on ISO’s work but cannot participate in it. 

They do not sell or adopt ISO International Standards nationally.” 

Companies and individual persons cannot become ISO members, but it is possible for 
these  groups  to  contribute  to  the  standard  development  by  contacting  the  technical 
committees  through  their  national standards bodies (NSB), as well as to participate in 
stakeholder consultation iso.org, N.Y(d). Standards in consultation are published online, 
and access can be obtained for a fee or through the NSB's consultation platforms. To 
provide  stakeholder  comments  the  stakeholder’s  national  member  shall be contacted 
(iso.org, N.Y(d)).  

829 

 
 
 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

Figure1:  Overview  of  the  ISO  governance  structure.  Source:  ISO,  Structure  and 
Governance. Available at ISO.org, N.Y(c): https://www.iso.org/structure.html  

The national standards bodies can adopt and sell ISO International Standards nationally. 
If  and  how  a  standard  is  adopted  nationally  is  decided  by  the  stakeholders.  Such 
approach must be transparent and conducted with the participation of stakeholders, the  
adoption  of  a  standard  takes  place  after  the  document  is  approved  on  a  public 
consultation process. (ISO Call-5/11/2020 - Representative Project Committee ISO/PC 
287).  

The  Chain  of  custody  of  wood  and  wood-based  products:  ISO  Standard 
38200:2018 

ISO 38200:2018 Chain of custody of wood and wood-based products was developed by 
the  technical  committee  ISO  PC  287  and  was  published  in  2018.  The  International 
Standard  provides  a  set  of  requirements  for a chain of custody system to enable the 
exchange and tracking of information on wood and wood-based products throughout a 
supply chain. ISO 38200 requires the implementation of a due diligence system based on 
risk management practices to ensure that materials entering the CoC has a legal origin.  

ISO 38200:2018 overview 

ISO 38200 was designed to provide a consistent basis against which the chain of custody 
of  wood and wood-based products can be assessed. It includes traceability measures 
(CoC) as well as due diligence requirements to ensure that only legal input  material is 
included in the CoC system. The Standard is intended to be used for several purposes 
(based on the ISO 38200:2018 Introduction and section 1. Scope): 

– 

facilitate business-to-business communications by providing a common framework 
that allows businesses to “speak the same language” when describing their chain 
of custody system (regardless of company size) 

–  For  purchasers  to  evaluate the information they receive from suppliers to help 

identify suitable input material 

–  For Other standards and certification schemes to use the ISO 38200:2018 as a 

reference regarding chain of custody systems 

ISO 38200:2018 sets requirements for setting up a CoC and due diligence system. The 
due diligence system shall include the elements of information gathering, risk ass essment 
830 

 
 
 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

and mitigation measures. The organization has to develop documented procedures, as 
well as document and keep records of their implemented mitigation measures. Annexes 
with guidance on applicable legislation, risk indicators and description of CoC is included, 
but are not mandatory to follow.  

Certification against the ISO standard 38200 

Considering  that  ISO  adopts  the  neutrality  principle  when  it  comes  to  conformity 
assessment, its International Standards must allow that such processes are conducted  by 
1st, 2nd and 3rd parties. In practice this means that an organization can claim compliance 
with  the  standard  without  a 3rd party conformity assessment, but to claim certification 
against ISO 38200 requires a 3rd party assessment by a certification body. It is however, 
not required for the certification body to be accredited by an accreditation body to certify 
against ISO 38200. Even if the CB is accredited, the accreditation body will not have to 
follow  the  ISO  standards  on  conformity  assessment  for  accreditation and certification 
bodies  (e.g. 
ISO/IEC  17011:2017  (Conformity  assessment  –  Requirements  for 
accreditation  bodies  accreditation  conformity  assessment  bodies),  and  ISO/IEC 
17065:2012  (Conformity  assessment  –  Requirements  for  bodies  certifying  products, 
processes and services).  

In other words, it is voluntary for a CB to follow an accreditation process. T herefore, it is 
possible that a 3rd party certification can be done by CBs without an accreditation and 
without  using  CASCO  standards  (ISO/IEC  17000  standards).  According  to  ISO,  non-
accreditation does not necessarily mean a CB is not reputable, but an accreditation will 
provide independent confirmation of competence. An organisation can find an accredited 
CB  by  contacting  the  national accreditation body in the applicable country or visit the 
International Accreditation Forum (www.iaf.nu). https://www.iso.org/certification.html. T he 
system  requirement  standards  are  developed  by  ISO  as  general  standard  for  all 
certification  process,  but  not  embedded  in  ISO  38200.  Because  of  this  there  can be 
differences in the system requirements for accreditation and for CBs certifying against ISO 
38200, both from country to country, as well as between certification bodies within one 
country.  

ISO 38200 can be applied under the following scenarios99: 

  1st party conformance evaluation. An organization can claim compliance with ISO 

38200 based on 1st party evaluation. 

  2nd party conformance evaluation; e.g. the purchaser/or interested party who want 

to evaluate the ISO 38200 compliance of an organisation.  

  3rd party evaluation (certification) 

o  Certified by a non-accredited CB. There is no independent confirmation of 

competence. 

o  Certified  by  a  CB  with  accreditation  from  an organisation that does not 
accredit against the ISO 17000 standards. Again, this does not necessarily 
mean that the accreditation body is not competent, but requirements of the 
CB and accreditation body will have to be evaluated on an individual basis.  
o  Certified  by  a  CB  that  is  accredited  by  an  accreditation  body  following 
ISO/IEC  17000  standards.  This  approach  ensures  that  the  supporting 
scheme  around  the  certification  process  are  in  line  with  international 
recognized standards for accreditation and certification. 

It is up to the organization wanting to get certified to look into the CB and the accreditation 
process and it is up to a buyer to evaluate how a supplying organisation are considered to 
be in compliance with ISO 38200. Certification against the ISO 38200 can be issued, but 
an organisation cannot claim that its products are ISO 38200 certified, since the standard 

99 More information about conformity assessment can be found: https://casco.iso.org/attestations-of-conformity.html  

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establishes  requirements  for  the  implementation  of  a  CoC  system.  The  document, 
however, when used in conjunction with a framework providing specific requirements for 
the characteristics of inputs/outputs, can be used to communicate particular aspects of a 
product.  

There is no international oversight mechanism of the ISO 38200 standard implementation, 
CBs or certificate holders. 

While  the  implementation  of  the  ISO  38200  standard  is  done  at  na tional  level,  the 
technical  committee  ISO/TC  287  Sustainable  processes  for  wood  and  wood-based 
products100, continues to work on the standard. The committee is overseeing the technical 
aspects of the document, and currently (end 2020), the technical committe e is doing an 
assessment of the standard, and improvements are being discussed (this includes the 
due diligence system and guidance for the implementation, as well as implementation of 
CoC). (ISO Call-5/11/2020. Representative Project Committee ISO/PC 287). 

100 Webpage of ISO/TC 287 Sustainable processes for wood and wood -based products:  
https://www.iso.org/committee/4952370.html  

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Box 1: Due diligence and legality in the ISO standard 38200 

The standard contains two specific section addressing legality: 

In  5.3.2 the standard requires organisations to implement a procedure to “identify legal 
requirements applicable to the chain of custody” and “to determine how these requirements 
apply  to  the  chain  of  custody”,  and  “document  how  these  legal  requirements  are 
addressed”. 

Further to this annexes A, B and C includes informative guidance on which areas legislation 
could cover in the supply chain related to social welfare and employment, environment and 
trade and customs. 

The second place where legal requirements are addressed is in the due diligence part of 
the standard (7 Due Diligence System). Here there are requirements on informati on, where 
it is required in 7.2, f), that there shall be “evidence that the applicable legal requirements 
are fulfilled, including that applying to legally harvested material”. Here a reference is given 
to  Annex E, which outlines and informative guidance to which legal categories could be 
considered: 

“.. 

  Rights to harvest material within legally gazetted boundaries 
  Payment  for  harvest  rights  of  material  including  duties  related  to  harvesting  of 

material. 

  Environmental and forest legislation, including that covering forest management and 

biodiversity conservation, directly related to harvesting material. 

  Third parties´ rights concerning use and tenure that are affected by harvesting of 

material; and 

  Trade and customs, in so far as the forest sector is concerned.” 

As  can  be  seen  the  above  legality  definition  is  an  exact  replication  of the definition of 
applicable legislation found in the EU Timber Regulation (Regulation 995/2010). 

ISO  defined 

It  is  underlined  that  the  definitions  in  Annexes  A,  B,  C  and  E  are  only  guiding  a nd 
informative. 
that 
complements the user’s understanding (ISO, How to Write Standards, 2016, p. 13). It is 
therefore  not  required  to  include  the  legality  definition  of  the  annex in a due dili gence 
system in order to become certified. 

information  as:  “additional 

information 

informative 

This  would  mean  that  the  definition  of  the  legal  framework  applicable  to  the  forest 
harvesting activities that are to be evaluated under the due diligence system is based on 
the interpretation of the organisation using the standard. –  

It is expected that users meet legal requirements according to Section 5.3.2, and therefore 
for users within the EUTR the definition of legality shall be in line with the EUTR. However, 
for ISO 38200 certificates originating outside the EU, different definitions of the applicable 
legislation may have been used, which means that there cannot be made a firm conclusion 
on  the  legality  definition  being  applied  on material sourced outside the EU with an ISO 
38200 B2B claim. Also, there is no requirement in the standard for the organisation buying 
ISO 38200 certified material to evaluate the legality definition being used by suppliers.  

This fact constitutes a potential gap in the certified supply chain, that could allow material 
with an (according to the EUTR) inadequate legality definition in the due diligence system, 
to enter the EU market with a certified claim. As such this gap is reflected throughout the 
below evaluation as the potential gap is relevant for all aspects of the definition of legality. 

Input material 

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All  input  material  going  into  the  CoC  standard  will  have  to  be  verified. Verification of 
material  shall  be  done  in  accordance  with the organization’s own procedures and set 
requirements.  

The  organization  implementing  the  standard  will  have  to  define  the scope of the due 
diligence system and classify input material as one of the following categories: 

–  certified material; verified material received with a certification status and meets 
the requirements of a particular certification scheme for which the organization can 
provide evidence of third-party certification to that scheme (3.9). It shall be verified 
that  certification bodies are independent, that the scheme has requirements to 
evaluate legality in forest management and is in conformance with the scope of the 
organization’s DDS, and that the certification has CoC requirements in place.  

–  verified  material;  material for which the organization can provide evidence of 

compliance with the requirements of the Due Diligence System (3.11) 

–  specified  material;  A  classification  of  verified  material  that  meets  publicly 
available documented specific requirements, set by organization(s) within a CoC 
and for which the organization provide information regarding the requirements as 
well  as  evidence  of  compliance  (3.10).  Organizations  can  set  up  their  own 
requirements for specified materials, but all input material will have to be assessed 
in  accordance  with  the  Due  diligence  system  requirements  of  the  ISO  38200 
standard  (clause  7).  The  specific  requirements  for  specified  material  shall  be 
documented and publicly available.  

The purpose of the specified material category is to allow companies to make clear 
communication  about  the  product  and  conformity  level  (ISO  Call-5/11/2020  - 
Representative Project Committee ISO/PC 287) 

– 

recycled material; material that has been recovered, or otherwise diverted, from 
the  waste  stream,  either  from  the  manufacturing  process  [i.e.  post -industrial 
recycled  materials,  but  not  in-house  scrap]  or  after  consumer  use  (i.e.  post-
consumer recycled materials), that is reused in the manufacture of new product, 
and  for  which  the  organization  can  provide  evidence  of  compliance  with  the 
requirements  of  the  Due  Diligence  System  (excluded  are by-products such as 
sawmilling by-products (e.g. sawdust, chips, bark) or forestry residues (e.g. bark, 
chips from branches, roots). Evidence shall be collected to verify that material is 
recycled  and  has been legally procured, but an actual risk assessment will not 
have to be conducted.  

Scope of this evaluation 

In  this  report,  only  ISO 38200:2018 criteria are evaluated. We are not evaluating any 
potential gaps of third-party certification systems, which may be used as certified material. 
It is important to keep in mind that in the case weaknesses are found in such certification 
systems,  this  will  also  be  a  potential  weakness  in  the  due  diligence  system  IF  an 
organization has used certified material as input to the CoC system. The standard does 
require the organization to evaluate the certification scheme and only to include material 
that is in conformance with their own COC/DD scope, but there are no requirements as to 
how this is evaluated, so it is not possible to assess as part of this evaluation.    

ISO  38200  is  a  standard  and  not  a  scheme.  There  is  no  mechanism  with  normative 
requirements  in  place  under  the  ISO  38200  standard  on  how certification bodies are 
accredited  and  managed.  As  in  line  with  the  ISO  system,  a  standard  can  be applied 
though 1st, 2nd and 3rd party conformity assessment, and certification bodies can operate 
without an accreditation. Also, accreditation bodies will not have to accredit against ISO 
standards on conformity assessments. This means that there is no streamlined approach 
for  the  implementation  of  ISO  38200,  and  it  is  not  possible  to  evaluate  the  global 

834 

 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

application/implementation  of  the  standard  through  publicly  available  documents. 
Therefore, the indicators on accreditation and CB requirements (B and C) can only be 
partly covered. 

The ISO 38200:2018 standard is still a newly developed standard and have, at the point of 
evaluation, not been widely implemented. It has not been possible to evaluate the impact 
of the standard based on what is currently available in the public domain.  

45.  Overview  of  the  certification  standards  used  for 

this analysis 

Type 

Norm ative 

General  

There are no normative references 
in the standard 

Guidance 
ISO/IEC  17011:2017  Conformity  assessment  — 
Requirements  for accreditation  bodies  accrediting 
conformity assessment bodies 

ISO/IEC  17065:2012  Conformity  assessment  — 
Requirements  for bodies  certifying products, 
processes and services 

Chain of 
Custody 

ISO  38200:2018  Chain  of custody of 
w ood and w ood-based products 

N/A 

Note: ISO 38200 is an international standard and not a certification scheme. There are 
therefore  no  normative  standards  in  place  for  the implementation and auditing of the 
standard.  

It  is  likely  that  the ISO management Quality management and Conformity as sessment 
standards are applied for accredited certification bodies and accreditation bodies, and 
therefore additional standards can be relevant for the report sections B and C. However, 
as  these  standards  are  not  normative,  it  is  not  a  requirement  to  follo w  the  standard 
requirements under ISO 38200 101. We have therefore not applied a full evaluation of the 
ISO standards, but evaluated a few selected standards (ISO/IEC 17011:2017 and ISO 
17065:2012) to exemplify the ISO system on conformity assessment.  

101 Note: As ISO 38200 is not a scheme Conformity Assessment standards cannot be normatively referenced in ISO 38200 .  
This is against the ISO/IEC Directives and applicable to all ISO standards. The system works  is that the st a n d a rd  wi l l b e  
picked up by the market that will build schemes around, which can then specify any requirements placed on CABs and  a n y 
specific applications or interpretations of requirements, where applicable as well as any specific applications or additions o f  
ISO/IEC 17011, if applicable. 

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ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

46.  Evaluation methodology 

The Standard is evaluated against Scheme Assessment Framework (SAF) and Scheme 
Assessment Procedure (SAP) in order to assess how the ISO Standard covers relevant 
requirements of the EUTR, and the criteria defined by the European Commiss ion as the 
basis for this Study. 

For each indicator, we will have a conclusion that will show the level of conformance of 
the Standard with the indicator: 

Conclusion 

Definition 

Covered 

When  available  Standard 
requirements  and information  - and 
any impacts  evidence available  - 
indicate  the coverage of the SAF 
indicator. 

When  available  Standard 
requirements  and information  - and 
any impacts  evidence available  - 
indicate  only partial coverage  of the 
SAF indicator.   

Partially Covered 

Alternatively,  special concerns about 
Standard  standards, credibility,  rigor 
or coverage may exist. 

Explanation 
Coverage  is the ability  of the Standard  to 
provide assurance that material  traded via the 
Standard  has a low  (negligible)  risk of being 
illegally  harvested, traded in line w ith the 
legality  definition  of the EU  Timber  Regulation. 

Partial  Coverage  means  the Standard is only 
partly able – or may be compromised  in one or 
more  w ays – to provide assurance that material 
traded via the Standard  has a low  (negligible) 
risk of being  illegally  harvested, traded in line 
w ith the legality  definition  of the EU  Timber 
Regulation.   

NOTE:  It is important  to justify the 
partial  coverage and indicate  w here 
the issues are w hich result in a 
Coverage  conclusion not  being  given. 
When  available  Standard 
requirements  and information  - and 
any impacts  evidence available  - 
indicate  that there is no coverage  of 
the SAF indicator. 

NOTE:  It is important  to justify a no 
coverage conclusion. 
When,  for w hichever reason, the SAF 
indicator  does not apply.   

Not Covered 

Not Applicable 
(N/A) 

The  Standard is not – or inadequately  – able  to 
provide assurance that material  traded via the 
Standard  has a low  (negligible)  risk of being 
illegally  harvested, traded in line w ith the 
legality  definition  of the EU  Timber  Regulation.   

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ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

47.  Overview of findings 

The below table includes an overview of the findings from the detailed assessment of the 
ISO  38200  and  other  relevant  ISO  standards  against  the  Scheme  Assessment 
Framework, as outlined in the following section of this report. 

It  is  highlighted  here  that  the  assessors  of  ISO  have  identified that the ISO standard 
38200  partially  cover  many  of  the  legality  requirements  in  section  A  of  the  Scheme 
Assessment Framework, mainly for the reasons outlined in Box 1. It is found that the fact 
that  the  ISO  legality  definition  is  only  included  as informative, may signify that supply 
chain entities upstream may have defined legality in a manner that is not consist ent with 
the  EUTR,  and  therefore  could  constitute  a  gap  in  the  ability  for  an  EU  operator  to 
evaluate risk of illegality for these specific issues. 

Requirements 

Requirement Section 
A. 
for Certificate Holders 
A.1 Legal 
Requirements at the 
forest lev el 

A.1.1 Rights to harvest 
timber within legally 
gazetted boundaries 
A.1.2 Payments for 
harvest rights and timber 
including duties related 
to timber harvesting 
A.1.3 Timber harvesting, 
including environmental 
and forest legislation 
including forest 
management and 
biodiversity conservation, 
where directly related to 
timber harvesting 

A.1.4 Third parties’ legal 
rights concerning use 
and tenure that are 
affected by timber 
harvesting 
A.1.5 Trade and 
customs, in so far as the 
forest sector is 
concerned 

A.2 Legal requirements 
for supply chain 
entities 
A.2.1. Legal registration 

A.2.2 Taxes and fees 

A.2.3 Trade and 
transport 

Conclusion  Summary 

Generally, indicators are considered partially covered as there are requirements 
in place to identify applicable legislation and only to source legal material. 
However, the identification of the specific material is guidance only and a re not 
detailed.  
Seven indicators are partially covered. Indicators are covered by guidance 
material but not required to obtain certification. 

Partially 
covered 

Partially 
covered 

Two indicators are partially covered. Indicators are covered by guidance 
material but not required to obtain certification. 

Partially 
covered 

Partially 
covered 

Partially 
covered 

Six indicators are partially covered, two indicators are not covered. 
Requirements to control potential illegal activities by third parties within the 
forest area managed by the operation are not included in ISO38200, and neither 
is examples of legal employment related specifically to the forest sector. 
Examples of legal employment relate to minimum working age, fo rced and 
compulsory labour, and discrimination and freedom of association. 

All other indicators are covered by guidance material but guidance is general 
and not mandatory to follow to obtain certification. 
Two indicators are not covered, while two indicators are partially covered.  
There are no requirements or guidance material on benefit sharing or FPIC.  

Two indicators are covered by guidance material, but guidance is general and 
not mandatory to follow to obtain certification. 
One indicator is fully covered, two indicators is not covered, and three  indicators 
are partially covered. 
There are normative requirements in place to comply with CITES.  
There are no normative requirements, nor guidance for classification of material, 
nor offshore trading, and transfer pricing.  

All other indicators are covered by guidance material but there are not 
mandatory to follow to obtain certification. 

Partially 
covered 
Partially 
covered 
Partially 
covered 

Indicators are covered by guidance material but not required to obtain  
certification. 
Indicators are covered by guidance material, but guidance is general and not 
mandatory to follow to obtain certification 
Three indicators are not covered. Three indicators are partially covered, and 
one is fully covered.  

There is no normative requirement, nor guidance for classification of material, 
offshore trading, and transfer pricing. 

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ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

A.3 Requirements for 
material control 
A.3.1 Material control 

Partially 
covered 

A.3.2 Recycled material   Covered 

There are requirements in place to assess  the prevalence of supplies of material 
harvested illegally according to restrictions and limitations set by CITES.  

All other indicators are covered by guidance material, but guidance is general 
and not mandatory to follow to obtain certification 

Four indicators are partially covered due to:  

 
 

 

Lack of information on species and origin for certified material 
The risk assessment  process  is generally in compliance with the EUTR 
but it is unclear how it is implemented in practice  and difficult to 
conclude fully covered at this point.  
Identification of applicable legislation to be defined by the organization. 
Risk  of legislation which is applicable under the EUTR is not included in 
the DDS scope of the organization. 

Three indicators are covered.  
The definition of recycled material in the ISO 38200 follows the EUTR definition. 
Collecting evidence of recycled material is required and are to  be verified or 
covered by the requirement of the due diligence system. 

A.4 General 
requirements for 
Certificate Holders 
A.4.1 Conflict resolution  Not covered  There is no reference to dispute management, and how to address these.  
A.4.2 Corruption 

There is no reference to corruption of the certificate holder, in the standard.  

Not 
Covered 
Partially 
covered 

A.5 Quality and 
procedural 
requirements for 
Certificate Holders 

A.5.1 Internal procedures 
for Certificate Holders 
A.5.2 Qualification and 
competence 
A.5.3 Risk based 
approaches to sourcing, 
trade or production 

Covered 

Covered 

Partially 
covered 

B. 
Requirements 
for Certification Bodies 
B.1 General Certification 
Body requirements 

Partially 
covered 

B.2 Certification Body 
requirements for auditing 
and certification 

Partially 
covered 

Five indicators are covered, two indicators are partially covered. 
A CoC system, which a DDS shall be in place, and annual audits shall be 
conducted. Risks shall be reassessed  if there is a change in risk in the 
supply chain. Staff shall have competence in place.  
The risk assessment  process  for DDS is generally in compliance with the 
EUTR but it is unclear how it is implemented in practice, as there is a lack of 
detailed requirements/guidance on the evaluation of risks  and risk 
assessment.  See eval A.1 

Certification schemes to be included in the DDS are required on ly to have 
competence to evaluate risks at forest level and it is therefore unclear how 
supply chain risks  on trade and taxes are to be covered by certification  

The  risk  assessment  process  is  generally  aligned  with  the  EUTR  but it is 
unclear  how  it  is  implemented  in  practice,  as  there  is  a  lack of detailed 
requirements/guidance on the evaluation of risks and risk  assessment 

There are no requirements for certification bodies in ISO 38200:2018  

Four indicators are covered under ISO 17065. General CB requirements are in 
place in ISO 17065, but the standard is not mandatory to be followed by CBs as 
not embedded in the ISO 38200.  
If it can be confirmed that an organisation is certified by a CB operating after 
ISO 17065 general certification body requirements can be considered to be 
covered.  
Two indicators are partially covered, three indicators are not covered. No  
detailed procedures in place for audits. And there is no requirement for 
stakeholder consultation and organizations sanctioned for corruption.  

A documented methodology shall for evaluation shall be applied by CBs, as well 
as having a methodology in place for evaluation of conformity, Review and 
certification decision, issuance of a certificate, and periodic surveillance. 

It should be noted that the three indicators Not covered by ISO 17065 or 17011 
could be covered by other CASCO standards. 17065 and 17011 were evaluated 
only to exemplify the ISO CASCO standards. 

Requirements 

C. 
for Certification 
Schemes 
C.1 Transparency 

Partially 

Four indicators are not covered, two indicators are partly covered. 

838 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

covered 

C.2 Scheme & standard 
scope 

Partially 
covered  

There are no normative scheme requirements for certification and 
accreditation bodies. It is possible to find public information about the 
development of ISO 38200. 
There are no overview of certified organization, summaries of full audit 
reports, it is unclear who deals with complains. 
There is no overall system to manage risk of corruption and conflict of 
interest in ISO 17076, 17011 or 38200.  
However, the way the system operates are sufficient to consider this 
indicator to be covered for certification conducted by CBs accredited in 
conformance with CASCO conformity assessment standards. 
Two indicators are not covered, one indicator is partially covered, one 
indicator is covered.  

Applicable legislation is not defined by ISO 38200:2018; accreditation body 
or certification body.  
The standard considers outsourcing in terms of the organisations CoC 
system and clear identification of the material being handled under 
outsourcing. 

C.3 Accreditation and 
oversight  

Partially 
covered 

Four indicators are partially covered, four indicators are not covered. 
As there are no normative requirements for certification and accreditation 
bodies and there is no overall oversight mechanism. There is no list of 
accredited certification bodies. 

C.4 Certification process  Partially 
covered 

If an accreditation body accredit against ISO 17000 conformance standards 
information of the accreditation body and process shall be public, 
requirements on competence, regularly evaluate the CBs, and the indicator 
would be considered to be covered.  
Under ISO 38200 However, this is not required and therefore not possible to 
conclude that the indicator is fulfilled without evaluating the applicable 
accreditation bodies system requirements.  
One indicator is not covered, three indicators are covered.  
There is a lack of thresholds for establishing conformance, and lack of 
scheme evaluation approach and decision making. 
According to ISO 17065 there are mechanism in place to ensure impartiality 
during the decision process, and there are requirements in place for auditors 
not to evaluate their own work.  

It is not possible the evaluate whether the actual use of low and high risk 
enable comparison with the negligible and non-negligible risk terms used in 
the EUTR  
The categories of applicable legislation are not defined in the document as 
normative. 

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ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

48.  Evaluation 

Code 

Criterion 

Indicators 

Standard reference  

Findings and Justification 

Conclusion 

A.  Requirements for Certificate Holders 
Requirements  applicable  to  the  Certificate  Holders.  These  include  requirements  to  comply  w ith  applicable  legislation,  as  w ell  as  requirements  relevant  to  ensuring  continued  performance  and 
integrity  of the operations  – as far as is related  to legal  compliance. 

A.1  Legal Requirements at the forest level 
This  principle  relates  to  how   the  scheme  ensures  that  Certificate  Holders  comply  w ith  all  applicable  legislation.  This  section  relates  to  requirements  of  the  Scheme  t hat  applies  to  Certificate 
Holders  - or other entities subject to the normative  requirements  of the Scheme  (e.g. included  w ithin the scope of a certified due diligence  system) - w ithin the Country of Harvest. 

A.1.1.1 

A.1.1 Rights to harvest tim ber within 
legally gazetted boundaries  
Land  tenure  and 
management 
rights 

A.1.1.1.1. The Scheme sh a l l 
that 
requirements 
include 
compliance  with 
ensure 
legislation 
land 
tenure 
including 
customary  rights  as  well  as 
management rights.  

covering 

rights, 

4 

general 

Findings 

Partially 
Covered 

ISO 
requirements 

38200:2018, 

ISO  38200:2018,  7  Due  Diligence 
System;  

ISO  38200:2018,  7.2.  general 
information required 

ISO 38200:2018, 7.5 Risk assessmen t  
process 

38200:2018, 

ISO 
E 
(informative)  Guidance  related  to 
legally harvested material 

Annex 

38200:2018, 

ISO 
F 
(informative)  Examples  of  low  and 
high risk indicators 

Annex 

840 

There are clear requirements to implement a due diligence syst e m  t o  e n su re  t h a t  
material source and included in a company CoC system is legal (ISO 38200:201 8,  4  
General requirements). 

Harvesting rights and Third parties ‘rights concerning use and tenure are examples of 
applicable legislation according to Annex E.  

Annex E is informative, meaning that it is additional information that complements the 
user’s  understanding (ISO - How to Write Standards, 2016, p. 13). It is therefore  n o t  
normative to include the examples of the annex in a due diligence system to becom e  
certified (ISO Call-5/11/2020 - Representative Project Committee ISO/PC 287).  

Some guidance has been provided on low and high-risk indicators in annex F. A lo w -
risk  indicator can be a harvest licence (provided that procedures conducted to obtain  
the licence are transparent, legal and open)” (F.1. f). The annex F is also informative  
and no further guidance is provided to evaluate land tenure rights.  

Direct interviews/ discussions / Stakeholder input 

It  is  not  specifically  stated which types of law shall be identified as applicable 
legislation,  but  all  legislation  relevant  to  the  CoC  shall  be  identified.  All 
organizations  will  have  to  comply with legal requirements applicable for their 
organization.  If  an  organisation  is  within  the  EU,  it  will  be  covered  by  the 

 
 
 
 
 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

Code 

Criterion 

Indicators 

Standard reference  

Findings and Justification 

Conclusion 

requirements  of  the  EUTR,  and  it  was  clarified  by  Project  Committee 
representative that the EUTR applicable legislation in such case will be applicable 
shall be identified as applicable legislati on under the ISO 38200 scope (ISO  Ca l l -
5/11/2020 - Representative Project Committee ISO/PC 287).  

Justification 

There  are  normative  requirements  in  place  to  ensure  that  evidence  is  to  be 
collected and recorded to ensure material is legally sourced in co m pli an ce wi t h  
applicable legislation.  

However, the applicable legislation is to be identified by the organization, and t h e  
identified legislation can therefore differ and there is a risk that not all categories of 
law  as  defined  by  the  EUTR  are  included.  While  it  is  clarified  by  ISO  that 
organizations based within the EU will have to follow the categories of appl ica b l e 
legislation defined by the EU, this is not applicable to organizati on s o u t si d e  t h e 
EU.  Material  sourced  as certified under ISO 38200 can enter the supply chain 
without having identified applicable legislation in conformance with the EUTR. 

There are requirements to identify applicable legislation and guidance is i n  p l a ce 
to address land tenure rights, including customary rights as well as mana g e m en t  
rights the indicator is considered to be partially covered. 

However, it cannot be concluded that land tenure rights, including customary rights 
as well as management rights are automatically covered by an organisation’s DDS 
under the ISO 38200, since the definition of applicable legislatio n i n  A n n ex E  i s 
informative only. 

The key issues  which result in a full Coverage conclusion not being given relate to: 

 

 

The applicable legislation is to be identified by an organization, and the 
identified legislation can therefore differ and there is a risk that not all 
categories of law as defined by the EUTR are included. Wh ile it is 
clarified by ISO that organizations based within the EU will have to 
follow the categories of applicable legislation defined by the EU, this is 
not applicable to organizations outside the EU. Material sourced as 
certified under ISO 38200 can enter the supply chain without having 
identified applicable legislation in conformance with the EUTR. 
Also, the guidance provided is rather general and it can be a challenge 

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Standard reference  

Findings and Justification 

Conclusion 

for a company to apply a due diligence system with strong risk 
conclusion and mitigation without detailed guidance/requirements.  

Findings 

Scheme info 

Partially 
Covered 

Annex E and F (both informative) 

i)  Harvest  licence  is  considered  a  low  risk  indicator  (annex  F)  provided  that 
procedures conducted to obtain the licence are transparent, legal and open.” 

ii) legislation related to Third parties’ legal rights concerning use and tenue that are 
affected by harvesting shall be considered. It is not further explained how this shall 
be considered.  

iii) Annex E states that applicable legislation includes that rights to harvest shall be 
within legally gazetted boundaries. 

iv)  It  is  stated  that  perception  of  corruption  is  a high -risk indicator in annex F. 
However,  it  is  not  clarified  how  it  should  be  evaluated  in  the  risk  assessment 
process. 

Justification 

There  are  no  normative  requirements in place to ensure that licenses, right of 
tenure and management rights, have been issued legally. In the guidance (an n e x 
E  and  F)  is  included the relevant points related to licenses, right of tenue and 
management rights. However, the guidance is quite vague, and it is not clear h o w 
to evaluate the perception of corruption. The guidance only specifies third part i es’ 
rights to be considered when legislation is in place, and there is no g u i d an ce o n  
how to consider conflicts with customary law.  

Therefore, the indicator is partly covered. 

requirements 

A.1.1.1.2. The Scheme sh a l l 
include 
to 
ensure  that  licenses,  right  of 
tenure  and  management 
rights, have been issued: 

i)    according  to  the  legally 
prescribed procedure, 

ii)  in  compliance  with  third 
parties' legal rights concerning 
tenure, 

iii)  specifying 
gazetted boundaries, and; 

the  legally-

iv)  with  absence  of  corrupt 
practices. 

38200:2018, 

ISO 
E 
(informative)  Guidance  related  to 
legally harvested material 

Annex 

ISO 
38200:2018,  Annex  F 
(informative) Examples of low a n d  
high risk indicators 

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Conclusion 

See also A.1.1.1.1, which relates to the same issue. 

requirements 

A.1.1.1.3  The  Scheme  shall 
that 
include 
ensure the existence of l e g a l 
business 
registration,  and 
other relevant legally required 
licenses.  

ISO 
38200:2018,  Annex  F 
(informative) Examples of low a n d  
high  risk  indicators;  F.1  Low  risk 
indicators 

Findings 

Scheme info 

A harvesting licence is mentioned as a low risk  indicator in Annex F. 

Justification 

A harvesting licence is mentioned as a low-risk guidance indicator. But otherwi se  
there is no reference to legal business registration and legally required licenses.  

See also A.1.1.1.1, which relates to the same issue. 

Findings 

Scheme info 

The standard does not specifically mention concession licenses. 

Justification 

Concessions  are  not  specifically  mentioned  in  the  standard.  However,  it  is 
mentioned in the guidance that applicable legislation includes Ri g h t s t o  h a rve st  
material within legally gazetted boundaries. This can be considered to apply a l so  
to concessions - See A.1.1.1 above. The indicator is therefore consi d e re d t o  b e  
partially covered.  

See also A.1.1.1.1, which relates to the same issue. 

A.1.1.2 

Concession 
licenses 

A.1.1.2.1  The  Scheme  shall 
that 
requirements 
include 
compliance  with 
ensure 
legislation 
regulating 
procedures  for  the  issuing  of 
concession licenses, including 
use of legal methods to obtain 
concession  licenses  and that 
licenses  are  covering  only 
legally gazetted areas 

38200:2018, 

E 
ISO 
(informative)  Guidance  related  to 
legally harvested material 

Annex 

843 

Partially 
Covered 

Partially 
Covered 

 
 
 
 
 
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Code 

Criterion 

Indicators 

Standard reference  

Findings and Justification 

ISO 38200:2018, 7.5 Risk assessmen t  
process 

38200:2018, 

ISO 
E 
(informative)  Guidance  related  to 
legally harvested material 

Annex 

Findings 

Scheme info 

See A.1.1.1.1. 

Conclusion 

Partially 
Covered 

A.1.1.3 

Management and  
harvesting 
planning 

and 

A.1.1.3.1  The  Scheme  shall 
requirements 
include 
that 
compliance  with 
ensure 
legislation 
legal 
obligations  for  management 
planning, including conducting 
forest  inventories,  having  a 
forest management plan  a n d 
related 
and 
monitoring. 

planning 

A.1.1.3.2  The  Scheme  shall 
include requirements th a t  a l l 
required  planning 
legally 
been 
have 
documents 
to 
approved 
prior 
implementation  of 
forest 
harvesting activities. 

A short reference to forest management is goven in Annex E.  

Justification 

The standard refers to a general requirement to have evidence t h a t  a p pl icab le  
legal  requirements  related  to  forest  management  are  fulfilled  (7.5).  There  is 
specific mentioning of forest management in Annex E, and management plannin g 
con be considered as part of general forest management.  

The indicator is partly covered, as no detailed guidance or normative requirements 
are in place for this indicator.  

See also A.1.1.1.1, which relates to the same issue. 

Findings 

Scheme info 

Partially 
Covered 

There is no mentioning of the need to have planning documents in place  p ri or t o  
harvesting activities.   

See also A.1.1.1.1 

Justification 

The standard refers to a general requirement to have evidence t h a t  a p pl icab le  
legal  requirements  related  to  forest  management  are  fulfilled  (7.5).  There  is 
specific mentioning of forest management in Annex E, and management plannin g 
con be considered as part of general forest management. If so, this can also cover 
planning documents. 

The  indicator  is  considered  to  be  partly  covered,  as  no  detailed  guidance or 
normative requirements are in place for this indicator.  

844 

 
 
 
 
 
 
 
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Conclusion 

A.1.1.4 

Harvesting 
permits 

A.1.1.4.1  The  Scheme  shall 
requirements 
include 
that 
compliance  with 
ensure 
legislation 
the 
issuing of harvesting permit s,  
legal 
licenses 
documents 
for 
specific harvesting operations. 

other 
required 

regulating 

or 

A.1.2.1 

A.1.2 Paym ents for harvest rights and 
tim ber including duties related to tim ber 
harvesting 
Payment 
royalties 
harvesting fees 

of 
and 

A.1.2.1.1  The  Scheme  shall 
requirements 
include 
that 
ensure 
compliance  with 
legislation covering pa yme nt  
of  all  legally  required  forest 
harvesting-specific  fees  such 
as  royalties,  stumpage  fees 

See also A.1.1.1.1, which relates to the same issue. 

ISO 
38200:2018,  Annex  F 
(informative) Examples of low a n d  
high  risk  indicators;  F.1  Low  risk 
indicators 

Findings 

Scheme info 

Partially 
Covered 

Annex F Low risk  indicators (informative – guidance) refer to harvesting permits as 
a low risk  indicator, if procedures conducted to receive the licence are transparent, 
legal and open.  

See also A.1.1.1.1 

Justification 

There is no explicit standard requirement on harvesting permits, but the sta n d a rd 
mentions harvesting permits as part of Annex F Low risk  indicators (inform a t ive   - 
guidance).  

Harvesting permits are low risk indicators, provided that procedures conducte d t o  
obtain the licence are transparent, legal and open.  
Reference to other permits or documents are not specifically mentioned. 

As the reference to harvesting permits are included only as guidance material and  
not required to obtain certification, the indicator is evaluated to be partly covered. 

See also A.1.1.1.1, which relates to the same issue. 

38200:2018,  Annex  C 

ISO 
(informative) Trade and customs 

Findings 

Scheme info 

Partially 
Covered 

38200:2018, 

ISO 
E 
(informative)  Guidance  related  to 
legally harvested material 

Annex 

Annex E mention that the payment of duties related to harvested material is part of 
the applicable legislation to consider.  

Payment of taxes and royalties are mentioned as a low-risk  indicator in A n n ex F.  

845 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Conclusion 

and other volume-based fees, 
as  well  as  land area taxes or 
fees. 

ISO 
38200:2018,  Annex  F 
(informative) Examples of low a n d  
high risk indicators 

(F.1, h)).  

See also A.1.1.1.1 

Justification 

As the reference to payment of royalties are included only as guida nce  m a te ria l 
and  not  required  to  obtain certification, the indicator is evaluated to be partly 
covered. 

A.1.1.1.1, which relates to the same issue. 

A.1.2.2 

Value-added 
taxes  and  other 
sales taxes 

A.1.2.2.2  The  Scheme  shall 
requirements 
include 
that 
compliance  with 
ensure 
legislation  covering different 
types of sales taxes that apply 
to  the  material  being  sold, 
including  selling  material as 
growing forest (standing stock 
sales). 

38200:2018,  Annex  C 

ISO 
(informative) Trade and customs  

Findings 

Partially 
Covered 

38200:2018,  Annex  E 
ISO 
(informative). Guidance relat e d t o  
legally harvested material. 

ISO 
38200:2018,  Annex  F 
(informative) Examples of low a n d  
high risk indicators 

Scheme info 

Payment of taxes and royalties are mentioned as a low-risk  indicator in A n n ex F.  
(F.1, h)). 
But the types of taxes are not specified. Guidance on applicable legislation (Annex 
E) does not cover general taxes and sales taxes but relate only to duties related to 
harvesting of material.  

See also A.1.1.1.1 

Justification 

The payment of taxes is mentioned in the informative annexes, but t h e re  a re  n o  
clear guidance of payment of value added taxes and other sales taxe s a re  t o  b e  
included as a low risk  indicator. 

Compliance with these annexes is not required in order obtain certification and the 
indicator is evaluated to be partly covered. 

A.1.3 Tim ber harvesting, including 
environm ental and forest legislation 

846 

 
 
 
 
 
 
 
 
 
 
 
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Code 

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Indicators 

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Findings and Justification 

Conclusion 

38200:2018,  Annex  E 
legally 

ISO 
(Guidance 
harvested material) 

related 

to 

A.1.3.1 

including forest m anagement and 
biodiversity conservation, w here directly 
related to tim ber harvesting 
Timber harvesting 
regulations 

requirements 

A.1.3.1.1  The  Scheme  shall 
include 
that 
ensure compliance with le g al 
for  harvesting 
obligations 
techniques  and  technology 
including  timing  of  harvest, 
selective cutting, shelter wood 
regeneration,  clear  felling, 
transport of timber from felling 
sites and seasonal limitatio ns 
etc. 

This  includes  the  mis-use  of 
salvaging  permits  or  other 
specific  ministerial  permits, 
with 
of 
circumventing 
harvest 
regulations 

intention 

the 

A.1.3.1.2  The  Scheme  shall 
requirements 
include 
to 
control 
illegal 
potential 
activities by third parties within 
the  area  managed  by  the 
operation. 

847 

Findings 

Scheme info 

Partially 
Covered 

The standard states that applicable legal requirements shall be f u lf il led ,  a n d i n  
annex E it is stated that applicable legislation include environme n ta l a n d  f o re st  
legislation,  including  that  covering  forest  management  and  biodiversity 
conservation, directly related to harvesting of material.  

See also A.1.1.1.1 

Justification 

There  are  normative  requirements  in  place  to  ensure  that  evidence  is  to  be 
collected and recorded to ensure material is legally sourced in co m pli an ce wi t h  
applicable legislation.  

However, it cannot be concluded that legal obligations for harvesting t e ch n iqu e s 
and technology are automatically covered by an organisation’s DDS under the ISO 
38200.  

Therefore, the indicator is partly covered. 

See also, the justification in A.1.1.1.1, which relates to the same issue. 

Justification 

Not Covered 

The is no specific mentioning of this requirement and the indicator is co n si d e re d  
not covered.  

 
 
 
 
 
 
 
 
   
 
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Code 

Criterion 

Indicators 

Standard reference  

Findings and Justification 

A.1.3.2

Protected 
and species 

sites 

A.1.3.2.1  The  Scheme  shall
requirements 
include 
that
compliance  with
ensure 
legislation related to protected 
areas  as  well  as  protected,
rare,  or  endangered species,
including  their  habitats  and
potential habitats.

38200:2018,  Annex  B 

ISO 
(informative) Environment  

Findings 

38200:2018, 

E 
ISO 
(informative)  Guidance  related  to 
legally harvested material 

Annex 

Scheme info 

The standard states that applicable legal requirements shall be fulfilled. A n ne x B  
specifies  that  applicable  legislation relate to management of biodiversity and 
natural habitat and annex E include legislation related to biodiversity conservation  
directly related to harvesting of material.   

See also A.1.1.1.1 

Justification 

There  are  normative  requirements  in  place  to  ensure  that  evidence  is  to  be 
collected and recorded to ensure material is legally sourced in co m pli an ce wi t h  
applicable legislation.  

Protection  of  areas  can  be  considered  relevant as part of the management of 
biodiversity  and  natural  habitats.  However,  it  cannot  be  concluded that legal 
obligation  for  protected  sites  and  species  are  automatically  covered  by  an 
organisation’s DDS under the ISO 38200.  

Therefore, the indicator is partly covered. 

See also, the justification in A.1.1.1.1, which relates to the same issue. 

Conclusion 

Partially 
Covered 

A.1.3.2.2  Requirements  that
ensure 
compliance  with
legislation related to protected 
areas  and  habitats,  shall
include that the identificat io n
of 
is 
conducted  according  to  the
legal requirements.

protected 

areas 

38200:2018,  Annex  B 

ISO 
(informative) Environment  

Findings 

Partially 
Covered 

38200:2018, 

ISO 
E 
(informative)  Guidance  related  to 
legally harvested material 

Annex 

Scheme info 

The is no specific mentioning of identification of protected are a s.  Ho we ve r,  t h e  
standard  states  that  applicable  legal  requirements  shall  be  fulfill ed,  and 
identification  of legislation related to management of biodiversity and natural 
habitats. 

Justification 

848 

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Findings and Justification 

Conclusion 

A.1.3.3

Environmental 
requirements 

of 

damage 

A.1.3.3.1  The  Scheme  shall
requirements 
include 
that
compliance  with 
ensure 
to 
related 
legislation 
impact 
environmental 
assessment 
in  connection 
with  harvesting,  acceptable 
levels 
and 
disturbance  of soil resources, 
establishment of buffer zone s 
(e.g.  along  watercourses, 
open  areas,  breeding  sites), 
maintenance of retained trees 
felling  sites,  seasonal 
on 
limitations on harvesting, an d  
environmental  requirements 
for forest machinery. 

There  are  normative  requirements  in  place  to  ensure  that  evidence  is  to  be 
collected and recorded to ensure material is legally sourced in co m pli an ce wi t h  
applicable legislation.  

Protection  of  areas  can  be  considered  relevant as part of the management of 
biodiversity  and  natural  habitats.  However,  it  cannot  be  concluded that legal 
obligation  for  protected  sites  and  species  are  automatically  covered  by  an 
organisation’s DDS under the ISO 38200.  

Therefore, the indicator is partly covered. 

See also, the justification in A.1.1.1.1, which relates to the same issue. 

38200:2018,  Annex  B 

ISO 
(informative) Environment  

Findings 

Partially 
Covered 

38200:2018, 

ISO 
E 
(informative)  Guidance  related  to 
legally harvested material 

Annex 

Scheme info 

The  scheme  requires  the  organization  to  establish,  implement  and  maintain 
procedures that include identification of legal requirements applicable to the CoC and 
how these apply.  

There  is  no  specific  mentioning  of  environmental  impact  assessment.  However, 
annex B states that applicable legislation can include legislation related to pollu ti on ,  
including management of hazardous wates, resource efficiency and risk management 
and emergency response. According to annex E environmental legislation is relevant  
to consider. 

See also A.1.1.1.1 

Justification 

If an environmental impact assessment is relevant in the applicable country, this is 
assumed to be relevant under the types of legislation identified in the inform at ive  
annexes of the ISO 38200 standard. 

See also the justification in A.1.1.1.1, which relates to the same issue. 

849 

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A.1.3.4

Health and safety  A.1.3.4.1  The  Scheme  shall
requirements 
include 
that
compliance  with
ensure 
Health & Safety legislation.

ISO 
38200:2018,  Annex  A 
(informative)  Social  welfare  and 
employment 

Findings 

Scheme info 

Conclusion 

Partially 
Covered 

The  scheme  requires  the  organization  to  establish,  implement  and  maintain 
procedures that include identification of legal requirements applicable to t h e  Co C 
and how these apply.  

Health  and  Safety  is mentioned in Annex A, as part of the guidance on social 
welfare  and  employment.  According  to  the  annex  the  relevant  legislation  is 
including, not limited to working conditions endangering safety or health. There  i s 
no further definition of relevant legislation related to H&S.  

See also A.1.1.1.1 

Justification 

The Scheme notes that relevant legislation relates to working conditions endangering 
safety and health. However, there is no further guidance, and whether H& S  wi l l b e  
fully covered by a CoC under ISO 38200 certification depend on the interpretation  o f  
the certified organization and CB and therefore the indicator can be  co n si d e re d a s 
only partially covered. 

See also the justification in A.1.1.1.1, which relates to the same issue. 

A.1.3.5

Legal employment  A.1.3.5.1  The  Scheme  shall
requirements 
include 
that
ensure 
compliance  with 
legislation for employment  o f  
personnel 
in 
in-forest 
harvesting 
processing) activities including 
but not limited to requirements 
for:  contracts  and  working 
permits, 
obligatory 
insurances,  certificates  of 
competence and other training 
requirements, and payment of 

involved 
(and 

38200:2018,  Annex  A 
ISO 
(informative)  Social  welfare  and 
employment 

Findings 

Scheme info 

Not Covered 

There is no reference to legislation on legal employment specifically related to th e  
forest sector.  

Examples given on applicable legislation are all covered by A1.3.6 below. 

Justification 

850 

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Criterion 

Indicators 

Standard reference  

Findings and Justification 

Conclusion 

social and income taxes.  

There  are  normative  requirements  in  place  to  ensure  that  evidence   is  to  be 
collected and recorded to ensure material is legally sourced in co m pli an ce wi t h  
applicable legislation.  

The examples of legal employment do not cover the examples of this indicato r.  T he  
guidance on addressing legislation on employment is including and not limited to. It is 
uncertain  if  an  organisation  will  be  able  to  identify  the  legislation  covering the 
indicator without such guidance.  

See also, the justification in A.1.1.1.1, which relates to the same issue. 

A.1.3.5.2  The  Scheme  shall
that
requirements 
include 
compliance  with 
ensure 
legislation 
for  minimum 
working  age  and  minimum 
age for personnel involved i n  
hazardous  work,  legislation 
and 
against 
compulsory 
and 
discrimination and legislat ion  
freedom  of 
allowing 
association. 

labour, 

forced 

for 

A.1.4.1

A.1.4 Third parties’ legal rights concerning
use and tenure that are affected by tim ber 
harvesting 
Customary rights 

A.1.4.1.1  The  Scheme  shall
requirements 
include 
that
ensure 
compliance  with
respect  for  customary  tenure
rights 
forest
harvesting activities.

relevant 

to 

ISO 
38200:2018,  Annex  A 
(informative)  Social  welfare  and 
employment 

Findings 

Scheme info 

Guidance  (annex  A)  related  to  applicable  legislation  in  relation  to  legal 
employment cover minimum working age and minimum age for personnel involved 
in  hazardous  work,  legislation  against  forced  and  compulsory  labour,  and 
discrimination and freedom of association. 

Justification 

There  are  normative  requirements  in  place  to  ensure  that  evidence  is  to  be 
collected and recorded to ensure material is legally sourced in co m pli an ce wi t h  
applicable legislation.  

See also, the justification in A.1.1.1.1, which relates to the same issue. 

E 
to 

Findings 

Scheme info 

Annex E specifies that applicable legal requirements include third part i es’ ri g h t s 
concerning use and tenure that are affected by harvesting of material. 

38200:2018, 

ISO 
(informative)  Guidance  related 
legally harvested material 

Annex 

851 

Partially 
Covered 

Partially 
Covered 

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Standard reference  

Findings and Justification 

Conclusion 

Customary rights are not mentioned specifically. 

Justification 

Customary rights are not mentioned specifically, but can be considered as covered 
under third parties’ rights  

There  are  normative  requirements  in  place  to  ensure  that  evidence  is  to  be 
collected and recorded to ensure material is legally sourced in co m pli an ce wi t h  
applicable legislation.  

See also, the justification in A.1.1.1.1, which relates to the same issue. 

Findings 

Not Covered 

There is no reference to this in ISO 38200:2018 and the indicator i s co n si d e re d  
Not covered.  

Findings 

Not Covered 

There is no reference to this in ISO 38200:2018 and the indicator i s co n si d e re d  
Not covered.  

Findings 

Scheme info 

Partially 
Covered 

Annex E specifies that applicable legal requirements include Third partie s ‘ri g h t s 
concerning use and tenure that are affected by harvesting of material. 

38200:2018, 

ISO 
E 
(informative)  Guidance  related  to 
legally harvested material 

Annex 

852 

or 

communities 

requirements 

A.1.4.1.2  The  Scheme  shall
include 
that
ensure compliance with le g al
obligations concerning benefit 
sharing they have negotia te d
with 
or 
customary  users.  E.g.  social 
agreements 
social 
responsibility  agreements  or 
cahier de charges, dependent 
on the country. 
A.1.4.2.1  The  Scheme  shall
include 
that
ensure  compliance  with  the
internationally 
adopted 
principles  of  'Free,  Prior and 
Informed 
in 
connection with granting rights 
to forest management. 
A.1.4.3.1  The  Scheme  shall
requirements 
include 
that
compliance  with 
ensure 
and 
national 
international 
conventions 
ratified that respect the tenure 
rights of indigenous and tribal  

requirements 

legislation 

Consent' 

A.1.4.2

Free,  Prior  and 
Informed Consent 

A.1.4.3

Indigenous  and 
traditional 
peoples' rights 

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Findings and Justification 

Conclusion 

peoples to forest land as we l l  
as their right to FPIC. 

A.1.5.1

A.1.5 Trade and custom s, in so far as the
forest sector is concerned 
Classification  of 
species, 
quantities, 
qualities 

material 

A.1.5.1.1  The  Scheme  shall
requirements 
include 
that
compliance  with
ensure 
regulating  how
legislation 
harvested 
is 
classified in terms of speci e s,
Quantities  and  qualities  in
connection  with  trade  and
transport.
A.1.5.2.1  The  Scheme  shall
requirements 
include 
that
compliance  with 
ensure 
trading 
required 
legally 
permits  as  well  as  legally 
required transport document s 
that  accompany  transport  of 
wood from forest operations. 

A.1.5.2

Trade 
transport 

and 

FPIC is not covered in ISO 38200:2018 

See also A.1.1.1.1 

Justification 

Customary rights are not mentioned specifically, but can be considered as covered 
under third parties’ rights  

There  are  normative  requirements  in  place  to  ensure  that  evidence  is  to  be 
collected and recorded to ensure material is legally sourced in co m pli an ce wi t h  
applicable legislation.  

See also the justification in A.1.1.1.1, which relates to the same issue. 

Findings 

Scheme info 

There  is  no  reference  to  classification of species, quantities, qualities and the 
indicator is considered Not covered. 

38200:2018,  Annex  C 

ISO 
(informative) Trade and customs 

Findings 

ISO 
38200:2018,  Annex  F 
(informative) Examples of low a n d  
high risk indicators 

Scheme info 

In annex C it is stated applicable legislation to consider are requirements related to 
export licences, as well as official authorization required for import and export.  

In annex F it is stated that compliance with trade and customs legislation is a  l o w 
risk  indicator 

Justification 

853 

Not Covered 

Partially 
Covered 

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Code 

Criterion 

Indicators 

Standard reference  

Findings and Justification 

Conclusion 

Documentation related to import/export is required, as well as a  re q u i re m e nt  t o  
comply with legislation related to trade.  

There  are  normative  requirements  in  place  to  ensure  that  evidence  is  to  be 
collected and recorded to ensure material is legally sourced in co m pli an ce wi t h  
applicable legislation.  

The key issues  which result in a full Coverage conclusion not being given re late to: 







There is no mentioning of identifying and assessing risks  related to
transport documents 
The applicable legislation is to be identified by an organization, and the
identified legislation can therefore differ and there is a risk that not all
categories of law as defined by the EUTR are included. While it is 
clarified by ISO that organizations based within the EU will have to
follow the categories of applicable legislation defined by the EU, this is 
not applicable to organizations outside the EU. Material sourced as 
certified under ISO 38200 can enter the supply chain without having 
identified applicable legislation in conformance with the EUTR.
Also, the guidance provided is rather general and it can be a challenge 
for a company to apply a due diligence system with strong risk 
conclusion and mitigation without detailed guidance.

Findings 

Scheme info 

There is no reference to offshore trading and transfer pricing in ISO 38200:2018 

38200:2018,  Annex  C 

ISO 
(informative) Trade and customs 

Findings 

ISO 
38200:2018,  Annex  F 
(informative) Examples of low a n d  
high risk indicators 

Scheme info 

In annex C it is stated applicable legislation to consider are requirements related to 
export licences, as well as official authorization required for import and export.  

There is no specific mentioning of product classification, but in annex F it is stat e d  
that compliance with trade and customs legislation is a low risk indicator. 

854 

Not Covered 

Partially 
Covered 

A.1.5.3

Offshore 
and 
pricing 

trading 
transfer 

A.1.5.3.1  The  Scheme  shall
requirements 
include 
that
ensure 
compliance  with
legislation regulating offshore
trading and transfer pricing.

A.1.5.4

Customs 
regulations 

A.1.5.4.1  The  Scheme  shall
that
include 
requirements 
ensure 
compliance  with
legislation  covering  areas 
export/import 
such 
product 
licenses, 
to 
classification 
customs  (codes,  quantities, 
qualities and species). 

related 

and 

as 

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Code 

Criterion 

Indicators 

Standard reference  

Findings and Justification 

Conclusion 

See also A.1.1.1.1 

Justification 

There  are  normative  requirements  in  place  to  ensure  that  evidence  is  to  be 
collected and recorded to ensure material is legally sourced in co m p li an ce wi t h  
applicable legislation.  

Licenses related to import/export are given as examples of applicable legisla t io n,  
as well legislation related to trade and customs are considered low risk indi ca t o r.  
The legislation to be identified are not limited to the examples provided.  

The indicator is considered partially covered.  

The key issues  which result in a full Coverage conclusion not being given relate to: 







There is no mentioning of identifying and assessing risks  related to product
classification. 
The applicable legislation is to be identified by an organization, and the
identified legislation can therefore differ and there is a risk that not all
categories of law as defined by the EUTR are included. While it is 
clarified by ISO that organizations based within the EU will have to
follow the categories of applicable legislation defined by the EU, this is 
not applicable to organizations outside the EU. Material sourced as 
certified under ISO 38200 can enter the supply chain without having 
identified applicable legislation in conformance with the EUTR.

Also, the guidance provided is rather general and it can be a challenge 
for a company to apply a due diligence system with strong risk 
conclusion and mitigation without detailed guidance.

A.1.5.5

CITES 

A.1.5.5.1  The  Scheme  shall
requirements 
include 
that
ensure 
compliance  with
legislation  related  to  CITES
permits  (the  Convention  on
International 
in
Endangered  Species of Wild

Trade 

ISO 
38200:2018, 
assessment  process 

7.5  Risk 

Findings 

Covered 

ISO 
38200:2018,  Annex  F 
(informative) Examples of low a n d  
high risk indicators 

Scheme info 

A risk  assessment  shall be conducted on whether there is risk of illegal logging  i n  
relation  to  CITES  (7.5).  Also  supplies  in compliance with CITES regulation is 
provided as a low-risk indicator.  

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Criterion 

Indicators 

Standard reference  

Findings and Justification 

Conclusion 

Fauna and Flora, also kn o wn  
as 
Washington 
Convention). 

the 

Justification 

There  are  normative  requirements  in  place  to   ensure  that  evidence  is  to  be 
collected and recorded to ensure material is legally sourced in co m pli an ce wi t h  
applicable legislation.  

The indicator is considered to be covered. 

A.1.5.6

Legislation 
requiring 
diligence 
care procedures 

due 
/  due 

covering 

A.1.5.6.1  The  scheme  shall
requirements 
include 
that
compliance  with 
ensure 
legislation 
due 
care 
diligence/due 
procedures, including e.g. due 
diligence/due  care  systems, 
declaration  obligations,  and 
trade 
/or 
related documents, legislation 
establishing  procedures 
to 
prevent 
illegally 
trade 
harvested timber and products 
derived from such timber, etc. 

the  keeping  of 

in 

ISO 
38200:2018,  Annex  F 
(informative) Examples of low a n d  
high risk indicators 

Findings 

Scheme info 

Partially 
Covered 

Verification or licensing mechanism, such as FLEGT licences, oth e r t h a n f o re st  
certification programmes are recognized as a low risk  indicator. 

Justification 

There is no explicit information about what a due diligence system shall contain i n  
order  to  be  approved  under the certification scope of ISO 38200. As there are 
varying degree of implementation of due diligence it is important with transparency 
in scope and approach for the material covered by the DDS.  

the guidance provided is rather general and it can be a challenge for a company to 
apply a due diligence system with strong ri sk  conclusion and miti ga t ion  wi t h ou t 
detailed guidance.   

Therefore, the indicator is considered to be partially covered.  

A.2  Legal requirements for supply  chain entities 
This  section  shall  apply  to  Certificate  Holders  -  or  other  entities  subject  to the normative requirements of the Scheme (e.g. included w ithin the scope of a certified due diligence sys tem) - w ithin 
the Country of Harvest. 

A.2.1. Legal registration

A.2.1.1

Legal Registration  A.2.1.1.1  The  scheme  shall
include 
that
ensure the existence of l e g a l

requirements 

ISO  38200:2018,  4  General 
requirements 

Findings 

Partially 
Covered 

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Criterion 

Indicators 

Standard reference  

Findings and Justification 

Conclusion 

business 
registration,  and 
other relevant legally required 
licenses. 

ISO 38200:2018, 5.1 General  

Scheme info 

ISO 38200:2018, 7 Due Dilige nce  
System 
7.1 general requirements 

There is no reference to legal business registration, or registration of businesses in 
the supply chain. 

However, the standard does require for the certificate holder to be in com pli an ce 
with legal requirements.  

See also A.1.1.1.1 

Justification 

The  certificate  holder  is  to  be  in  compliance  with legal requirements and it can 
therefore be concluded that the indicator is in place for the certificate holder.  

However, there is no clear reference to legal conformance of the operation of sup p l y 
chain  entities  besides ensuring that the material is traded legally. Therefore, this 
indicator is considered only partly covered.  

Findings 

Scheme info 

Partially 
Covered 

Guidance material (annex C) refer to payment of taxes and duties related to export 
of materials, and payment of taxes and fees are considered as a low risk  in dicator.  

Justification 

The certificate holder will have to comply with applicable legislation related t o  t a x 
payment, as they are to comply with legislation, and the informative annexes a l so  
refer to taxes, duties and royalties.  

The key issues which result in a full Coverage conclusion not being given relate to: 





As the standard does not clearly state that the legislation to be identified
relate to supply chain entities 

Also, the guidance provided is rather general and it can be a challenge 
for a company to apply a due diligence system with strong risk 

A.2.2.1

A.2.2 Taxes and fees
Payment of taxes, 
royalties and fees 

A2.2.1.1  The  Scheme  shall 
that 
requirements 
include 
ensure 
compliance  with 
legislation covering pa yme nt  
of  all  legally  required  taxes, 
royalties and fees. 

ISO  38200:2018,  4  General 
requirements 

38200:2018,  Annex  C 

ISO 
(informative) Trade and customs 

38200:2018,  Annex  F 
ISO 
(informative) Examples of low a n d  
high risk indicators 

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Criterion 

Indicators 

Standard reference  

Findings and Justification 

Conclusion 

A.2.2.2

Value-added 
taxes  and  other 
sales taxes 

A2.2.2.1  The  Scheme  shall 
requirements 
include 
that 
ensure 
compliance  with 
legislation  covering different 
types of sales taxes that apply 
to  the  material  being  sold, 
including  selling  material as 
growing forest (standing stock 
sales). 

ISO  38200:2018,  4  General 
requirements 

38200:2018,  Annex  C 

ISO 
(informative) Trade and customs 

ISO 
38200:2018,  Annex  F 
(informative) Examples of low a n d  
high risk indicators 

A.2.3.1

A.2.3 Trade and transport
Classification  of 
species, 
quantities, 
qualities 

A.2.3.1.1  The  Scheme  shall
requirements 
include 
that
compliance  with
ensure 
regulating  how
legislation 
products  are  classified 
in
terms of species, volumes and
qualities  in  connection  with
trade and transport.

858 

conclusion and mitigation without detailed guidance 

Findings 

Scheme info 

Partially 
Covered 

Guidance  material  (annex  C)  refer  to  payment  of  taxes,  royalties  and fees as 
examples of applicable legislation applicable for the supply chain.  

See also A.1.1.1.1 

Justification 

There is no clarification on how payment of taxes shall be assessed. The standard 
does  note  that  this  shall  be  in  place  for the supply chain, but it is unclear if  it 
relates to the operations of the supply chain entities or only to the trade/transfer o f  
the product. Whether it is in place for supply chain entities will have to be de f ine d 
by the scope if the CoC and due diligence system. 

The certificate holder will have to comply with applicable legislation related t o  t a x 
payment, as they are to comply with legislation.  

The key issues which result in a full Coverage conclusion not being given relate to: 





the standard does not clearly state that the legislation is to b e identified 
for supply chain entities 

Also, the guidance provided is rather general and it can be a challenge 
for a company to apply a due diligence system with strong risk 
conclusion and mitigation without detailed guidance

Findings 

Not Covered 

 There  is  no reference to classification of species, quantities, qualities and the 
indicator is considered not covered. 

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Code 

Criterion 

Indicators 

Standard reference  

Findings and Justification 

A.2.3.2

Trade 
transport 

and 

A.2.3.2.1  The  Scheme  shall
requirements 
include 
that
compliance  with
ensure 
required  trading  permits  as 
required
well  as 
legally 
transport  documents 
that
accompany transport of wood. 

38200:2018,  Annex  C 

ISO 
(informative) Trade and customs 

Findings 

ISO 
38200:2018,  Annex  F 
(informative) Examples of low a n d  
high risk indicators 

Scheme info 

There is guidance material in place related to export license s,  a s  we l l  a s o t h e r 
documentation related to import/export, but there is no reference  t o  o t h e r t ra d e 
and transport permits.   

However, Annex C does provide guidance to identify legislation related to trade.  

Justification 

Conclusion 

Partially 
Covered 

As there is guidance in place to note that legislation related t o  t ra d e  sh o u l d b e  
considered, the indicator is considered to be partly covered  

The key issues  which result in a full Coverage conclusion not being given relate to: 



there are no normative references in place to ensure that trade permits 
and other trade documents are included in an organisations due
diligence system,



the guidance provided is rather general and it can be a challenge for a
company to apply a due diligence system with strong risk  conclusion
and mitigation without detailed guidance
There is no reference to offshore trading and transfer pricing 

Not Covered 

There is no reference to offshore trading and transfer pricing in the standard.  

Not Covered 

38200:2018,  Annex  C 

ISO 
(informative) Trade and customs 

Findings 

ISO 

38200:2018,  Annex  F 

Scheme info 

859 

Partially 
Covered 

A.2.3.3

Offshore 
and 
pricing 

trading 
transfer 

A.2.3.4

Customs 
regulations 

A.2.3.3.1  The  Scheme  shall
that
requirements 
include 
ensure 
compliance  with
legislation regulating offshore
trading.
A.2.3.3.2  The  Scheme  shall
requirements 
include 
that
ensure 
compliance  with
legislation regulating tran sf e r
pricing.
A.2.3.4.1  The  Scheme  shall
requirements 
include 
that
ensure 
compliance  with
legislation  covering  areas 

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Code 

Criterion 

Indicators 

Standard reference  

Findings and Justification 

Conclusion 

as 

and 

export/import 
such 
product 
licenses, 
to 
classification 
customs  (codes,  quantities, 
qualities and species). 

related 

(informative) Examples of low a n d  
high risk indicators 

Legislation on customs and import/export licenses are referred to a s a p p l i ca b le  
legislation under annex C.  

Justification 

As there is guidance in place to note that legislation related to custom sh o u l d  b e  
considered, the indicator is considered to be partly covered.  

The key issues  which result in a full Coverage conclusion not being given relate to: 





there are no normative references in place to ensure that trade permits
and other trade documents are included in an organisations due
diligence system 

the guidance provided is rather general and it can be a challenge for a
company to apply a due diligence system with strong risk  conclusion
and mitigation without detailed guidance

A.2.3.5

CITES 

A.2.3.5.1  The  Scheme  shall
requirements 
include 
that
ensure 
compliance  with
legislation  related  to  CITES
permits  (the  Convention  on
in
International 
Endangered  Species of Wild
Fauna and Flora, also kn o wn
as 
Washington
the 
Convention).

Trade 

38200:2018, 
ISO 
assessment  process 

7.5  Risk 

Findings 

Covered 

ISO 
38200:2018,  Annex  F 
(informative) Examples of low a n d  
high risk indicators 

Scheme info 

The scheme has normative requirements in place to ensure that a risk assessmen t  
is conducted on prevalence of illegal harvesting of specific tree species accordi n g 
to the restrictions or limitations set by CITES or applicable national listing of illegal 
harvesting.  Also  guiding  annex  F  notes  that  a  low  risk  indicator  can  be  that 
supplies are in compliance with CITES regulation.  

Justification 

As there are normative requirements in place to assess the prevalence of supplies 
of material harvested illegally according to restrictions and limitations set by CITES 
the indicator is considered to be covered. 

A.2.3.6

Legislation 
requiring 
diligence 
care procedures 

due 
/  due 

A.2.3.6.1  The  scheme  shall
requirements 
include 
that
compliance  with 
ensure 
due 
legislation 
diligence/due 
care 
procedures, including e.g. due 
diligence/due  care  systems, 

covering 

ISO 
38200:2018,  Annex  F 
(informative) Examples of low a n d  
high risk indicators 

Findings 

Scheme info 

Partially 
Covered 

Verification or licensing mechanism, such as FLEGT licences, oth e r t h a n f o re st  
certification programmes are recognized as a low-risk  indicator. 

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Criterion 

Indicators 

Standard reference  

Findings and Justification 

Conclusion 

the  keeping  of 

declaration  obligations,  and 
/or 
trade 
related documents, legislation 
establishing  procedures 
to 
prevent 
illegally 
trade 
harvested timber and products 
derived from such timber, etc. 

in 

A.3  Requirements for material  control 

A.3.1.1

A.3.1 Material control
Material origin and 
identification 

A.3.1.1.1  The  Scheme  shall
require  systematic  processes 
to enable the identificatio n o f
the  country  of  harvest  of  the
material, 
where
applicable to a higher level o f
detail,  such  as 
the  sub-
national region or concessio n
level.

and 

If the certificate holder is based within a country with legislation in place co ve rin g 
due  diligence,  this  is  required  to  be  implemented  as in compliance  with that 
legislation. 

Justification 

There is no explicit information about what a due diligence system shall contain i n  
order to be approved under the certification scope of ISO 38200. I n  E u ro p e i t  i s 
common for companies not to have diligence systems in place as required by t h e  
EUTR,  and  the  quality  and  efficiency  of  due  diligence  systems  vary  greatly 
between companies. It is important with transparency in scope and appro ach  f o r 
the material covered by the DDS.  

the guidance provided is rather general and it can be a challenge for a company to 
apply a due diligence system with strong risk  conclusion and miti ga t ion  wi t h ou t 
detailed guidance.   

Therefore, the indicator is considered to be partially covered.  

ISO  38200:2018,  7.2.  general 
information required 

Findings 

Scheme info 

Partially 
Covered 

The scheme requires the country of harvest to be declared, and if necessary, al so  
the sub-national region and/or concession of harvest. 

The  information  shall  be  collected  as  part  of  the  company’s  DDS  before  the 
material is used and repeated annually or when any information is changed. 

However, information on country of harvest are to be collected fo r n o n -ce rt if ie d 
material. However, certified material and recycled material i s e xe m p t  f ro m  t h is 
requirement. 

Justification 

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Standard reference  

Findings and Justification 

Conclusion 

A.3.1.1.2  The  Scheme  shall
require  systematic  processes 
to enable the identificatio n o f
in
the  species 
materials or products included 
in the scope of certification.

included 

 Information on country of harvest is to be collected for input material, but certified  
material is exempt from this requirement. Therefore, the indicator i s co n si d e re d  
only partly covered.  

Recycled  material  is  exempt  as  well,  which  is  in  compliance  with  the EUTR. 
However, the origin of material shall be known also for certified material according 
to the EUTR.  

ISO  38200:2018,  7.2.  general 
information required 

Findings 

Scheme info 

Partially 
Covered 

Species - or potential species in the case where input contain mix speci es -sh a l l  
be collected annually. If needed the species scientific name shall be declared. 

However, it is not required to identify species if material is sourced as recycl e d  o r 
certified. 
Note:  the  certified  material  is  accepted  only  to  be  included in the DDS if the 
certification scheme is in compliance with the requirements und e r t h e  st a n d a rd 
indicator  7.4  on  information  required  for  certified  material.  This  includes 
certification scheme requirements for evaluating forest management legality, wi t h  
a scope that covers the organisation’s due diligence system requirements. Also,  a  
chain of custody system must be in place. 

Justification 

Information of species are to be collected for input material, but certified material is 
exempt from this requirement. Therefore, the indicator is considere d  o n ly p a rt ly 
covered.  

Recycled material is exempt as well, which is in compliance with the EUTR. However, 
the origin of material shall be known also for certified material according to the EUTR. 

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A.3.1.1.3 The Sch eme
shall include clear a n d
effective  measures  to
prevent  material  from
risk,
non-negligible 
unverified or potentially
illegal  sources 
from
entering 
the  supply
chain  and  mixed  with
conforming material.

ISO  38200:2018,  3  Terms  and 
definitions 

Findings 

Partially 
Covered 

ISO 38200:2018, 6 Input material,  
6.1 categories of input material 

ISO  38200:2018,  7.2  General 
information required 

ISO 38200:2018, 7.4 Info rma t io n 
required for certified material 

ISO 38200:2018, 9.3 Output materi al 
declaration 

Scheme info 

“All input material within the scope of the organization’s chain of custody sh a l l b e  
assessed  in accordance with the Due Diligence System described in Clause 7  

There are four categories of input material. 

-

-

-

-

-

certified material: verified material received with a certification status and
meets the requirements of a particular certification scheme for which the
organization can provide evidence of third-party certification to that scheme
(3.9). It shall be verified that certification bodies are independent, that the
scheme has requirements to evaluate legality in forest management and is in
conformance with the scope of the organization’s DDS, and that the
certification has CoC requirements in place. 
v erified material; material for which the organization can provide evidence
of compliance with the requirements of the Due Diligence System (3.11)
specified material; A classification of verified material that meets publicly
available documented specific requirements, set by organization(s) within a
CoC and for which the organization provide information regarding the
requirements as well as evidence of compliance (3.10). Organizations can
set up their own requirements for specified materials, but all input material
will have to be assessed in accordance with the Due diligence system
requirements of the ISO 38200 standard (clause 7). The specific
requirements for specified material shall be documented and publicly
available.
The purpose of the specified material category is to allow companies to
make clear communication about the product and conformity level (ISO Call -
5/11/2020 - Representative Project Committee ISO/PC 287)
recycled material; material that has been recovered, or otherwise diverted,
from  the waste stream, either from the manufacturing process [i.e. post-
industrial recycled materials, but not in-house scrap] or after consumer use
(i.e. post-consumer recycled materials), that is reused in the manufacture of
new product, and for which the organization can provide evidence of
compliance with the requirements of the Due Diligence System (excluded
are by-products such as sawmilling by-products (e.g. sawdust, chips, bark) 
or forestry residues (e.g. bark, chips from branches, roots). Evidence shall
be collected to verify that material is recycled and has been legally procured,
but an actual risk assessment  will not have to be conducted.

Iso  38200  provides  three  examples  of levels of assurance of output information 
(9.3): 

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-
-
-

first part (e.g. self-declaration),
second party (e.g. customer assessment)  or 
third party (e.g. certification).

Certified material can only be included in the organizations DDS if it can be verif i e d 
that the certification bodies of the certification scheme are independent; th at  t h e re  
are requirements in place to evaluate legality in the forest management and that th e 
scope is broad enough to over the organizations own DDS requirements; and last l y 
that there are a CoC in place related to the product.  

Justification 

 As such the organization shall ensure that all material is verified und e r t h e ir o wn  
DDS  or  certified  under  a certification scheme that will ensure that the DDS is in 
place,  but  there  are  some  gaps  in  the verification of material which means the 
indicator is only partially covered.  

The key issues  which result in a full Coverage conclusion not being given relate to.  





The risk assessment  process  is generally in compliance with the EUTR
but it is unclear how it is implemented in practice. E.g. the level of
assurance can according to 9.3 be self-declaration, but it is unclear if it is 
up to the organization to base their entire DDS on self-declaration. This 
can be a potential gap 
Identification of applicable legislation to be defined by the organization.
There is risk  of legislation which is applicable under the EUTR is not
included in the DDS scope of the organization.

ISO  38200:2018,  8  Chain  of 
custody  control  methods;  8.1 
Principles and requirements 

Findings 

Scheme info 

Partially 
Covered 

ISO 38200:2018, 9.1 General 

ISO  38200:2018,  9.2  Output 
categories 

ISO  38200:2018,  9.3  Output 
material declaration 

There is no requirement of tracking of material through the entire supply chain. 

However, there shall be measures in place to ensure the tracking of material wit h in  
the organisation, as well as recording of amount of input and output material use fo r 
production, as well as conversion factors, if relevant. There are CoC m e a su re s i n  
place  to  track  the  material  within the organization through physical separation, 
percentage method and credit method. 

Justification 

All material is to be verified under the DDS before used as in p u t  m at e ria l (se e  A  

864 

require 

A.3.1.1.4 
Where
applicable, the Scheme
the
shall 
segregation 
and
tracking  of  certified
(according 
to  each
individual claim type) or
verified 
legal  wood
along the supply chain ,
using 
appropriate
inventory methods a n d
documented  controls 
where  necessary 
to
risks  of
ensure 

that 

ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

mixing  are  identified, 
managed and mitigated. 

3.1.1.3). 

The certificate holder will have to keep track of input and output ma t eri al  a nd  t h e  
amounts in their own organization. 

However, there is no requirement of validation of volumes along the supp l y ch a in.  
This is considered as a gap in the system and can allow for mixing of material in the 
supply chain of material covered by the CoC-system.  

A.3.2 Recycled m aterial

A.3.2.1  Waste material  A.3.2.1.1 The Sch eme
shall have a definition of
waste material which at
the 
least 
definition 
of  waste 
material  as  described 
by the EUTR Guidance  
document. 

covers 

ISO  38200:2018,  3  Terms  and 
definitions; 3.12 recycled materi al 
definition; 3.13 in-house scrap 

Findings 

Scheme info 

Covered 

ISO 38200:2018, 7.3. Informa t ion  
required for recycled material.  

The standard excludes recycled material from the requirement to collect information 
on species, origin and evidence of compliance with legal requirements. 

Recycled  material  is  defined  as  material  that has been recovered, or otherwise 
diverted, from the waste stream, either from the manufacturing process [ i . e .  p o st -
industrial  materials,  but  not  in-house  scrap]  or  after  consumer  use  [i.e.  post-
consumer recycled materials), that is reused in the manufacture of n e w p ro d uct s,  
and  for  which  the  organization  can  provide  evidence  of  compliance  with  the 
requirements of the Due Diligence System. 

The following resources are available from the European Commission in relation to 
reclaimed material: 




EU Timber Regulation (995/2010)
EUTR Guidance document on Recycled timber and timber products 
The EUTR exempts material which has completed its lifecycle and would otherwise be 
disposed of as waste, fitting a definition close to post-consumer waste. This is 
demonstrated in the EUTR definition of timber and timber products, which excludes 
“timber products or components of such products manufactured from timber or timber 
products that have completed their lifecycle and would otherwise be disposed of as 
waste”[1].  

The EUTR Guidance document on Recycled timber and timber products reinforces the 

[1] Directive 2008/98/EC Article 3(1) defines 'waste ' as “any substance or object which the holder discards or intends or is required to discard” 

865 

ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

EUTR’s exemption for post-consumer reclaimed material, by describing that this 
exemption: 

 

 

applies to timber products of a kind covered by the Annex, produced from 
material that has completed its lifecycle and w ould otherwise have been 
disposed of as w aste (e.g. recycled paper, timber retrieved from dismantled 
buildings, or products made from waste wood).  
does not apply to by-products  of a manufacturing process that involves 
material which has not completed its lifecycle and w ould otherw ise 
hav e been discarded[2]. 

Material deemed a by-product of a manufacturing process, fitting a definition closer to 
pre-consumer waste, is not exempt from the EUTR.  

The EUTR Guidance document on Recycled timber  and timber  products describes 
that: “By-products” from another production are not waste but are to be regarded as a 
raw material in the production. Material in a regulated tim ber product is not recycled 
material if the material is the by-product of a manufacturing process. Example: 
Sawdust or off-cuts from sawn timber used to make particle board or medium density 
fibreboard. 

Justification 

The definition of recycled material in the ISO 38200 follows the EUTR definition. 

ISO 38200:2018, 7.3. Informa t ion  
required for recycled material.  

Findings 

Scheme info 

Covered 

The scheme require evidence to be collected to show that material is recycle d  a n d  
legally purchased. Information collected shall be verified.  

Recycled  material  shall  be covered by the CoC and is considered as a separate 
category. 

Justification 

that 

A.3.2.1.2 The Sch eme  
shall require systematic 
processes  to enable the 
identification  of  waste 
material 
has 
completed its life cycl e  
and to differentiate t h is 
material  from  virgin  or 
material  that  are  by-
a 
products 
manufacturing  process 

of 

[2] EUTR Guidance document on Recycled timber and timber products: “By-products” from another production are not waste but are to be regarded as a raw material in the production. Material in a regulated 
timber product is not recycled material if the material is the by-product of a manufacturing process. Example: Sawdust or off-cuts from sawn timber used to make particle board or medium density fibreboard. 

866 

 
 
 
 
 
                                              
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

has 

not 
which 
completed  its  lifecycle 
as  defined  by 
the 
EUTR. 

A.3.2.1.3  The  Scheme 
shall  include  clear  and 
effective  measures 
to 
prevent “timber products of 
a  kind  covered  by  the 
Annex  of 
the  EUTR”, 
produced from i) reclaimed 
material 
that  has  NOT 
completed its lifecycle and  
would  otherwise  have 
been  discarded as waste”, 
ii)  unverified  or  iii)  virgin 
material (as defined by the 
EUTR)  from,  entering  the 
supply chain.  

A systematic process  for collecting evidence of recycled material is requi re d a n d  t h e 
indicator is covered. 

ISO  38200:2018,  3  Terms  and 
definitions   
3.12 recycled material definition 

Findings 

Scheme info 

Covered 

3.13 in-house scrap 
ISO 38200:2018, 6.1 Categories of 
input material 

All input material to the CoC system shall be covered by the DDS and  b e  ve ri f i ed  
before being included into the system.  

Justification 

There  are  clear  requirements  for  all input material to be included into the CoC 
system to be verified or covered by the requirement of the due d i lig en ce syst e m .  
The indicator is therefore covered. 

A.4  General requirements for Certificate Holders 

A.4.1  Conflict 

resolution 

A.4.1.1  The  Scheme 
include 
shall 
requirements 
that 
ensure that disputes are 
identified, recorded and 
managed, in a way that: 

Findings 

Scheme info 

Not Covered 

There is no reference to dispute management, and how to address these. 

requires 

i)  ensures  there  is  a 
transparent 
ongoing 
process  to  address  the 
issue 
the 
ii) 
exclusion 
the 
scope  of the certificate 
situations  or  areas  or 
forest where the legality 
or 
tenure 
of 

for 
from 

867 

 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

Corruption  

management/harvesting 
is  not  defined  or  is 
unclear and disputed. 
iii  ensures  respect  for 
legally-enshrined 
customary tenure rights 
of local communities. 
A.4.1.2  The scheme shall 
include  requirements  to 
certificate 
ensure 
holders  do  not  engage in 
corrupt practices related to 
illegal harvesting. 

that 

Findings 

Scheme info 

There is no reference to corruption of the certificate holder, in the standard. 

A.5  Quality  and procedural requirements for Certificate Holders 

A.5.1 

Internal 
procedures  for 
Certificate 
Holders 

A.5.1.1  The  Scheme 
include 
shall 
requirements 
the 
for 
Certificate  Holders  to 
have  in  place  -  and 
implement  -  systems 
procedures 
and 
all 
covering 
requirements  of 
the 
Scheme. 

A.5.1.2  The  Scheme 
include 
shall 
requirements 
the 
for 
Certificate  Holders  to 
regularly 
the 
proper  functioning  of 
their own procedures. 

review 

ISO 38200:2018, 5 Organizationa l 
requirements 

Findings 

Scheme info 

A CoC system  (incl. a due diligence system) shall be in place to en su re s t h a t  t h e  
document (ISO 38200:2018) is in place.  

Justification 

The indicator is considered to be covered. 

ISO  38200:2018,  5.4.  Internal 
audit. 

Findings 

Scheme info 

The  organization  shall  at least annually conduct internal audi ts with the aim to 
evaluate whether the CoC system confirms with the standard and the organisation’s 
own procedures. 

Justification 

The indicator is considered to be fully covered by the requirement of an annual audit on 
the CoC system. 

868 

Not Covered 

Covered 

Covered 

 
 
 
 
 
 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

A.5.2  Qualification 
and 
competence 

A.5.2.1  The  Scheme 
include 
shall 
requirements 
that 
that  certified 
ensure 
have 
organisations 
personnel with sufficient 
and 
qualifications 
to 
competencies 
consistently 
and 
effectively  implement 
Scheme requirements. 

A.5.3  Risk 

based 
approaches  to 
sourcing,  trade 
or production 

contain 

the  Scheme 
A.5.3.1 
If 
to 
includes  an  option 
implement  a 
riskbased 
approach to sourcing non -
certified  material 
(Due 
Diligence System), it shall:  
clear 
i) 
and 
requirements 
ii) 
ensure 
consistent 
implementation of the Due  
Diligence  System,  for  all 
activities,  materials  and 
suppliers  included  within 
the 
the 
scope 
certification. 

of 

ISO 38200:2018, 5.2.1 Roles a n d  
responsibilities 

Findings 

Scheme info 

ISO  38200:2018,  5.2.2  Top 
management 

The  Scheme  sets  requirements  for  defining  the  competence  needed  for  all 
personnel that affect the performance of the CoC system.  
There  are  requirements  of  education,  training  and/or  experience,  as  well  as 
communication of the CoC requirements to the relevant personnel.  

Competence and training records shall be maintained.   

Top management are to allocate the adequate and appropria te resources to ensu re  
competence and training of personnel. 

Justification 

Requirements  on  qualification  and  competence  is in place and the indicator is 
considered to be covered.  

ISO  38200:2018,  7.1  General 
requirements 

Findings 

Scheme info 

Covered 

Partially 
Covered 

The  Scheme  requires that a due diligence system is implemented to include or 
exclude input material based on defined requirements.  

The due diligence system shall comply with the standard an d  f o r a n y a d di ti on al  
requirements set by the organization, procedures shall be established.  

Risk  criteria shall be broken down into indicators by the organisation to help identify 
low or high risk. Examples have been given in the standard (Annex F),  

The steps to collect due diligence are in place: 

Information required (see 7.2, 7.3 and 7.4); 

a) 
b)  Risk  assessment  process  (see 7.5); 
c)  Risk  mitigation (see 7.6). 

Direct interviews/ discussions / Stakeholder input 

Currently there are no guidance on how to evaluate risks. 

869 

 
 
  
 
 
 
 
 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

Justification 

The  general due diligence system requirements are well in place. However, the 
indicator is considered to be only partially covered. 

The key issues  which result in a full Coverage conclusion not being given relate to:  

 

The risk assessment  process  is generally aligned with the EUTR but it is 
unclear how it is implemented in practice, as there is a lack of detailed 
requirements/guidance on the evaluation of risks and risk  assessment 

A.5.3.2  The  Scheme 
include 
shall 
that 
requirements 
ensure  that  whenever 
there is a change in the 
risk  related  to  illegal 
harvest, 
or 
transport  in  a  supply 
chain  –  or  a  supply 
chain  covered  by  a 
DDS  –  the risk shall be 
assessed  and mitigated 
prior  to  shipping  and 
sale. 

trade 

ISO  38200:2018,  7.2.  General 
information required 

Findings 

Scheme info 

The standard requires DD (incl. information, risk assessment  and risk  mitigation) t o  
be  conducted  prior  to  use  of  the  material,  annually  and whenever information 
related to the product is changed.  
The information collected refer to origin, species and evi dence that the a p p lica bl e 
legal requirements are fulfilled. 

Justification 

There are clear requirements for DDS to be conducted when information is changed 
and the indicator is therefore considered to be covered.  

A.5.3.3  In  cases where 
other 
party 
3rd 
schemes  permitted  to 
be  used  by  the  due 
diligence  system  as 
meeting  specific  due 
diligence requirements,  
shall 
scheme 
the 
include 
requirements 
that  ensure  that  it  is 
clear: 
i) 
recognition 
and;  
ii) how it is verified th a t  

basis 
is  made 

on  what 

ISO  38200:2018,  7.2.  General 
information required 
ISO 38200:2018, 7.4 Info rma t io n 
required for certified material. 

Findings 

Scheme info 

It is recognised that if sourcing certified material from 3 rd party systems,  i t  m u st  b e  
confirmed  that the certification scheme has requirements to evaluate legality in 
forest management that is broad enough to cover the organization’s DDS.   

Recognition  is  done  based  on  the  CB  being  independent,  that  there  are 
requirements  to  ensure  legality at FM level, and the definition should be broad 
enough to cover the DDS of the organization, and CoC should be in place. 

Justification 

There  are  clear  requirements  to  ensure  that  certifi cation  schemes  are  in 
conformance  with  the  organizations  Due  Diligence  scope.  The  indicator  is 

870 

Covered 

Partially 
Covered 

 
 
 
 
 
 
 
 
 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

other  Schemes  ensure 
conformance  with  the 
specific  due  diligence 
requirements. 

considered to be partly covered.  

The key issues  which result in a full Coverage conclusion not being given relate to:  

 

The certification scheme shall have requirements to evaluate risks at forest 
level and it is therefore unclear how supply chain risks on trade and taxes 
are to be covered by certification 

at 

Findings 

Scheme info 

ISO 38200 has the elements in place to cover;  

ISO  38200:2018,  7.1,  General 
requirements 

ISO 38200:2018, 5 organizatio na l 
requirements 

A.5.3.4  The  Scheme 
shall 
include 
requirements to ensu re  
DDS 
that 
the 
comprises, 
a 
minimum, the following  
elements:  i)  a  quality 
management system, ii) 
for 
procedures 
obtaining  access 
to 
information pertinent t o  
the identification of risk;  
risk  assessments, 
iii) 
the 
and 
implementation 
of 
mitigations  measures 
are 
when 
identified. 
B. Requirements for Certification Bodies 
Scheme requirements for Certification Bodies shall be clear and unambiguous and allow the Scheme owner to verify the level of conformance of each Certification Body to these requirements.  

quality management, as well as  
information required 
risk  assessment  process 
risk  mitigation 

The elements in question are in place and the indicator is considered to be covered.  

i) 
ii) 
iii) 
iv) 

Justification 

risks 

iv) 

Covered 

B.1 General Certification Body  requirements 
B.1.1  Competence 
and 
qualifications 

17065:2012, 

ISO/IEC 
6.1.2 
Management  of  competence  for 
personnel involved in certificat io n 
process;  6.1.2.1, 6.1.2.2  

Findings 

Scheme info 

Partially 
Covered 

other 

B.1.1.1  The  Scheme 
shall have mechanisms 
to ensure that auditors,  
relevant 
and 
personnel 
the 
of 
Certification  Body,  are 
qualified and competent 
to 
evaluate 
organisations’ 
compliance with specific 
Scheme requirements. 

ISO/IEC 
Application review; 7.3.4  

17065:2012, 

7.3 

ISO/IEC  17065:2012,  Annex  A 
(informative) Principles for product  
their 
certification  bodies  and 

ISO’s  Committee  on  Conformity  Assessment  (CASCO)  has  developed  several 
standards on conformity assessment to be used in a certification process, includin g 
ISO/IEC  17065  (Conformity  assessment  –  Requirements  for  bodies  certi fying 
products, processes  and services). According to ISO 17065 personnel of a CB shall  
have competences to perform the certification activity, considering the require me nt  
of the scheme. ISO 17065 is a standard specifying general practices for CB s  wh e n  
conducting certification activities. When defining the need for co m p et e ncie s a n d  

871 

 
 
 
 
 
 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

certification activities; 
A.3 Competence 

training  the  CB  shall  take into account the requirement of the scheme (see ISO 
17065:2012, 6.1.2.1 a). 

However,  there  is  no  scheme  supporting  the  implementation of the ISO 38200 
standard  and  it  is  voluntary  for  a  CB to comply with ISO 17065 when certifying 
against ISO 38200. 

Justification 

ISO 17065 has clear requirements to have competences in place to certify against a 
standard´s requirements. However, ISO 38200 does not require CBs to b a se  t h e i r 
certification  system  on  ISO  17065.  There  is  no  requirement  for  an  oversight 
mechanism  that  ensures  competence  is  in  place.  It  is  therefore  not possible to 
conclude that the indicator is fulfilled without evaluating the applicable certi fi cat io n 
bodies system requirements.  

In cases  where the certification body is accredited by an accreditation body th a t b a se  
their  systems  on  the  ISO  17000  standards,  there  are  requirements  for  having 
applicable competence in place. However, there is no specific guidance describing th e 
competence needed for certification bodies to evaluate the 38200 require men t s.  I t  i s 
therefore unclear how this will be managed in practice. To be abl e t o  st a t e  t h a t  t h e  
indicator is fully covered an evaluation of the applicable CB’s system wi l l  h a ve  t o  b e  
conducted. 

If the systems  of the CB are based on/and accredited against ISO 17000 conformance  
standards  there  will  be  some  requirements  on  competence,  as  well  as  oversight 
mechanism, and the indicator is therefore considered partially covered. 

B.1.1.2  If  the  Scheme 
includes  an  option  for 
the Certificate Holder to 
implement 
a  Due 
Diligence  System,  the 
scheme  shall  ensure 
that  the  auditors  and 
relevant 
other 
personnel 
the 
of 
Certification  Body  are 
qualified and competent 
to 
evaluate 
organisations’ 

17065:2012, 

6.1.2 
ISO/IEC 
Management  of  competence  for 
personnel involved in certificat io n 
process;  6.1.2.1  

Findings 

Scheme info 

Partially 
Covered 

There are requirements on place under ISO 17065 to ensure competence within the 
applicable scheme, but there is no reference to due diligence systems. 

See also B.1.1.1 

Justification 

ISO 17065 has clear requirements to have competences in place to certi f y a g ai nst  a  
standard’s  requirements.  However,  ISO  38200  does  not  require  CBs  to  base  their 
certification  system  on  ISO  17065.  There  is  no  requirement  for  an  oversight 

872 

 
 
 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

compliance with related 
Scheme requirements. 

B.1.2 

Impartiality 

B.1.2.1  The  scheme 
shall 
include 
requirements to ensure  
that auditors, and other 
personnel  relevant  to 
conformance 
the 
evaluation 
an 
of 
organisation  shall  be 
impartial to the ent it y(-
ies) under evaluation. 

2012, 

17065: 

ISO/IEC 
4.2 
Management of impartiality; 4.2.1 ,  
4.2.2,  4.2.3,  4.2.4,  4.2.5,  4.2.6, 
4.2.7, 4.2.8, 4.2.9, 4.2.10, 4. 2 .1 1 , 
4.2.12  

2012, 

5 
17065: 
ISO/IEC 
safeguarding 
for 
Mechanism 
impartiality;  5.2.1,  5.2.2,  5.2.3, 
5.2.4  

ISO/IEC  17065:  2012,  6.1.3 
Contract with the personnel  

mechanism  that  ensures  competence  is  in  place.  It  is  therefore  not  possible  to 
conclude that the indicator is fulfilled without evaluating the app lica ble  ce rt i fi cat io n 
bodies system requirements.  

In cases  where the certification body is accredited by an accreditation body th a t b a se  
their systems  on the ISO 17000 standards, the requirements for having competence to  
certify an organisation against the standard requirements is in place. However, there is 
no  specific guidance describing the competence needed for certification bodies to 
evaluate the 38200 requirements, including the due diligence system . It is unclear ho w 
this will be managed in practice. To be able to state that the indicator is full y c o ve red  
an evaluation of the applicable CBs system will have to be conducted.  

If the systems  of the CB are based on/and accredited against ISO 17000 conformance  
standards  there  will  be  some  requirements  on  competence,  as  well  as  oversight 
mechanism, and the indicator is therefore considered partially covered. 

Findings 

Scheme info 

Partially 
Covered 

ISO’s  Committee  on  Conformity  Assessment  (CASCO)  has  developed  several 
standards on conformity assessment to be used in a certification process, includin g 
ISO/IEC  17065  (Conformity  assessment  –  Requirements  for  bodies  certifying 
products,  processes,  and  services).  ISO  17065  has  elaborate  requirements  on 
impartiality. 

However,  it  is  not  required  for  a  CB  to  comply  with  ISO 17065 when certifying 
against ISO 38200. 

Justification 

ISO 17065 has clear requirements on impartiality. 

However, ISO 38200 does not require CBs to base their certification  syst e m  o n  I S O  
17065. There is no requirement for an oversight mechanism that ensures impartiality is 
in place. It is therefore not possible to conclude that the indicator is f u l f i lle d wi t h ou t  
evaluating the applicable certification bodies system requirements.  

In cases  where the certification body is accredited by an accreditation body th a t b a se  
their systems  on the ISO 17000 standards, the requirements for impartiality, as well a s 
oversight mechanism will be in place. In that case, the indicator would be covered.  

873 

 
 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

that 

B.1.2.2  The  Scheme 
include 
shall 
that 
requirements 
ensure 
the 
certification  decision 
process  is;  
i) well defined and; 
ii)  ensures 
the 
that 
decision on certification 
by 
is 
conducted 
that 
positions/bodies 
are 
to  the 
auditee. 

impartial 

However,  it  will  have  to  be  verified  that  the  CB  and  the  accreditation  body  is 
operating  in  conformance  with  ISO  17065:2012.  Therefore,  the  indicator  is 
considered partially covered.  

17065:2012, 

4.2 
IEC/ISO 
Management of impartiality; 4.2.8 ,  
4.2.10  

Findings 

Scheme info 

Partially 
Covered 

IEC/ISO  17065:2012,  4.4.  Non-
discriminatory conditions 

17065:2012, 

IEC/ISO 
7.6 
Certification decision; 7.6.1, 7.6.2 ,  
7.6.3, 7.6.4, 7.6.5, 7.6.6  

ISO’s  Committee  on  Conformity  Assessment  (CASCO)  has  developed  several 
standards on conformity assessment to be used in a certification process, includin g 
ISO/IEC  17065  (Conformity  assessment  –  Requirements  for  bodies  certifying 
products, processes  and services). ISO/IEC 17065 has clear requirements in pl a ce 
that personnel of the CB shall be partial in the certification -decision making. And the 
certification body shall confine requirements for decisions related to the scope of the 
certification. 

However, it is voluntary for a CB to comply with ISO 17065 when certifying a g ai nst  
ISO 38200. 

Justification 

ISO 17065 has requirements for impartiality in the decision -making process, as well a s 
for the CB to set requirements for decision making. 

However, ISO 38200 does not require CBs to base their certification  syst e m  o n  I S O  
17065.  It  is  therefore not possible to conclude that the indicator is fulfilled without 
evaluating the applicable certification bodies system requirements.  

In cases  where the certification body is accredited by an accreditation body th a t b a se  
their systems  on the ISO 17000 standards, the requirements for decision  m a ki n g,  a s 
well  as  oversight  mechanism  will  be  in place. In that case, the indicator would be 
covered.  

However,  it  will  have  to  be  verified  that  the  CB  and  the  accreditation  body  is 
operating  in  conformance  with  ISO  17065:2012.  Therefore,  the  indicator  is 
considered partially covered.  

B.2 Certification Body  requirements for auditing  and certification 
B.2.1  Auditing 

Findings 

process 

B.2.1.1  The  Scheme 
include 
shall 
requirements 
that 
ensure that Certification 

ISO/IEC 17065:2012, 4.6 Publicly 
available information 

ISO/IEC 17065:2012, 7.1 General; 

Scheme info 

874 

Partially 
Covered 

 
 
 
 
 
 
apply 

Bodies 
documented 
methodology 
evaluation 
(assessments 
audits) of clients.  

for 

ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

a 

7.1.2. 

the 

and 

ISO/IEC 17065:2012, 8.2 Genera l 
management 
system 
documentation 

ISO’s  Committee  on  Conformity  Assessment  (CASCO)  has  developed  several 
standards on conformity assessment to be used in a certification process, includin g 
ISO/IEC  17065  (Conformity  assessment  –  Requirements  for  bodies  certifying 
products, processes  and services). ISO 17065 have requirements in place to m a ke  
the evaluation setup public. Procedures shall be in place to ensure the standard and 
other normative documents are in place.  

ISO/IEC 
17065,  Annex  A 
(informative) Principles for product  
certification  bodies  and 
their 
activities;  A.4.3 
certification 
Openness  

However, it is voluntary for a CB to comply with ISO 17065 when certifying a g ai nst  
ISO 38200. 

Justification 

ISO 17065 has requirements on having a documented methodology for the evaluation. 

However, ISO 38200 does not require CBs to base their certification  syst e m  o n  I S O  
17065.  There  is  no  requirement  for  an  oversight mechanism that ensures that the 
methodology is documented. It is therefore not possible to conclude that the indicator is 
fulfilled without evaluating the applicable certification bodies system requirements.  

If the accreditation and requirements follow the ISO 17065 requirements, then indicator 
is covered. However, it will have to be verified that the CB and the accreditation bo dy is 
operating in conformance with ISO 17065:2012. Therefore, the indicator is considere d  
partially covered. 

to 

B.2.1.2 As a minimu m,  
this  methodology shall 
include  procedures  for 
the following activit ie s:  
of 
Evaluation 
i) 
of 
conformity 
organisations 
the 
Schemes  (e.g. audit of 
sites,  or  inspection  of 
records  or  of  self-
assessment 
declarations); 
ii) 
and 
Review 
certification  decision; 
Issuance  of  a 
iii) 
and 
certificate; 
re-
iv) 

  Periodic 

Partially 
Covered 

ISO/IEC 
Evaluation 

17065:2012, 

7.4 

Findings 

Scheme info 

ISO/IEC 17065:2012, 7.5 Review 

ISO/IEC 
Certification decision 

17065:2012, 

7.6 

ISO/IEC 
Certification documentation 

17065:2012, 

7.7. 

ISO/IEC 
Surveillance 

17065:2012, 

7.9 

ISO’s  Committee  on  Conformity  Assessment  (CASCO)  has  developed  several 
standards on conformity assessment to be used in a certification process, includin g 
ISO/IEC  17065  (Conformity  assessment  –  Requirements  for  bodies  certifying 
products, processes,  and services). The standard touches upon the relevant po in ts 
of this indicator.  

However, it is voluntary for a CB to comply with ISO 17065 when certifying a g ai nst  
ISO 38200. 

Justification 

ISO  17065  has  requirements  on  having  a  methodology in place for evaluation of 
conformity, Review and certification decision, issuance of a certificat e ;  a nd  p e ri od ic 

875 

 
 
 
 
 
 
 
 
 
 
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assessment. 

surveillance. 

However, ISO 38200 does not require CBs to base their certification  syst e m  o n  I S O  
17065.  There  is  no  requirement  for  an  oversight mechanism that ensures that the 
methodology cover the relevant points. It is therefore not possible to conclude that t h e  
indicator  is  fulfilled  without  evaluating  the  applicable  certification  bodies  system 
requirements.  

If the accreditation and CB requirements follow the ISO 17065 requiremen t s,  t h e n  
indicator  is  covered.  However,  it  will  have  to  be  verified  that  the  CB  and  the 
accreditation body is operating in conformance with ISO 17065:2012. Therefore, the 
indicator is considered partially covered. 

ISO 17065:2012, 7.9 Surveillance; 
7.9.1  

Findings 

Scheme info 

Not Covered 

ISO’s  Committee  on  Conformity  Assessment  (CASCO)  has  developed  several 
standards on conformity assessment to be used in a certification process, includin g 
ISO/IEC  17065  (Conformity  assessment  –  Requirements  for  bodies  certifying 
products, processes  and services). ISO 17065 have requirements on surve i l l an ce 
requirements  but  does  not  fully  cover  the indicator. It is noted that surveillance 
requirements this shall be defined by the certification scheme. 

However,  there  is  no  scheme  supporting  the  implementation  of the ISO 38200 
standard  and  it  is  voluntary  for  a  CB to comply with ISO 17065 when certifying 
against ISO 38200. 

Justification 

Requirements in ISO 17065 and ISO 38200 does not cover the specific point of t h e  
indicator related to audit procedures. The indicator is therefore considered not to be  
covered.  

876 

the 

implement 

B.2.1.3  The  Scheme 
include 
shall 
requirements 
that 
ensure that Certification 
Bodies  have  in place - 
and 
– 
specific  procedures  for 
audits  that  include  at 
least 
following: 
i)  frequency  of  audits; 
(no  longer  than  every 
12 
months); 
ii)  requirements for on-
site  (field)  visits  where 
applicable; 
iii) sampling protocol for 
audits  (if  applicable); 
and 
iv) 
structure 
the 
competencies  of 
audit 
team; 
v)  the  minimum  set  of 
aspects that need to be  
checked in every audit ;  
vi) minimum content o f  
audit reports, includin g  
non-conformances, 
clarification  of  scope, 
and 
process 
audit 

 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

B.2.2  Stakeholder 
consultation 

B.2.2  Corruption 

evaluation findings. 
vii) 
for 
ability 
unannounced  or  short-
notice audits in case  o f  
substantiated claims o r 
for other reasons.  
B.2.2.1  The  Scheme 
shall 
include 
mechanisms  to  ensure 
that Certification Bodies 
consultation 
conduct 
stakeholder 
with 
(including 
rights 
holders) as appropriate  
in  relation  to  audits 
(only applicable wh e re  
necessary** 
for 
evaluating complia nce  
of certificate holders).  

scheme 
that 

shall 
The 
ensure 
the 
certification holder h a s 
a  proper  stakeholder 
consultation  process in 
place. 

B.2.2.2  The  Scheme 
include 
shall 
mechanisms to identif y 
(or  for  the Certification 
Body 
so) 
companies  sanctioned 
in 
for  engagement 
corrupt 
practices 
relevant  to  the  forest 
sector. 

do 

to 

Findings 

Not Covered 

Requirements in ISO 17065 and ISO 38200 does not cover the specific point of t h e  
indicator related stakeholder consultation. The indicator is therefore considered n o t 
to be covered.  

Findings 

Scheme info 

Not Covered 

There  is  no  specific  mentioning  of  identification  of  companies  sanctioned  for 
involvement  in  corrupt  practices  relevant  for  the  forest  sector.  Perception  of 
corruption is mentioned as a high-risk indicator, but this is not directly related to t h e  
sanction of a specific company.   

Justification 

The indicator is not covered. 

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ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

C. Requirements for Certification Schemes 

C.1 Transparency 
C.1.1 

Transparency 

C.1.1.1 
Scheme 
requirements  for  both 
Certificate Holders a n d  
Certification 
Bodies 
shall 
publicly 
be 
available online.  

ensure 

C.1.1.2  Schemes  shall 
requirements 
include 
that 
that 
relevant 
information 
about  the  following  is 
freely available: 
i)  development  and 
content of the Scheme; 
ii)  how  the  system  is 
governed;  
ii) who is evaluated and 
under what process;  
iv)  impact  information 
and the various ways in  
which stakeholders ca n  
engage. 

Not Covered 

Partially 
Covered 

Findings 

Scheme info 

All ISO standards are available for a fee.  

Justification 

The ISO 38200:2018 standard is not supported by a scheme, and it is not possi b l e  t o  
get a full overview of the scheme requirements for certificate holders and certif ica t io n 
bodies. The systems implemented by certification bodies and accre d it at io n s b o d ie s 
might differ between organisations, as there are no requirements specified re la t ed  t o  
the implementation of ISO 38200:2018.  

Findings 

Scheme info 

ISO  38200  is  an  international  standard and not a certification scheme. As such 
there are no requirements defined by ISO 38200 related to this indicator. Howeve r,  
ISO  38200  is  developed  and  managed  as  other ISO standards. It is possible to 
obtain the relevant information from the ISO webpage.  

There is no Impact Information available on ISO 38200. 

Justification 

The indicator is considered to be partially covered, as most of  t h e  i n f o rm a ti on  i s 
available through ISO webpage. 

See  also  the  overview  section  of  this  report  for  more  information  on  the 
development and content of the Scheme; how ISO is governed; who i s e va l u at ed  
and under what process and the various ways in which stakeholders can engage. 

878 

 
 
 
 
 
 
 
 
 
 
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C.1.1.3  The  Scheme 
include 
shall 
requirements 
that 
ensure  that  an  up-to-
of 
register 
date 
certified/verified 
organisations is publicly 
available. 

C.1.1.4  The  Scheme 
shall  make  summaries 
full  reports)  with 
(or 
relevant  findings  from 
audits available on t h e  
internet. 

C.1.2.1  Procedures  for 
complaints 
handling 
and grievances shall be 
in place, made publicly 
and 
available 
The 
implemented. 
procedures  shall  be 
publicized, 
clearly 
making 
for 
stakeholders  to  submit 
or 
comments 
complaints 
where 
applicable. 
C.1.3.1 
The 
Certification  Scheme 
in  place 
shall  have 
requirements  at  all 
levels  of  the  scheme 

it  easy 

C.1.2 

Impartiality 

C1.3 

Conflict 
of 
interest  and 
corruption 

2012, 

17065: 

ISO/IEC 
4.2 
Management of impartiality; 4.2.1 ,  
4.2.2,  4.2.3,  4.2.4,  4.2.5,  4.2.6, 
4.2.7, 4.2.8, 4.2.9, 4.2.10, 4. 2 . 11 ,  

Findings 

Scheme info 

There is no complete online register for organisations certifie d u n d er I S O  3 8 2 0 0 
(ISO email response-27/10/2020 – Representative Project Committee ISO/PC 287). 

Justification 

The indicator is not covered. 

Findings 

Scheme info 

There is no requirement to make summaries (or full reports) with relevan t  f i nd in gs 
from audits available. 

Justification 

The indicator is not covered. 

Findings 

Scheme info 

ISO 38200 is not a scheme. It is unclear who are to deal with complaints relat ed  t o  
the standard and the implementation of the standard.  

Justification 

The  indicator  is  considered  Not  Covered,  as  the  complaints  related  to  the 
implementation of the standard.  

Findings 

Scheme info 

ISO  38200  does  not  address  the  issue  of  corruption  within  the  CH,  but  legal 

879 

Not Covered 

Not Covered 

Not Covered 

Partially 
Covered 

 
 
 
 
 
 
 
 
 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

(normative 
requirements  for  CHs, 
requirements  for  CBs, 
and 
the  scheme 
functioning) to manage  
risks  of  corruption  and 
conflict of interest. 

for 

4.2.12 

requirements will have to be complied with by the CH. 

2012, 

5 
17065: 
ISO/IEC 
Mechanism 
safeguarding 
for 
impartiality;  5.2.1,  5.2.2,  5.2.3, 
5.2.4 

ISO/IEC  17065:  2012,  6.1.3 
Contract with the personnel  

ISO’s  Committee  on  Conformity  Assessment  (CASCO)  has  developed  several 
standards on conformity assessment to be used in a certification process, includin g 
ISO/IEC  17065  (Conformity  assessment  –  Requirements  for  bodies  certifying 
products,  processes  and  services).  ISO  17065  has  requirements  in  place  to 
managing and safeguarding impartiality for CBs. However, it is voluntary for a CB t o  
comply with ISO 17065 when certifying against ISO 38200. 

Justification 

There is no overall system to manage risk of corruption and conflict  o f  i nt e re st  i n  
ISO, neither as a standard setting body or in the requirements for CH’s  or CBs.   B u t  
the way the system operates are sufficient to consider this indicator to be  co ve re d  
for  certification  conducted  by  CBs  accredited  in  conformance  with  CASCO 
conformity assessment standards. 

However, as ISO 38200 does not require CBs to base their certification system on IS O  
17065, it will have to be verified that the CB and the accreditation body is operati ng  i n 
conformance with ISO 17065:2012. Therefore, the indicator is co n si d e re d  p a rt ial l y 
covered. 

C.2 Scheme & standard  scope 
Note:  section C2 is not specifically referring to EUTR  issues but has been included  as part of the evaluation  of schemes to understand scheme  structures. 

C.2.1

Standard 
adaptation to 
the  national 
or 
subnational 
context 

shall 

International 
C.2.1.1
standards 
be 
adapted to the nationa l 
or  subnational  context 
in which they are bein g 
and 
implemented 
contain 
of 
a 
applicable legislation, or 
the  Scheme 
shall 
enable/require detailed  
evaluation of applicable 
legislation in a nationa l 
context. 

list 

ISO 38200:2018, 5.3.2 Record ing  
of legal requirements 

Findings 

Scheme info 

Not Covered 

The certificate holder will have to identify legislation applicable to their supply cha in  
(depending of origin and scope of CoC/DDS).  

Direct interviews/ discussions / Stakeholder input 

The standard is an international standard, that has general requirements which ca n  
be  applied  to  organisations  at  national  level without being adapted to specific 
national  conditions.  The  standard will be adopted at national level by national 
standards bodies, but national legislation is not to be identified by the NSB.  

880 

ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

C.2.2 

International 
conventions 
and treaties 

C.2.2.1  The  Scheme 
shall include a list of the 
relevant 
international 
conventions  to  which 
the country has ratified, 
and  which  hold  legal 
force in the country. 

C.2.3  Use 

of 

contractors 

C.2.3.1 
The 
requirements  for  forest 
managers  and  supply 
chain  entities  shall  be 
applicable 
the 
organisation’s 
contractors 
outsourcing facilities. 

and 

to 

Justification 

The  standard  is  not  to  be  adapted  to  national  and  subnational context, as the 
approach for CoC and due diligence will be similar regardless of where a co m p a n y 
is based. 

The  certificate  holder is to identify the applicable legislation. This can become 
complex if the material sources originate from many countries. Neither ISO, the  CB  
or national standards bodies are to identify the list of applicable legislation th a t  a re  
relevant for the implementation of ISO38200.  

This is a gap that is like to result in an uneven implementation of the DDS under the 
ISO 38200 standard 

Findings 

Not Covered 

List of international conventions to which a country has ratified is not defined as part  
of  ISO  38200.  See  indicator  C.2.1  for  evaluation  of  the  identified  applicable 
legislation. 

ISO 38200:2018, Introduction 

Findings 

ISO 38200:2018, 5.6 Outsourcing 

Scheme info 

38200:2018,  Annex  D 

ISO 
(informative) Internal audits 

ISO 38200 is not applicable to forest management. 

Covered 

The organization shall ensure that the contractor has a documented control syst e m  
is in place that ensures that material related to the CoC is clearly i d e nt if ia b le.  A n  
outsourcing  agreement  shall  be  in  place  that  shall  allow  the  organization  /or 
representative to gain access to the contractor’s operations in order to ensu re  t h a t  
the CoC system  or the requirements of ISO38200 is met.  

Justification 

The standard consider outsourcing in terms of the organisations Co C syst e m   a n d  
clear identification of the material being handled under outsourcing.  

881 

 
 
 
 
 
  
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

C.2.4  Endorsing 

and 
recognising 
of 
other 
Schemes and 
systems 

C.2.4.1  If  the  Scheme 
includes the recognition 
or endorsement of other 
schemes  or  systems,  it 
shall  ensure  coverage 
consistent 
and 
implementation 
of 
EUTR  requirements  at 
all levels. 

C.3 Accreditation and oversight 

C.3.1  Accreditation 

C.3.1.1 The Scheme sha l l 
for 
include  a  system 
accreditation  or  oversight 
of  Certification  Bodies  to 
ensure  that  CBs  have  in 
place 
required 
procedures,  capacity  and 
competencies. 

the 

ISO 38200:2018, 7.4 Info rma t io n 
required for certified material. 

Findings 

Scheme info 

Partially 
Covered 

Certified material can be included as input material into the DDS. They sh a l l b e  i n  
compliance with the organization’s procedures and comply with due diligence.  

The ISO 38200 standard does allow certified material from ext e rn a l ce rt if ica t io n 
systems  to be included in the scope of the CoC system. 

The  requirements  do not as include a formal recognition or endorsement of the 
external  certification  schemes,  but  allow  the  organisation using the ISO 38200 
standard to include certified material as an input category. 

Justification 

The  scheme  does  not  endorse  specific  certification  schemes  but  set  criteria  for 
schemes holder to evaluate the certification scheme before accepting material as valid  
input material. It is not needed to collect tree species and origin of material source s a s 
certified if it is found that the CH finds the scheme to be in compliance with their scope, 
nor evidence that applicable legislation are fulfilled. This means that the requirement of 
the EUTR to collect information on species and origin is not fulfilled.   

Also, the ISO38200 does not specify the normative law categories in confo rma nce  
with the EUTR to be identified. The scheme does therefore not guaran t ee  t h at  a n  
organizations procedure will cover all relevant law categories,  a n d  t h e re f ore  t h e  
recognized certified material might not be in line with the EUTR. This will have to be 
assessed  on an individual basis.  

Findings 

Scheme info 

Not Covered 

ISO’s  Committee  on  Conformity  Assessment  (CASCO)  has  developed  several 
standards on conformity assessment to be used in a certification process, includin g 
ISO/IEC 17011 (Conformity assessment – Requirements for accredi t a t io n b o d ies 
accrediting conformity assessment bodies). 

882 

 
 
 
 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

that 

C.3.1.2 The Scheme sha l l 
ensure 
the 
requirements  and  process 
for accreditation is publicly 
available. 

Direct interviews/ discussions / Stakeholder input 

The accreditation of CBs is done at national level. There is no requi re m en t  i n t h e  
ISO38200 standard for the accreditation of CBs. ISO has developed procedures o n  
accreditation, which is usually applied, but there can be national d i f f ere n c es t h a t  
means that there can be differences to the accreditation standard. 

ISO  does  not  have  the  overview  of  certification  bodies  (ISO  Call-5/11/2020  - 
Representative Project Committee ISO/PC 287). 

Justification 

 Based on the above the indicator is not covered. 

ISO/IEC  17011:2017,  8.2  Publicly 
available information; 8.2.1  

Findings 

Scheme info 

Partially 
Covered 

ISO/IEC  17011  Conformity  assessment – Requirements for accreditation bodies 
accrediting  conformity  assessment  bodies  can  be  accessed  by  a  fee.  It  can  be 
purchased from a national standard body. 

ISO’s  Committee  on  Conformity  Assessment  (CASCO)  has  developed  several 
standards on conformity assessment to be used in a certification process, includin g 
ISO/IEC 17011 (Conformity assessment – Requirements for accredi t a t io n b o d ies 
accrediting conformity assessment bodies). ISO 17011 requires information relat ed  
to accreditation body and process to be made public.  

However,  it  is  voluntary  for  an  accreditation  to  comply  with  ISO  17011  when 
accrediting CBs to certify against ISO 38200. 

Justification 

If an accreditation body accredit against ISO 17000 conformance standards there  wi l l 
be to make information of the accreditation body and process public, and the indicat o r 
would be covered. 

If an accreditation body accredit against ISO 17000 conformance standards there  wi l l 
be  to  make  information  on  certification  bodies public, and the indicator would be 
considered to be covered. However, this is not required and therefore not possi b l e  t o  
conclude that the indicator is fulfilled without evaluating the applicable  a ccre d it at io n 

883 

 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

C.3.1.3 The Scheme sha l l
make publicly available, an
up-to-date  list  and details 
of 
accredited
all 
Certification Bodies 

bodies system requirements.  

Therefore, this indicator is considered to be partially covered. 

ISO/IEC  17011:2017,  8.2  Publicly 
available information; 8.2.2  

Findings 

Scheme info 

ISO’s  Committee  on  Conformity  Assessment  (CASCO)  has  developed  several 
standards on conformity assessment to be used in a certification process, includin g 
ISO/IEC 17011 (Conformity assessment – Requirements for accredi t a t io n b o d ies 
accrediting conformity assessment bodies). ISO 17011 requires a publicly available  
list of CBs.   

However,  it  is  voluntary  for  an  accreditation  to  comply  with  ISO  17011  when 
accrediting CBs to certify against ISO 38200. 

Justification 

If an accreditation body accredit against ISO 17000 conformance standards there  wi l l 
be  to  make  information  on  certification  bodies public, and the indicator would be 
considered to be covered. However, this is not required and therefore not possi b l e  t o  
conclude that the indicator is fulfilled without evaluating the applicable  a ccre d it at io n 
bodies system requirements.  

Therefore, this indicator is considered to be partially covered. 

C.3.1.4 The Accredita ti on
have
shall 
Body 
mechanisms to ensure that
relevant  personnel  are
qualified and competent to
Certification 
evaluate 
in 
Body’s  performance 
relation 
Scheme 
to 
requirements. 

ISO/EIC  17011:2017,  6  Resource 
requirements;  

Findings 

Scheme info 






6.1.1 General
6.1.2 Determination of
competence criteria; 6.1.2.1,
6.1.2.3, 6.1.2.4, 6.1.2.5, 6.1.2.6,
6.1.2.8, 6.1.2.9. 

6.1.3 Competence management;
6.1.3.1

ISO’s  Committee  on  Conformity  Assessment  (CASCO)  has  developed  several 
standards on conformity assessment to be used in a certification process, includin g 
ISO/IEC 17011 (Conformity assessment – Requirements for accredi t a t io n b o d ies 
and accrediting conformity assessment bodies). ISO 17011 requires the perso n n e l 
carrying out the accreditation has the skills and competence needed. 

However,  it  is  voluntary  for  an  accreditation  to  comply  with  ISO  17011  when 
accrediting CBs to certify against ISO 38200. 

Direct interviews/ discussions / Stakeholder input 

884 

Partially 
Covered 

Partially 
Covered 

ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

Certification  bodies  are  accredited  at  a  national  level.  Most  will  base  their 
accreditation  on  ISO  17011, but there might be national differences ((ISO Call-
5/11/2020 - Representative Project Committee ISO/PC 287). 

Justification 

In cases  where the accreditation body base their systems on the ISO 17000 standards, 
there  are  requirements  for  having  mechanisms  to  ensure  competence  in  place. 
However,  there  is  no  specific  guidance  /  scheme  documents  describing  the 
competence  needed  for  the  accreditation  body  to  accredit  against  the  38200 
requirements. It is therefore unclear how this will be managed in practice. To be able to 
state that the indicator is fully covered an evaluation of the applica bl e a ccre d it a ti on  
bodies system will have to be conducted. 

If  the  systems  of  the  accreditation  body  are  based  o n  ISO  17000  conformance 
standards  there  will  be  some  requirements  on  competence,  and  the  indicator  is 
therefore considered partially covered. 

ISO 17011:2017, 7.9 Accreditation 
cycle; 7.9.1, 7.9.3, 7.9.4  

Findings 

Scheme info 

Partially 
Covered 

ISO’s  Committee  on  Conformity  Assessment  (CASCO)  has  developed  several 
standards on conformity assessment to be used in a certification process, includin g 
ISO/IEC 17011 (Conformity assessment – Requirements for accredi t a t io n b o d ies 
and accrediting conformity assessment bodies). ISO 17011 requires the evaluati on  
of  CBs  at  a  regular basis, and that onsite evaluation does not exceed every two 
years. A re-assessment  shall not exceed 5 years. The is no mentioning on the need 
for stakeholder consultation.  

However,  it  is  voluntary  for  an  accreditation  to  comply  with  ISO  17011  when 
accrediting CBs to certify against ISO 38200. 

Justification 

If an accreditation body accredit against ISO 17000 conformance standards there  wi l l 
requirement to regularly evaluate the CBs, and the indicator would be considered to be 
covered. However, this is not required and therefore not possible to conclude th a t  t h e 
indicator  is  fulfilled  without evaluating the applicable accreditation bodies system 
requirements.  

885 

C.3.2  Oversight 

mechanism 

C.3.2.1  The  Scheme 
shall  ensure  that  the 
competence 
and 
consistent performance 
of Certification Bodies is 
regularly evaluated.  

both 
AND 

shall 
Performance 
desk-
employ 
based 
field 
approaches, including: 
i) 
Stakeholder 
consultation 
ii) In-field evaluation  o f  
the performance of t h e  
Body, 
Certification 
whether 
via  on-site 
inspections  of  certified 
forests/  supply  chain 
or  witness 
entities 
audit 
of 
audits 
personnel. 

 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

that 

establishing 

C.3.2.2  The  Scheme 
include 
shall 
that 
requirements 
ensure 
the 
oversight  mechanism 
applies  a  clear  basis 
for:  
i) 
conformance;  
raising  corrective 
ii) 
non-
actions 
for 
and 
conformance, 
ensuring closure withi n  
timeframes 
to  avoid 
legal  non-compliance, 
and;  
iii) certification issue (o r 
maintenance) decisi on  
making. 

Therefore, this indicator is considered to be partially covered. 

ISO/IEC 
Accreditation decision-making 

17011:2017, 

7.7 

Findings 

Scheme info 

Not Covered 

17011:2017, 

ISO/IEC 
9.5 
Nonconformities  and  corrective 
actions 

a)  The requirement of establishment of conformance is not defined in ISO 17011  
i) 

corrective actions shall be appropriate to the impact of the problems 
encountered and shall be implemented in a timely manner.  
The accreditation body shall describe its process for all types of 
accreditation decisions, and the standard specified the information to be 
provided to the reviewer. 

ii) 

Direct interviews/ discussions / Stakeholder input 

ISO  International  have  not  implemented  an  oversight  mechanism  that  cover  the 
implementation of the standard at national level (ISO Call-5/11/2020 - Represent at ive  
Project Committee ISO/PC 287 ).  

Justification 

Not covered 

i-iii)  This  will have to be evaluated at a national basis, as CBs are accredited at 
national  level  and  national  standards  bodies  or  accreditation  bodies  specify 
requirements for their national certification bodies 

C.3.2.3  The  Scheme 
shall 
the 
specify 
approach to be used i n  
oversight, ensuring that 
oversight 
the 
is 
mechanism 
the 
independent  of 
Certification 
Bodies 
being assessed.  
C.3.2.4    The  Scheme 
shall 
the 
define 
frequency  of  oversight 

ISO  17011:2017,  7  Process 
requirements;  7.1.  Accreditation 
requirements 

Findings 

Not Covered 

i-iii)  This  will have to be evaluated at a national basis, as CBs are accredited at 
national  level  and  national  standards  bodies  or  accreditation  bodies  specify 
requirements for their national certification bodies 

Findings 

Not Covered 

  i-iii)  This  will  have  to  be  evaluated  at  a  national basis, as CBs are accredited at 

886 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

or  the  procedure  for 
determining 
the 
frequency, applicable in 
the  case  of  risk-based 
oversight. 

C.4 Certification process 
C.4.1  Compliance 

evaluation 

that 

C.4.1.1  The  Scheme 
include 
shall 
that 
requirements 
the 
ensure 
Certification 
Bodies 
applies  a  clear  basis 
for:  
i) 
conformance;  
ii) 
actions 
compliance, and;  
iii) certification decision  
making. 

raising  corrective 
non-
for 

establishing 

national  level  and  national  standards  bodies  or  accreditation  bodies  specify 
requirements for their national certification bodies 

Findings 

Scheme info 

Justification 

The threshold for establishing conformance, raising corrective actions, and ma ki n g  
certification decisions has not been identified. There is no g u i d an ce p ro vi di ng  a  
uniform threshold is applied between CBs and countries. The indicator is the re f o re  
not covered 

C.4.1.2  The  Scheme 
requirements 
for 
establishing 
conformance 
should 
enable comparison with 
the 
of 
definition 
negligible  and  non-
negligible 
as 
outlined  in  the  EUTR 
and associated guides.  

risk 

ISO  38200:2018,  5.3.2  recording of 
legal requirements 

ISO 
assessment  process 

38200:2018, 

7.5 

Risk 

Findings 

Scheme info 

ISO 38200 operates with low or high risk. 

The standard requires risk assessment  procedures and to conduct risk assessm e n t  
to establish the risk level - guidance is found in Annex F. 

Justification 

The use of low and high risk enable comparison with the negligible and non -negligib le  
risk  terms  used  in  the  EUTR.  However,  the  risk  assessment  process  and thresholds 
have not been defined. It is not possible to conclude that low or hi g h -ri sk i n d i ca to rs 
chosen  by  the  organisation  under  evaluation  against  the  ISO  38200  standard  is 
necessarily aligned with the EUTR definition of legality and the definition of neg lig ibl e 
risk. 

887 

Not Covered 

Partially 
Covered 

 
 
 
 
 
 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

C.4.1.3  The  Scheme 
include 
shall 
requirements 
that 
ensure  that  the  above 
requirements are in line 
with the requirements of 
the  EUTR  to  prohibit 
illegal  material 
or 
material  with  a  non-
negligible risk categ o ry 
being placed on the EU 
market. 

the  Scheme 
C.4.1.4 
include 
shall 
requirements 
that 
ensure that the decision 
certify 
process 
to 
organisations, 
or 
maintain certification o f  
from 
CHs, 
conflict  of  interest  and 
includes  checks  and 
balances. 

free 

is 

ISO  38200:2018,  4  General 
requirements, a) 

Findings 

Scheme info 

ISO 38200:2018, 7 Due Dilige nce  
System 

ISO  38200  includes  a  due  diligence  system  in  line  with  the  EUTR  steps  on 
information required (information gathering), risk assessment  and mitigation. As t h e  
scheme is voluntary there are only requirements to cover the ma t e ri a l wi t hi n t h e  
scope of the CoC and DDS certified under ISO 38200.  

Justification 

The  categories  of  applicable  legislation  are  not  defined  in  the  document  as 
normative, and even though there is guiding material (Annex E and F), this ca n n o t  
guarantee  that  all  applicable  legislation  is  ide ntified  and  assessed  across  all 
countries.  

ISO 17065: 2012, 4.2 Management 
of impartiality;  4.2.8, 4.2.9 , 4.2.10  

Findings 

Scheme info 

ISO 17065: 2012, 5.2 Mechani sm  
for safeguarding impartiality; 5.2.1. 

ISO  17065:  2012,  8.6  Internal 
audits (A); 8.6.4  

ISO  17065:  2012,  Annex  A 
(informative) Principles for product  
certification  bodies  and 
their 
certification activities 
A.2 Impartiality 

ISO’s  Committee  on  Conformity  Assessment  (CASCO)  has  developed  several 
standards on conformity assessment to be used in a certification process, includin g 
ISO/IEC  17065  (Conformity  assessment  –  Requirements  for  bodies  certifying 
products, processes  and services). According to ISO 17065 there are mechanism in 
place to ensure impartiality during the decision process, and there are requirements 
in place for auditors not to evaluate their own work.  

However,  there  is  no  scheme  supporting  the  implementation of t he ISO 38200 
standard  and  it  is  voluntary  for  a  CB to comply with ISO 17065 when certifying 
against ISO 38200. 

Partially 
Covered 

Partially 
Covered 

Justification 

ISO 17065 has clear requirements on impartiality. 

However, ISO 38200 does not require accredited CBs to base their certification system 
on  ISO  17065.  There  is  no  requirement  for  an  oversight  mechanism that ensures 
impartiality  is  in  place.  It  is therefore not possible to conclude that the indicator is 
fulfilled without evaluating the applicable certification bodies system requirements.  

In cases  where the certification body is accredited by an accreditation body th a t b a se  
their  systems  on  the  ISO  17000  standards,  the requirements for impartiality in the 

888 

 
 
 
 
 
 
 
 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

decision-making process, as well as oversight mechanism will be in place. In that case, 
the indicator would be covered.  

However, it will have to be verified that the CB and the accreditation body is operat in g  
in conformance with ISO 17065:2012. Therefore, the indicator is considered  p a rt ia lly 
covered. 

889 

 
 
 
ANNEX 7 : INTERNATIONAL STANDARD ASSESSMENT REPORT – ISO 38200 

Annex 1. References 

 

ISO, 2016: How to write standards. Available at:  

https://www.iso.org/files/live/sites/isoorg/files/archive/pdf/en/how-to-write-
standards.pdf. Brochure, International Organization for Standardization.  

 

ISO webpage: 

o 
o 
o 
o 
o 

iso.org, N.Y(a): https://www.iso.org/about-us.html   
iso.org, N.Y(b): https://www.iso.org/members.html   
iso.org, N.Y(c): https://www.iso.org/structure.html  
iso.org, N.Y(d): https://www.iso.org/get-involved.html  
iso.org, N.Y(e): https://www.iso.org/who-develops-standards.html   

 

 

ISO Call-5/11/2020 - Representative Project Committee ISO/PC 287  

ISO email response-27/10/2020 – Representative Project Committee ISO/PC 287 

890 

 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Annex 8: Scheme Assessment  Report 
Bureau Veritas Origine et Légalité des Bois 
(OLB) 

891 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Table of Contents 

Executive summary ................................................................................................. 893 

Introduction............................................................................................................... 896 

Acronyms ................................................................................................................. 897 

1. Overview of Certification Scheme ................................................................... 898 

2. Report Structure ............................................................................................... 902 

2.1. Overview of the certification standards used for this analysis .................... 903 

3. Evaluation methodology................................................................................... 904 

4. Overview of findings ......................................................................................... 905 

5. Evaluation ......................................................................................................... 909 

A. Requirements for Certificate Holders  ............................................................. 909 

A.1a Legal Requirements at the forest level – FM STANDARD ....................... 909 

A.1b  Legal  Requirements at the forest level  – Non-Certified  input  - COC 
Standard Annex 1: Supplier Evaluation Program............................................... 929 

A.2a  Legal  requirements  for supply  chain entities  – COC Standard  (Main  text)
 .............................................................................................................................. 945 

A.2b  Legal  requirements  for supply  chain entities  – COC Standard  Annex  1: 
Supplier Evaluation Program ............................................................................... 952 

A.3 Requirements for material control ................................................................ 958 

A.4 General requirements for Certificate Holders  .............................................. 966 

A.5 Quality and procedural requirements for Certificate Holders ...................... 968 

B. Requirements for Certification Bodies ............................................................ 973 

B.1 General Certification Body requirements ..................................................... 973 

B.2 Certification Body requirements for auditing and certification  .................... 977 

C. Requirements for Certification Schemes ....................................................... 988 

C.1 Transparency................................................................................................. 988 

C.2 Scheme & standard scope............................................................................ 997 

C.3 Accreditation and oversight ........................................................................ 1000 

C.4 Certification process.................................................................................... 1009 

892 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Executive summary  

The objective of the Scheme Assessment Report of the BV OLB ( Origine de la Legalité 
des Bois) scheme is to create a resource of knowledge and reference for all interested 
and  concerned  parties  in  the  forest-  and  wood-based  products sector. It should help 
Competent Authorities, Operators and Monitoring Organisations covered by the EUT R in 
their understanding of potential benefits and shortcomings of certification, in particular in 
the context of the implementation of the EUTR.  

The  evaluation  has  been  made  using  the  indicators  of  the  Scheme  Assessment 
Framework (SAF), developed by Preferred by Nature in the context of the assessment of 
forestry certification schemes against the EU Timber Regulation (EUTR) requirements.  

The BV OLB (Origine et Légalité des Bois) verification scheme was developed in 2004 by 
Bureau  Veritas  Certification  (BV),  an  international  independent  certification  body 
headquartered in Paris, France. The OLB System is managed directly by BV and does not 
have external oversight or accreditation.  

The general purpose of the OLB certification is to certify that a forest is managed legal ly, 
the origin of forest products is controlled, and the transfer of certificate claims along the 
supply chain is ensured. Chain of custody certification aims to ensure that the certification 
claim is transferred along the value chain.  

The system is based on two main standards:  

–  a forest management (FM) standard for forest enterprises, and  

–  a chain of custody (CoC) standard for supply chain entities (processors and trade 

activity companies) 

Both the OLB FM and COC standards have been reviewed and updated b y BV and are at 
the final approval phase at the time of writing this report. These new versions have been 
used in this evaluation. 

Overall findings 

The  BV  OLB  scheme  is  assessed  to  be  a  comprehensive  scheme  that  covers  many 
critical parts of the EU Timber Regulation. Both the FM and the COC standard are aligned 
with the language and requirements of the EUTR. 

In total, out of the 84 indicators of the scheme assessment framework evaluated within the 
study, 55 were concluded as Covered, 15 as Partially Covered and 6 as Not Covered. 8 
indicators were concluded as Not Applicable.  

In  the  following  sections,  this  executive  summary  highlights  only  areas  of  significant 
strength in the scheme or areas where significant gaps or areas of lower coverage were 
identified. 

It  should  be  noted  that this report reflects an evaluation that has only considered the 
normative  and  guidance  documents  relevant  to  the  scheme.  Consideration  of impact 
studies  and  other  information  relating  to  the  performance  of  certification  schemes  in  
general, are included in a Meta-report which brings together findings in relation to all five 
schemes.  

Coverage by the scheme of legal requirements at the forest level  

The Forest Management (FM) standard is comprehensive and adapted at the country 
level. Most SAF indicators at the FM level are covered. Only “requirements to comply with 
legal obligations concerning benefit sharing” are not fully addressed.  

893 

 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

The Supplier Evaluation Program, used by companies implementing a credit system in 
their  chain  of  custody  management,  is  less  exhaustive  and  detailed  as  the  OLB  FM 
standard, and does not fully address the following areas:  

o 

It does not include requirements to control potential illegal activities by third parties 
within the area managed by the operation.  

o  Organisations are not required to have procedures in place to ensure absence of 
corrupt  practices  or  potential  misuse  of  salvaging  permits  or  other  specific 
ministerial permits, with the intention of circumventing harvest regulations.  

o  Protection of rare or endangered species, including their habitats and potential 

o 

o 

habitats is not explicitly included.  
It  is  not  specified  regulation  related  to  acceptable  levels  of  damage  and 
disturbance of soil resources, establishment of buffer zones.  
It is not required to check obligatory insurances, certificates of competence and 
other training requirements, and payment of social and income taxes.  

o  Legislation  against  discrimination  and  legislation  allowing  for  freedom  of 

association are not mentioned  

o  Requirements to comply with legal obligations concerning benefit sharing are not 

included. 

o  The terminology 'Free, Prior and Informed Consent' in connection with granting 

rights to forest management is not explicitly.  

o  There  are  not  specific  requirements  to  comply  with  legislation  regulating  how 
harvested  material  is  classified  in  terms  of  species,  quantities  and  qualities in 
connection with trade and transport.  
It is not detailed how to prove compliance with offshore trading and transfer pricing 
and other customs regulations. 

o 

This Supplier Verification Program is implemented by certificate holders themselves. Even 
though the OLB standard requires minimum documentation checks and onsite audits by 
qualified  (as  defined  by  the  own  company)  staff,  the  quality and robustness of these 
assessments  may  vary.  Also,  it  is  not  possible  from  the  claim  on  verified  material  to 
identify which material is from 100% certified areas and which include material from non -
verified sources. 

Coverage by the scheme of legal requirements at the supply chain level  

At  the  chain  of  custody  level,  the  robustness  of  the  OLB  system  may  be  potentially 
discredited  by  the  fact  that  the  COC  system  allows  –  like  other  forestry  certification 
systems –mixing OLB and non OLB inputs. Non OLB inputs may be:  

1)  certified  against  other  approved  or  acceptable  schemes (i.e., FSC, PEFC and 
PEFC-endorsed schemes, NEPCon LegalSource and BV DDS). In this case, we 
refer to the PEFC and FSC Scheme Assessment Reports.  

2)  not  certified,  but  evaluated  as  part  of  a  “Supplier  Evaluation  Program”.  The 
conclusions of the coverage of this program have been included in this evaluation. 
Note: this option is only allowed for companies implementing a credit system.  

Material control 

The Chain of Custody standard does not use a B2B volume reconciliation system, thus 
indicating a gap in the ability to track volumes through the supply chain.  

Another gap at the chain of custody level is the endorsement of inputs certified against 
other  certification  schemes  (FSC  and  some  PEFC  endorsed  schemes),  without 
performing a full assessment of the requirements of these certification systems compared 
to  the  EUTR.  This  may  represent  a  risk  that  BV  does  not  identify  potential  lack  of 
alignment.  

894 

 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Other requirements of the Certification scheme 

The owner and only certification body of the OLB scheme, Bureau Veritas (BV) is a well -
established independent certification body that requires their auditors a satisfactory level 
of competence, and has procedures in place to cover scheme rela ted indicators such as 
Conflict  resolution,  Corruption  ,  Certification  Body  requirements  for  auditing  and 
certification and Scheme & standard scope.  

Since the scheme does not include accreditation of other certification bodies, most of the 
indicators related to Accreditation and oversight are not applicable, but the lack of external 
oversight represents a weakness. BV has worked on internal procedures to fill this gap 
partly. 

895 

 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Introduction 

The  objective  of  the  Study is to create a resource of knowledge  and reference for all 
interested and concerned parties in the forest- and wood-based products sector. It should 
help  Competent  Authorities,  Operators  and  Monitoring  Organisations  covered  by  the 
EUTR  in  their  understanding  of  potential  benefits  and  shortcomings  of  certification 
schemes,  in  the  context  of  the  implementation  of the EUTR. As such, one part of the 
overall  objectives  is  to  create  an  overview  of  existing  certificates,  third -party  verified 
schemes and certifying bodies issuing certificates with regard to forests and wood -based 
products  and to evaluate their respective strengths and weaknesses in respect to the 
EUTR obligations. This should, in turn, encourage stronger standards and transparency of 
certification and third part verification schemes. 

It should be underlined that it is NOT the intention of the study to create a compliance 
checklist  of  certification  schemes.  The  EUTR  continues  to  recognise  third  party 
certification as an important potential tool for risk assessment and risk mitigation, bu t does 
not  recognise  certification  as  proof  of  compliance. This will not change based on this 
study. 

As part of the above objective, this framework has been developed to allow evaluation of 
the  differences  and  uniformities  between  certificates  and certifying bodies. It includes 
requirements  to  assess  to  which  degree different forest certification schemes provide 
assurance of low (negligible) risk of ‘legal non-compliance’ of certified material.  

The  Framework  aligns  with  the  definitions  and  approach  to  cert ification  schemes  as 
described within the EU Timber Regulation (No. 995/2010) and the associated Guidance 
Document,  along  with  additional  requirements  for  the  use  of  third  party  certification 
schemes as outlined in the Commission implementing Regulation (EU) No 607/2012 and 
specifically Article 4 in the Commission Implementing Regulation (EU) No 607/2012.  

The Scheme Assessment Framework has been developed by Preferred by Nature as a 
comprehensive  interpretation  of  the  EUTR  legality  definition  to  provide  the  abi lity  to 
evaluate in detail the different aspects of legality covered by the schemes included in this 
study.  

It  should  therefore  be  underlined  that  the  legality  definition  used  in  the  Assessment 
Framework is a comprehensive interpretation of the EUTR intended to expand on the five 
legality categories included in the Regulation.   

The Framework takes into account verifiers for Article 6 in the EUTR, and documentation 
for  Article  4  of  the  Implementing  Regulation,  as  well  as  a  wide  array  of sustainability 
standards and benchmarks used in the areas of forest and wood-based products, among 
other resources identified under References. 

The current report contains an evaluation of BV OLB. 

896 

 
 
 
 
  
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Acronyms 

ATFS:   

Australian Timber Forestry Standard (endorsed by PEFC) 

BV DDS:  

Bureau Veritas Due Diligence System 

BV:  

CB:  

Bureau Veritas 

Certification Body 

CERFLOR:   Certification Florestal (endorsed by PEFC) 

CERFOAR:   Certificacion Forestal Argentina (endorsed by PEFC) 

CERTFOR:   Certification Forestal (Chile) (endorsed by PEFC) 

CFCC:  

China Forest Certification Council (endorsed by PEFC) 

CH:  

Certificate Holder 

CITES:  

CoC:    

DDS:    

EUTR:  

FM:  

FPIC:    

FSC:    

IFCC:   

ILO:  

The  Convention  on  International  Trade  in  Endangered  Species of Wild 
Fauna and Flora 

Chain of Custody 

Due Diligence System 

EU Timber Regulation 

Forest Management 

Free, Prior and Informed Consent 

Forest Stewardship Council 

Indonesian Forestry Certification Cooperation (endorsed by PEFC)  

International Labour Organisation (BIT – Bureau International du travail) 

KoFPI :  

Korea Forest Certification Council (endorsed by PEFC) 

MTCC :  

Malaysian Timber Certification Council (endorsed by PEFC) 

NCCF :  

Network for Certification and Conservation of Forests (endorsed by PEFC)  

NZFCA:  

New Zealand Forest Certification Association (endorsed by PEFC) 

OIBT:   

OLB:   

PAFC:   

PEFC:   

Organisation internationale des bois tropicaux 

Origine  et  Légalité  des  Bois  (The  timber  legality  verification  system  of 
Bureau Veritas) 

Pan-African Forest Certification (endorsed by PEFC) 

The Programme for the Endorsement of Forest Certification Schemes 

SAFAS:  

South African Forestry Assurance Scheme (endorsed by PEFC)  

SFI:  

Sustainable Forestry Initiative (endorsed by PEFC) 

SGEC:  

PEFC Japan (endorsed by PEFC) 

897 

 
 
 
 
 
 
 
 
 
 
 
  
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

49.  Overview of Certification Scheme 

The BV OLB (Origine et Légalité des Bois) verification scheme was developed in 2004 
by Bureau Veritas Certification (BV), an international independent certification body listed 
on the Euronext Paris stock exchange. BV provides Testing, Inspection and Certification 
(TIC) services in a range of fields to help clients around the world meet quality, safety, 
environmental protection, and social responsibility requirements.  

The  Forestry  Department  of  Bureau  Veritas  Certification  France,  an  independent 
certification  organisation  and  a  subsidiary  of  Bureau  Veritas  Certification  Holding, 
developed  and  manages  the  OLB  system.  The  OLB  System  is  managed  directly  by 
Bureau Veritas (BV) and does not have external oversight or accreditation.  

The general purpose of the OLB certification is to certify that a forest is managed legally, 
the origin of forest products is controlled, and the transfer of certificate claims along the 
supply chain is ensured. Chain of custody certification aims to ensure that the certification 
claim is transferred along the value chain.  

The system is based on two main standards:  

–  a forest management (FM) standard for forest enterprises, and  
–  a chain of custody (CoC) standard for supply chain entities (processors and trade 

activity companies) 

For multi-site companies, there is an additional standard to cover specific requirements.  

Forest Management 

The version of the OLB FM standard currently implemented by fore st enterprises dates 
from 2010 (RF03 OLB EF Version 3.3). This version has gone through several revisions 
that have not been published to date. At the date of writing this report, the most recent 
review (v.3.4) is its final version before publishing, and it is expected to replace version 
3.3 sometime in 2021.  

The  findings  in  this  report  are  based  on  the  evaluation  of  version  3.4,  which  is  not 
operational yet. 

The  3.4.  version  has  been  coordinated  by  BV  Douala  and  has  gone  through  two 
stakeholder consultations in 2018. The main purpose of the revision is to be aligned with 
the  new  developments  in  the  forest  sector,  and  more  precisely  Due  Diligence 
requirements of regulations such as the EU Timber Regulation (EUTR).  

The criteria and indicators listed in the  standard are applicable to forests located in all 
geographies.  

Chain of Custody (COC) 

The version of the OLB COC standard currently implemented by Supply Chain entities 
dates from 2010 (RF03 OLB CdC v3.5). Companies that want to comply with additional 
requirements  related  to  social  and  environmental  aspects,  may implement the OLB + 
standard (RF03 OLB+ COC v1.0). As with the FM standard, the COC standard has been 
entirely reviewed and updated to be more aligned with recent developments in the forest 
sector, namely regulations such as the EUTR. At the date of writing this report, the most 
recent review (v.3.6) is its final version before publishing and it is expected to replace 
version 3.5 sometime in 2021. The requirements of OLB + are now incorporated in t he 
new version to come of the main COC standard. OLB+ will therefore disappear.  

The findings in this report are based on version 3.6, which is not operational yet.  

898 

 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

It should be noted that Bureau Veritas has developed their own Due Diligence System 
that may be implemented by companies that seek to fulfill the Due Diligence requirements 
of the EUTR. This is a different standard (BV DDS) and has not been evaluated in this 
assessment.  

I.  Verification of Legal Compliance at the Forest Level 

Forest Enterprises that seek to sell their products as OLB certified must comply with the 
requirements listed in the standard RF03 OLB EF Version 3.4, once adopted, which will 
be applicable also to subcontracted entities.  

Conformity with these requirements must be evaluated in the field.  

This standard cover traceability up to the first point of sale or primary processing. F orest 
enterprises may then sell their products as OLB certified (the claim OLB certified, and the 
company’s OLB certificate number are included on the sales invoices). 

II.  Verification of Legal Compliance at the Supply Chain Level 

Supply Chain entities that seek to sell their products as OLB certified must guarantee the 
chain of custody of the materials by complying with the requirements listed in the standard 
RF03 OLB CdC v3.6, once adopted.  

Supply Chain entities have  2 segregation options to guarantee the traceability of OLB 
products:  

1)  Physical separation: OLB certified inputs are separated from non-certified inputs 
throughout the process of transformation and/or commercialization. This is the 
recommended  option,  and  it  is  mandatory  for  trade  activity  companies  (i.e. 
companies that do not transform or process wood).  

There are three physical separation methods:  

  Separation in time 
  Separation in space 
 

Individual identification 

In a physical separation system, two kinds of inputs may be used:  

i.  OLB certified wood 

ii.  Wood certified against other recognised certification schemes (recognised 

certification schemes are listed in Annex 2). These are:  

  The Dutch Keurhout Legality and/ or Sustainability system 
  FSC 
  PEFC  –  Germany,  Australia,  Austria,  Belarus,  Belgium,  Czech 
Republic,  Denmark,  Spain,  Estonia,  Finland,  France,  Hungary, 
Ireland,  Italy,  Latvia,  Luxembourg, Norway, Netherlands, Poland, 
Portugal,  Romania,  Russia,  Slovakia,  Slovenia,  Sweden, 
Switzerland, UK, Uruguay  

  SFI – Canada - USA 
  ATFS - USA 
  MTCC – Malaysia  
  CERFOAR - Argentina 
  CERFLOR - Brazil 
  CERTFOR - Chile 
  CFCC - China 
  PAFC - Gabon 
  NCCF - India 

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ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

IFCC – Indonesia  

 
  SGEC - Japan 
  NZFCA – New Zealand  
  KoFPI – Republic of Korea  
  SAFAS – South Africa 

2) Credit System: It consists of ensuring an equivalence between the volume of 

OLB raw materials purchased and the volumes of OLB products sold. 

In this system, the organization can sell a proportion of the products with the OLB 
claim  equivalent  to  the  volumes  of  OLB  raw  materials  that  have  entered  the 
production.  OLB  entries  can  also  be  accumulated  as OLB credits on a credit 
account.  When  producing  OLB  product  lines,  OLB  wood  and  acceptable raw 
materials can be used. 

For example: A company buys 1,000 m3 of OLB wood in June and processes the 
raw material with a 50% conversion factor for the species concerned in the last 12 
months (July to June). The company can then sell the equivalent of 500 m3 of 
OLB finished products in July. 

In a credit system, four kinds of inputs can be used:  

i.  OLB certified wood 

ii.  Wood certified against other recognised certification schemes (recognised 

certification schemes are listed in Annex 2, see II.1.ii). 

iii.  Wood verified against other acceptable certification schemes (acceptable 

verification schemes are listed in Annex 2). These are:  

  Legalsource  
  BV DDS 

iv.  Wood coming from acceptable sources (as evaluated using the framework 
described  in  the  “Supplier  Evaluation  Program”  in  Annex 1 of the CoC 
standard) 

Inputs that do not fall under one of the four categories above cannot enter the OLB chain 
of custody system and must be kept separated. This is a major change compared to the 
previous version of the standard, where unacceptable sources could potentia lly enter the 
OLB supply chain. 

Only  OLB  certified  inputs  and  Wood  certified  against  other  recognised  certification 
systems (categories i. and ii. above) qualify as OLB credits.  

The outputs in all cases, regardless of the segregation system in place, are OLB certified 
products (the claim OLB and the company’s OLB certificate number are included on the 
sales invoices).  

There are no different claims to differentiate OLB products made from wood coming from 
an OLB certified forest compared to OLB products that have gone through a credit system 
and therefore may come from acceptable sources and not necessarily an OLB certifi ed 
forest. The robustness of the Supplier Evaluation Program is therefore a critical point in 
the credibility of the OLB chain of custody certification.  

III.  Supplier Evaluation Program 

The Supplier Evaluation Program is described in Annex 1 of the Chain of Cu stody 
standard  and  can  only  be  used  as  part  of  a  credit  system  to  qualify  inputs  as 
“acceptable” (do not qualify as OLB credits).  

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ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

It is based on the verification of a set of criteria to be assessed at the forest level. It is 
therefore required that the company implementing the Supplier Evaluation Program is 
close enough to the forest or that it can prove traceability from the intermediaries to 
the forest level.  

Only a list of criteria is provided in the standard, without clear indicators or guidance 
to ensure that it is consistently implemented by Certificate Holders and objectively 
evaluated by Bureau Veritas auditors.  

For  the  sake  of  this  assessment,  the  Supplier  Evaluation  Program  has  been 
evaluated and treated as a separate standard, both at the Forest Management level 
and at the supply chain level.   

OLB claims and labels 

The FM and COC standards include requirements to ensure that wood products sold 
as  OLB  certified  are  correctly  identified  as  such,  and  invoices  and  transport 
documentation  shall  be  clearly  linked  to  the  products  and  include,  among  other 
information,  “The  number  and  validity  period  of the OLB certificate” (as stated in 
section 5 of RF03 OLB EF Version 3.4 and 1.4 of RF03 OLB CoC v3.6_FR).  

At the chain of custody level, there are no different OLB claims to differentiate OLB 
outputs from a physical separation system or a credit system. 

Companies also have the possibility of using the OLB logo, in which case they must 
follow  the  rules  stated  in  the  documents  "OLB  Trademark  Use  Regulations "  and 
"GRAPHIC charter of the OLB Logo".  

For the use of the OLB trademarks, the conditions and rules are explained in the 
procedures document GP01 CdC OLB (sections 17, 18 and 19). 

OLB and BV trademark uses must be approved by Bureau Veritas Douala for pr ior 
approval. The accompanying invoices to products carrying the OLB or BV logo must 
include the species, quantity, OLB product type (product description) and certificate 
reference (e.g. OLB-CERT/FC-00000000). 

On  product  OLB  trademark  use  must  include  the  certificate  reference  and  the 
following statement (unless the timber product is marked directly through a stencil or 
by  paperwork):  “Origin  and  Legality  of  these  timber  products  are  certified  by  an 
independent organization, according to OLB standards”.  

Off  product  OLB  trademark use (i.e. promotional or commercial documents) must 
also  include  the  certificate  reference, in addition to the following statement: “This 
forestry  organization  received  certification  from  an  independent  certification 
organization,  according  to  OLB  standards,  which  guarantee  the  traceability  and 
legality of timber until their first processing (and so on)”. 

Other  specific  claims  can  be  authorised  by  Bureau  Veritas  Douala  for  specific 
trademark use.  

901 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

50.  Report Structure 

The structure of this report is based on the Scheme Assessment Report (SAR).  

To allow the evaluation of non-certified inputs entering the credit system of OLB COC 
certified companies (“Supplier Evaluation Program”), sections A1 and A2 of this report are 
split into two pieces: 

A.1a Legal Requirements at the forest level – Forest management certification 

A.1b  Legal  Requirements  at  the  forest  level  –  COC  Standard  Annex  1:  Supplier 
Evaluation Program 

A.2a Legal Requirements for supply chain entities – COC standard (main text) 

A.2b Legal Requirements for supply chain entities  – COC Standard Annex 1: Supplier 
Evaluation Program 

B. Requirements for Certification Bodies 

C. Requirements for certification schemes 

902 

 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

1.1 Overview  of  the  certification  standards  used  for  this 

analysis 

Type 

Norm ative 

Guidance 
  OLB  Certification  Standard  setting specific 

instruction Ref.: SI  OLB  standard setting 
Version: 1.0 

  OLB  certification process for Forestry 

Companies  - GP01  OLB FC  1.2 version, 22 
March 2013  (FR) 

General  

  OLB  certification process for Chain  of Custody 

GP01  CoC  Version 2.3 (EN) 

 

Specific Instructions OLB:  Chain  of Custody and 
Forestry Companies  Certification  process Ref.: 
SI  OLB process v10 [10 12 10]  

  Manuel  des Procédures  de Certification  OLB: 

PL-CAM-015 

 

Evaluation  Checklist  OLB  standard for Forestry 
Companies 

  DO  100902  Legislation  Chart 

  Checklist  OLB Chain  of Custody  Standard   

Forest 
Managem ent 

Chain of 
Custody 

  REFERENTIEL  A 
L'INTENTION  DES 
ENTREPRISES 
FORESTIERES  (Forest 
Management  Enterprises 
standard, in French) : 
Référentiel  RF03  OLB  EF 
Version 3.4 

 

SF03  OLB  FM  Documents 
légalité 

  REFERENTIEL  DE  CHAINE 

DE  CONTROLE  (Chain  of 
Custody standard, in  French) 
: Réf: RF03  OLB CdC  v3.6   

  Multisite  standard RF03  OLB 
Multi-site  v1, 10 December 
2010. RF03  OLB+  COC 
v1.0, September  2010 

903 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

51.  Evaluation methodology 

The scheme is evaluated against the Scheme Assessment Framework (SAF) by use of 
the  Scheme  Assessment Procedure (SAP) in order to assess how the scheme covers 
relevant requirements of the EUTR, and the criteria defined by the European Commission 
as the basis for this Study. 

For each indicator, we will have a conclusion that will show the level o f conformance of 
the Scheme with the indicator: 

Conclusion 

Definition 

Covered 

When  available  Scheme  requirements 
and information  - and any impacts 
evidence available  - indicate the 
coverage of the SAF indicator. 

When  available  Scheme  requirements 
and information  - and any impacts 
evidence available  - indicate only 
partial coverage of the SAF indicator.   

Partially Covered 

Alternatively,  special concerns about 
Scheme  standards, credibility,  rigor or 
coverage may  exist. 

NOTE:  It is important  to justify the 
partial  coverage, and indicate  w here 
the issues are w hich result in a 
Coverage  conclusion not being  given. 
When  available  Scheme  requirements 
and information  - and any impacts 
evidence available  - indicate that 
there is no coverage of the SAF 
indicator. 

NOTE:  It is important  to justify a no 
coverage conclusion. 
When,  for w hichever reason, the SAF 
indicator  does not apply.   

Not Covered 

Not Applicable 
(N/A) 

Explanation 
Coverage  is the ability  of the Scheme  to 
provide assurance that material  traded via the 
Scheme  has a low  (negligible)  risk of being 
illegally  harvested, traded in line w ith the 
legality  definition  of the EU  Timber  Regulation. 

Partial  Coverage  means  the Scheme  is only 
partly able – or may be compromised  in one or 
more  w ays – to provide assurance that material 
traded via the Scheme  has a low  (negligible) 
risk of being  illegally  harvested, traded in line 
w ith the legality  definition  of the EU  Timber 
Regulation.   

The  Scheme  is not  – or inadequately  – able to 
provide assurance that material  traded via the 
Scheme  has a low  (negligible)  risk of being 
illegally  harvested, traded in line w ith the 
legality  definition  of the EU  Timber  Regulation.   

904 

 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

52.  Overview of findings 

Requirement Section 
A. Requirements for Certificate 
Holders 
A.1 Legal Requirements at the 
forest lev el  
A.1.1 Rights to harvest timber 
within legally gazetted boundaries 

A.1.2 Payments for harvest rights 
and timber including duties 
related to timber harvesting 
A.1.3 Timber harvesting, including 
environmental and forest 
legislation including forest 
management and biodiversity 
conservation, where directly 
related to timber harvesting 

Conclusion  Summary 

Conclusion  Summary 

A – Forest management certification 

B – Input  from non-certified forests 

Partially 
covered 

Covered 

There is no specific requirement related to 
legally gazetted areas. 
The standard requires that the organisation 
has the official legal rights and valid 
authorisations for the management and 
harvesting of the forest management area but 
does not mention the requirement of having 
procedures to ensure the use of legal methods 
to obtain these. 
All indicators are covered 

Covered 

All indicators of this criterion are covered  

Partially 
Covered 

Partially 
covered 

Partially 
Covered 

Gaps identified in the following areas 
- Organisations are not required to have procedures in place to ensure absen ce 
of corrupt practices (part of indicator A.1b.1.1.2) 
- Organisations are not required to have procedures in place to ensure the use 
of legal methods to obtain official authorisations (part of indicator A.1b.1.2.1 ) 
- It is not explicitly mentioned that l egally required planning documents have 
been approved prior to implementation of forest harvesting activities (part of 
indicator A.1b.1.3.2) 

All indicators of this criterion are covered. There are no mention of land area 
taxes or sales taxes. (A.1b.2.1.1 and A.1b.2.2.2) 

The scheme does not include requirements to control potential illegal activities 
by third parties within the area managed by the operation (A.1b.3.1.2) 

In addition, there are gaps in the following areas: 
- There are no specific requirements to assess  the potential mis-use of 
salvaging permits or other specific ministerial permits, with the intention o f 
circumventing harvest regulations (part of indicator A.1b.3.1.1) 
-  Protection of rare or endangered species, including their habitats and 
potential habitats is not included (part of indicator A.1b.3.2.1) 
-Identification of protected areas is conducted according to the legal 
requirements is not required for non-mandatory forestry operation planning 
document (part of indicator A.1b.3.2.2) 
- It is not specified regulation related to acceptable levels of damage and 
disturbance of soil resources, establishment of buffer zones (part of indicator 
A.1b.3.3.1) 
- It is not required to check obligatory insurances, certificates of competence 
and other training requirements, and payment of social and income taxes (part 
of indicator A.1b.3.5.1) 
- Legislation against di scrimination and legislation allowing for freedom of 
association are not mentioned (part of indicator A.1b.3.5.2) 

905 

 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Requirement Section 
A.1.4 Third parties’ legal rights 
concerning use and tenure that 
are affected by timber harvesting 

Conclusion  Summary 
Partially 
Covered 

Requirements to comply with legal obligations 
concerning benefit sharing are not clearly 
defined (A.1a.4.1.2) 

Conclusion  Summary 
Partially 
Covered 

A.1.5 Trade and customs, in so 
far as  the forest sector is 
concerned 

Partially 
Covered 

There are no requirements ensuring that 
certificate holders implement a due diligence 
system, where applicable. (A.1.a.5.6.1). 

Partially 
Covered 

There are gaps in the following areas:  
- Requirements to comply with legal obligations concerning benefit sharing are 
not included (part of indicator A.1b.4.1.2) 
-  The terminology 'Free, Prior and Informed Consent' in connection with 
granting rights to forest management is not explicitly mentioned (part of 
indicator A.1b.4.2.1) 
- It is not required to prove respect the tenure rights of indigenous and tribal 
peoples to forest land as well as their right to FPIC (part of indicator A.1b.4.3.1) 
There are gaps in the following areas:  
- There are not specific requirements to comply with legislation regulating how 
harvested material is classified in terms of species, quantities and  qualities in 
connection with trade and transport (part of indicator A.1b.5.1.1) 
- It is not detailed how to prove compliance with offshore trading and transfer 
pricing (part of indicator A.1b.5.3.1) 
- It is not detailed how to prove compliance with custom s regulations (part of 
indicator A.1b.5.4.1) 
- There are no requirements ensuring that certificate holders implement a due 
diligence system, where applicable (A.1.b.5.6.1) 

A.2 Legal requirements for 
supply chain entities  
A.2.1. Legal registration 

Covered 

All indicators of this criterion are covered 

Covered 

All indicators of this criterion are covered 

A.2.2 Taxes and fees 

Covered 

All indicators of this criterion are covered 

Covered 

All indicators of this criterion are covered 

A.2.3 Trade and transport 

Partially 
Covered 

It is not detailed the requirement of having 
import/export licenses, or product classification 
related to customs (A.2a.3.4.1). 

Partially 
Covered 

CITES specific requirements for OLB inputs 
are not included in the chain of custody 
standard (A.2a.3.5.1). 

Requirements for COC companies to comply 
with declaration obligations in the context of a 
Due Diligence/Due Care legislation are not 
included (A.2a.3.6.1). 

906 

Offshore trading and transfer pricing is not included in the Supplier Evaluation 
Program. 

In addition, there are gaps in the following areas: 
- There are not specific requirements to comply with legislation regulating how 
harvested material is classified in terms of species, quantities and qualities in 
connection with trade and transport (part of indicator A.2b.3.1.1) 
- It is not detailed how to prove compliance with offshore trading and transfer 
pricing (indicator A.2b.3.3.1) 
- It is not detailed how to prove compliance with customs regulations (part of 
indicator A.2.3.4.1)  

 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Requirement Section 
A.3 Requirements for 
material control 
A.3.1 Material  control 

A.3.2 Recycled  material 
A.4 General requirements 
for Certificate Holders 
A.4.1 Conflict  resolution 

Conclusion  Summary 

Partially 
covered 

Even  though OLB  does include  a CoC  system, it does not include  any B2B  volume  control or reconciliation,  w hich is considered a 
gap in terms of securing volume  control along  the supply chain (A.3.1.1.4) 

Not  covered 

OLB  does not include  any mention  of recycled or reclaimed  material 

Partially 
covered 

There  is no requirement  to excluded areas w here tenure is disputed (point ii). 

A.4.2 Corruption 

Covered 

All indicators of this criterion are covered 

A.5 Quality and procedural 
requirements for Certificate 
Holders 
A.5.1 Internal  procedures for 
Certificate  Holders 
A.5.2 Qualification  and 
competence 
A.5.3 Risk  based approaches 
to sourcing, trade or 
production 
B. 
Certification Bodies 
B.1 General  Certification  Body 
requirements 
B.2 Certification  Body 
requirements  for auditing  and 
certification 

Requirements for 

Partially 
covered 
Covered 

Partially 
Covered 

The  Scheme  does not include  requirements  for the Certificate  Holders to regularly review  the  proper functioning  of their ow n 
procedures (A.5.1.2) 

There  are not clear indicators and/or guidance  to recognised material  certified under other certification schemes.  (A.5.3.3). 

Covered 

All applicable  indicators  of this criterion are covered 

Partially 
covered 

It is required that the organisation  is not involved  in controversial activities  or practices that may impair  its legal  integrity.  But it does 
not directly require auditors to evaluate  if companies  have been sanctioned or otherw ise involved in corrupt practices (B.2.2.1) 

907 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Requirement Section 
C. 
Certification Schemes 
C.1  Transparency 

Requirements for 

Partially 
covered 

C.2  Scheme  & standard scope  Covered 
Partially 
C.3  Accreditation and 
covered 
oversight 

C.4  Certification  process 

Partially 
covered 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Conclusion  Summary 

There  are gaps in the follow ing areas:  
- The procedure explaining  various w ays in w hich stakeholders  can engage  is not freely available  (C.1.1.2) 
- A public version of the FM  report is available,  but only upon request (not directly available  on the internet).  COC  reports are not 
publicly  available  (C.1.1.4). 
All applicable  indicators  of this criterion are covered 
Requirements  for non-conformities  are structured in a w ay that there is a potential  risk that a non-conformity  may represent an 
infringement  of legislation  and that, as a result, illegal  w ood may enter the EU  market  w ithout mitigation  measures to prevent this 
from occurring for a period of up to 3 or 12 months  (C.3.2.2). 

OLB  does not apply independent  accreditation  and oversight (C.3.2.3). 

Requirements  for non-conformities  are structured in a w ay that there is a potential  risk that a non-conformity  may represent an 
infringement  of legislation  and that, as a result, illegal  w ood may enter the EU  market  w ithout mitigation  measures to prevent this 
from occurring for a period of up to 3 or 12 months  (C.4.1.2). 

Non  OLB sources used in the credit system go through a Supplier  Verification Program  less comprehensive  than the OLB FM 
standard and is implemented  by the certificate holders themselves  (C.4.1.3) 

908 

 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

53.  Evaluation 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A. Requirements for Certificate Holders 

Requirem ents applicable to the Certificate Holders. These include requirements to com ply w ith applicable legislation, as w ell as requirem ents relevant to ensuring 
continued performance and integrity of the operations – as far as is related to legal com pliance. 

A.1a Legal Requirements at the forest level – FM STANDARD 

This principle  relates to how  the scheme  ensures that Certificate  Holders  comply w ith all  applicable  legislation.  This section relates to requirements  of the Scheme  that applies  to 
Certificate  Holders  - or other entities  subject to the normative  requirements  of the Scheme  (e.g. included  w ithin the scope of a certified due diligence  system) - w ithin the Country of 
Harvest. 

A.1a.1.1 

A.1a.1 Rights to harvest tim ber 
w ithin legally gazetted 
boundaries  
Land tenure 
and 
management 
rights 

A.1a.1.1.1. The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
covering land 
tenure rights, 
including customary 
rights as  well as 
management rights.  

RF03 OLB EF Version 3.4 

L'entreprise doit démontrer le respect des lois nationales, 

1.2 - 
des règlements d'application et autres exigences administratives 
concernant les opérations forestières. 

1.2.1 - 
exploitée est légalement classée comme forêt exploitable* 

L'entreprise doit fournir la preuve que la zone forestière 

Note : 
accepté (si l'entreprise apporte les justificatifs nécessaires). 

un processus  de classement administratif en cours peut être 

L’entreprise détient les droits légaux et les autorisations 

1.2.2 - 
officielles et valides pour la gestion et l’exploitation des surfaces 
forestières évaluées. 

1.3 : L'entreprise doit démontrer le respect des lois nationales, des 

909 

Findings 

Scheme info 

Covered 

The standard requires that national legislation and 
other administrative requirements be respected 
and requires proof that the forest area is legally 
classified as exploitable at that the FME has the 
rights to manage and harvest the forest 
management area.  

Section 1.3 (1.3.4-1.3.7) lists the requirements 
related to the respect of national legislation and 
other administrative requirements related social 
aspects (communities impacted by forest 

 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1a.1.1.2. The 
Scheme shall 
include 
requirements to 
ensure that 
licenses, right of 
tenure and 
management rights, 
have been issued: 

i)  according to the 
legally prescribed 
procedure, 

ii) in compliance 
with third parties' 
legal rights 
concerning tenure, 

iii) specifying the 
legally-gazetted 
boundaries, and; 

iv) with absence of 
corrupt practices. 

A.1a.1.2.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 

A.1a.1.2  Concession 

licenses 

règlements d'application et autres exigences administratives 
concernant les aspects sociaux. 

Exigences relatives aux communautés concernées par les activités 
forestières (1.3.4-1.3.7) 

RF03 OLB EF Version 3.4 

L’entreprise détient les droits légaux et les autorisations 

1.2.2 - 
officielles et valides pour la gestion et l’exploitation des surfaces 
forestières évaluées. 

4.3.2: -  Concernant les enregistrements relatifs à la légalité, les 
documents officiels ont été obtenus des autorités compétentes de 
façon transparente. 

management activities). 

Justification 

Based on the above, this indicator is covered by the 
standard. 

Findings 

Scheme info 

Partially 
Covered 

The standard requires that legal rights and 
authorisations be “official and valid”. 

In addition, in section 4 -Fonctionnement du 
système, it is required that: “official documents 
have been obtained from the competent 
authorities in a transparent manner”. 

There is no specific requirement related to legally 
gazetted areas. 

Justification 

Based on the above, this indicator is partially 
covered by the standard. 

RF03 OLB EF Version 3.4 

Findings 

Scheme info 

Partially 
Covered 

1.2.2 - 
officielles et valides pour la gestion et l’exploitation des surfaces 

L’entreprise détient les droits légaux et les autorisations 

The standard requires that the organisation has 
the official legal rights and valid authorisations for 

910 

 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

regulating 
procedures for the 
issuing of 
concession 
licenses, including 
use of legal 
methods to obtain 
concession licenses 
and that licenses 
are covering only 
legally gazetted 
areas 

A.1a.1.3.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation and 
legal obligations for 
management 
planning, including 
conducting forest 
inventories, having 
a forest 
management plan 
and related 
planning and 
monitoring. 

A.1a.1.3  Management 

and harvesting 
planning 

forestières évaluées. 

RF03 OLB EF Version 3.4 

L'entreprise doit élaborer et mettre en œuvre un document de 

1.2.3 - 
planification des opérations forestières ou d'un plan 
d'aménagement/gestion forestier si celui -ci est requis par la 
réglementation locale*: 

Ce document doit décrire les coupes prévues et leur 

i. 
emplacement, les volumes de bois prélevés, le diamètre minimum 
d'exploitation (si applicable) et les essences prélevées. 

the management and harvesting of the forest 
management area but does not mention the 
requirement of having procedures to ensure the 
use of legal methods to obtain these.  

Direct interviews/ discussions / Stakeholder input 

In reaction to the original conclusion ‘partially 
covered” and the justification “Part of the indicator 
is not met: Organisations are not required to have 
procedures in place to ensure the use of legal 
methods to obtain official authorisations.”, BV 
points out:  
1.1.4. in the OLB EF standard states: “The 
company is not involved in controversial activities 
or practices that may impair its legal integrity”. 

Justification 

BV’s input has been taken into consideration and 
based on the above this indicator is partially covered.   

Findings 

Scheme info 

Covered 

Indicators 1.2.3, 1.2.4 and 1.2.5 list the 
requirements for organisations to comply with 
legislation and legal obligations for management 
planning, including conducting forest inventories, 
having a forest management plan and related 
planning and monitoring. 

ii. 
clairement les zones d'exploitation et les volumes prévus par coupe. 

Ce document doit définir un plan de coupe annuel qui décrit 

Justification 

iii. 
existent), et les travaux d'inventaires sont validés par l'autorité 

Les normes d'inventaires forestiers sont respectées (si elles 

Based on the above, this indicator is covered by 
the standard. 

911 

 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

compétente le cas échéant 

iv. 
réglementation locale, il doit être approuvé par l'autorité compétente. 

Si un plan d'aménagement/gestion est requis par la 

1.2.4 - 
surfaces  forestières évaluées*: 

L'entreprise démontre qu'elle maitrise les limites des 

i. 
L'entreprise doit matérialiser et entretenir sur le terrain et de 
façon non provisoire les limites des surfaces forestières évaluées et les 
limites de la zone forestière en cours d'exploitation.  

Note : Dans  le cas des grands périmètres, un programme d’évaluation 
des risques et de planification de matérialisation et entretien des 
limites pourra être accepté 

ii. 
respectées. 

Les limites de la zone d'exploitation autorisées sont 

1.2.5 - 
Les prescriptions d'exploitation forestière réglementaires et/ou 
préconisées dans le document de planification des opérations forestières 
ou dans le plan d'aménagement/ gestion sont respectées: 

planification des coupes,  
volumes autorisés,  
diamètres minimum,  
essences  autorisées,  
méthodes d'exploitation,  
modalités de marquage,  
utilisation de documents de déclaration et de suivi obligatoires,  
les essences  protégées ne sont pas récoltées, 
les attributs des sites dédiés à la protection (sites protégés*) 

i. 
ii. 
iii. 
iv. 
v. 
vi. 
vii. 
viii. 
ix. 
et/ou la conservation sont respectés, 
x. 

Autres* 

912 

 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1a.1.3.2 The 
Scheme shall 
include 
requirements that 
all legally required 
planning documents 
have been 
approved prior to 
implementation of 
forest harvesting 
activities. 

RF03  OLB EF  Version 3.4 

1.2.1 

L'entreprise doit fournir la preuve que la zone forestière 
exploitée est légalement classée comme forêt exploitable* 

Note : 
accepté (si l'entreprise apporte les justificatifs nécessaires). 

un processus de classement administratif en cours peut être 

1.2.2 

1.2.3 

L’entreprise détient les droits légaux et les autorisations 
officielles et valides pour la gestion et l’exploitation des surfaces 
forestières évaluées. 

L'entreprise doit élaborer et mettre en œuvre un document de 
planification des opérations forestières ou d'un plan 
d'aménagement/gestion forestier si celui -ci est requis par la 
réglementation locale*: 

Findings 

Scheme info 

Covered 

It is not explicitly mentioned that “[…] have been 
approved prior to implementation of forest 
harvesting activities”. 

Direct interviews/ discussions / Stakeholder input 

In reaction to the original conclusion ‘partially 
covered” and the justification “Part of the indicator 
is not met: it is not explicitly required that planning 
documents have been approved prior to 
implementation of forest harvesting activities”, BV 
points out:  
“Not that level of precision. But verification done in 
situ because it is a matter of respecting the 
regulations of the country in which the activity is 
carried out”. 
OLB EF v3.3. The company holds the official and 
valid permits necessary for the exploitation of the 
forest areas assessed. 

Justification 

BV’s input has been taken into consideration and 
based on the above this indicator is covered.   

A.1a.1.4  Harvesting 

permits 

A.1a.1.4.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
regulating the 
issuing of 
harvesting permits, 
licenses or other 

RF03 OLB EF Version 3.4 

L’entreprise détient les droits légaux et les autorisations 

1.2.2 - 
officielles et valides pour la gestion et l’exploitation des surfaces 
forestières évaluées. 

Système documenté 
L'entreprise doit établir et mettre en œuvre un système 

4.2 - 
4.2.1 - 
documenté permettant de répondre aux exigences du présent 
référentiel. 

Findings 

Scheme info 

Covered 

Section 4 of the standard requires organisations to 
designate a competent responsible person in 
charge of the implementation of the standard, as 
well as written procedures.  

“[…]The company must define and implement a 

913 

 
 
 
 
 
 
 
 
 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

legal documents 
required for specific 
harvesting 
operations. 

L'entreprise doit définir et mettre en œuvre une procédure de 

aux droits fonciers et aux droits d'usage à long terme de la 

4.2.2 - 
veille légale permettant de recenser et de disposer de l'ensemble des 
textes de lois nationaux et internationaux relatifs : 
i. 
terre et des ressources  forestières sur la zone exploitée ; 
ii. 
iii. 
iv. 
Note: 
d’un registre faisant référence à l’ensemble des textes ci -dessus 
4.2.3 - 
pertinentes vis-à-vis des activités effectuées auprès des responsables 
chargés d’assurer  le fonctionnement du système et le respect des 
exigences du référentiel 

à la gestion / aménagement et à l'exploitation forestière; 
au travail, à la santé, à la sécurité des travailleurs ; 
à la gestion de l'environnement. 
L’entreprise doit conserver une copie des textes, et disposer 

L’entreprise assure la diffusion des informations légales 

legal watch procedure making it possible to 
identify and have access to all the national and 
international laws relating to: 

i. land rights and long-term use rights to land and 
forest resources in the harvested area; 

ii. forest management / development and 
harvesting; 

iii. at work, health and safety of workers; 

iv. environmental management.” 

Justification 

Based on the above, this indicator is covered by the 
standard.  

A.1a.2 Paym ents for harvest 
rights and tim ber including 
duties related to tim ber 
harvesting 

A.1a.2.1  Payment of 

royalties and 
harvesting fees 

A.1a.2.1.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
covering payment of 
all legally required 
forest harvesting-
specific fees such 
as royalties, 
stumpage fees and 
other volume-based 
fees, as  well as land 
area taxes or fees. 

RF03 OLB EF Version 3.4 

L’entité forestière est en règle vis-à-vis de ses obligations 

1.1.3 - 
fiscales de droit commun applicables, ainsi que de ses obligations 
fiscales et taxes liées à son (ses)  activité(s) forestières (Patente, TVA, 
taxes et redevance liées à la récolte du bois, au volume, au transport 
et à la commercialisation du bois, …)   

Findings 

Scheme info 

Covered 

Standard requires organisations to be in 
compliance with all their fiscal obligations, 
including fees related to their forest harvesting 
activities.  

Justification 

Based on the above, this indicator is covered by 
the standard. 

914 

 
 
 
 
 
 
 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1a.2.2  Value-added 

taxes and other 
sales taxes 

A.1a.2.2.2 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
covering different 
types of sales taxes 
that apply to the 
material being sold, 
including selling 
material as growing 
forest (standing 
stock  sales). 

RF03 OLB EF Version 3.4 

L’entité forestière est en règle vis-à-vis de ses obligations 

1.1.3 - 
fiscales de droit commun applicables, ainsi que de ses obligations 
fiscales et taxes liées à son (ses)  activité(s) forestières (Patente, TVA, 
taxes et redevance liées à la récolte du bois, au volume, au transport 
et à la commercialisation du bois, …)   

Les preuves documentées de la conformité avec les 

5.3 - 
L’entreprise doit prouver sa conformité avec toutes les lois 
nationales et internationales applicables relatives au transport et à la 
commercialisation du bois 
5.3.1 - 
prescriptions légales du pays d'origine du bois en matière de transport 
et de commerce sont disponible (documents légaux de transport, 
déclaration en douanes, payement des droits de douanes, etc.). 
5.3.2 - 
L’entreprise détient l es preuves documentées de sa 
conformité à la réglementation applicable du commerce offshore et les 
tarifs et taxes y afférents si applicable. 

Findings 

Scheme info 

Covered 

Standard requires organisations to be in 
compliance with all their fiscal obligations, 
including taxes related to wood harvesting and 
commercialisation of timber. 

Justification 

Based on the above, this indicator is covered by 
the standard. 

A.1a.3.1 

A.1.3 Tim ber harvesting, 
including environm ental and 
forest legislation including 
forest m anagement and 
biodiversity conservation, 
w here directly related to tim ber 
harvesting 
Timber 
harvesting 
regulations 

A.1a.3.1.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legal 
obligations for 
harvesting 
techniques and 
technology 
including timing of 

RF03 OLB CoC v3.6_FR - Annex 1 : Supplier Evaluation Program  

Findings 

Covered 

Le fournisseur doit élaborer et mettre en œuvre un document 

Si la réglementation locale l’exige, le plan d'aménagement 

- 
de planification de ses opérations forestières ou un plan 
d'aménagement forestier (lorsque la réglementation locale l'exige); 
- 
forestier doit être approuvé par l'autorité compétente; 
- 
volumes autorisés, diamètres minimum, essences exploitables, 
marquage réglementaire, utilisation des documents légaux 
d’enregistrement de la récolte et de transport obligatoires, les 

Les prescriptions en matière d'exploitation sont respectées : 

Scheme info 

Suppliers (Forest Management Enterprises) must 
develop and implement a forestry operations 
planning document or an approved (by the 
competent authority) forest management plan 
when required by the law.  

Operating requirements are respected: permitted 
volumes, minimum diameters, exploitable species, 

915 

 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

harvest, selective 
cutting, shelter 
wood regeneration, 
clear felling, 
transport of timber 
from felling sites 
and seasonal 
limitations etc. 

This includes the 
mis-use of 
salvaging permits or 
other specific 
ministerial permits, 
with the intention of 
circumventing 
harvest regulations 

A.1a.3.1.2 The 
Scheme shall 
include 
requirements to 
control potential 
illegal activities by 
third parties within 
the area managed 
by the operation. 

essences  protégées ne sont pas récoltées ; 

regulatory marking, use of legal harvest 
registration and transport documents, protected 
species are not harvested; 

Justification 

Based on the above, this indicator is covered by 
the standard. 

RF03 OLB EF Version 3.4 

Section 2 : Contrôle des activités illégales 

Findings 

Scheme info 

Covered 

L'entreprise doit avoir défini et documenté les moyens 

2.1 - 
nécessaires et les actions mises en œuvre pour s'affranchir de toute 
coupe de bois illégale et les autres activités illégales sur la zone 
d'exploitation considérée, réalisée par des tiers externes à l'entreprise  

Section 2 of the standard includes the 
requirements to control potential illegal activities 
by third parties within the area managed by the 
operation. 

2.1.1 -  Une stratégie de lutte contre les coupes illégales de bois et 
toutes autres activités illégales sur la zone forestière évaluée est 
définie et actualisée autant que nécessaire pour besoin d’efficacité  

Justification 

Based on the above, this indicator is covered by 
the standard. 

2.1.2 - 
La stratégie de lutte contre les coupes illégales de bois de 
l’entreprise et toutes autres activités illégales est mise en œuvre. Au 
minimum :   
i. Une signalisation est présente sur les voies d'accès, précisant que 
toute activité illégale (exploitation non autorisée, braconnage…) est 
interdite 
ii. Les principales voies d'accès sont identifiées et contrôlées 
iii. Une surveillance des limites est effectuée, adaptée en fonction du 

916 

 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1a.3.2  Protected sites 

and species 

A.1a.3.2.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
related to protected 
areas as well as 
protected, rare, or 
endangered 
species, including 
their habitats and 
potential habitats. 

Findings 

Scheme info 

Covered 

Organisations must develop and implement a 
forestry operations planning document (or forest 
management plan, if required by local regulation) 
that ensures that protected species are not 
harvested and that protected sites or sites 
destined to conservation are respected.  

In addition, requirements form internal treaties 
such as CITES, BIT and OIBT conventions and 
Biodiversity Convention must be respected.  

Justification 

Based on the above, this indicator is covered by 
the standard. 

niveau de risque des activités d'exploitation illégale. 

RF03 OLB EF Version 3.4 

L'entreprise doit élaborer et mettre en œuvre un document 

1.2.3 - 
de planification des opérations forestières ou d'un plan 
d'aménagement/gestion forestier si celui -ci est requis par la 
réglementation locale*: 

i. 

ii. 

iii. 

iv. 

Ce document doit décrire les coupes prévues et leur 
emplacement, les volumes de bois prélevés, le 
diamètre minimum d'exploitation (si applicable) et les 
essences  prélevées. 

Ce document doit définir un plan de coupe annuel qui 
décrit clairement les zones d'exploitation et les volumes 
prévus par coupe. 
Les normes d'inventaires forestiers sont respectées (si 
elles existent), et les travaux d'inventaires sont validés 
par l'autorité compétente le cas échéant 

Si un plan d'aménagement/gestion est requis par la 
réglementation locale, il doit être approuvé par l'autorité 
compétente. 

1.2.5 - 
Les prescriptions d'exploitation forestière réglementaires 
et/ou préconisées dans le document de planification des opérations 
forestières ou dans le plan d'aménagement/ gestion sont respectées : 
i. 
ii. 
iii. 
iv. 
v. 
vi. 
vii. 
obligatoires,  

planification des coupes,  
volumes autorisés,  
diamètres minimum,  
essences  autorisées,  
méthodes d'exploitation,  
modalités de marquage,  
utilisation de documents de déclaration et de suivi 

917 

 
 
 
 
 
 
 
 
 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

les essences  protégées ne sont pas récoltées,
les attributs des sites dédiés à la protection (sites protégés*) 

viii.
ix.
et/ou la conservation sont respectés,
x.

Autres*

A.1a.3.2.2
Requirements that
ensure compliance
with legislation
related to protected 
areas and habitats,
shall include that 
the identification of
protected areas is 
conducted
according to the
legal requirements.

L'entreprise doit démontrer le respect des lois nationales, 

1.4 - 
des règlements d'application et autres exigences administratives 
concernant les aspects environnementaux. 

Les exigences des traités internationaux tels que CITES, les 

1.5 - 
conventions du BIT et de l'OIBT, et la convention sur la diversité 
biologique doivent être respectées* 
Note: Les conventions de l’OIT qui ont un impact sur les opérations et 
pratiques forestières sont les suivantes: 29, 87, 97, 98, 100, 105, 111, 
131, 138, 141, 142, 143, 155, 169, 182 et les Directives du BIT sur la 
santé et la sécurité en milieu forestier. 

RF03 OLB EF Version 3.4 

L'entreprise doit démontrer le respect des lois nationales, 

1.2 - 
des règlements d'application et autres exigences administratives 
concernant les opérations forestières. 
1.2.1 - 
exploitée est légalement classée comme forêt exploitable* 

L'entreprise doit fournir la preuve que la zone forestière 

1.2.5 - 
Les prescriptions d'exploitation forestière réglementaires 
et/ou préconisées dans le document de planification des opérations 
forestières ou dans le plan d'aménagement/ gestion sont respectées : 
i.
ii.
iii.
iv.
v.
vi.
vii.
obligatoires,
viii.
ix.
et/ou la conservation sont respectés,

planification des coupes,
volumes autorisés,
diamètres minimum,
essences  autorisées,
méthodes d'exploitation,
modalités de marquage, 
utilisation de documents de déclaration et de suivi

les essences  protégées ne sont pas récoltées,
les attributs des sites dédiés à la protection (sites protégés*) 

918 

Findings 

Scheme info 

Covered 

The organisation shall prove that the harvesting 
area is classified as “exploitable”.  

The (mandatory) forestry operati ons planning 
document (or forest management plan, if required 
by local regulation) shall include, among other 
requirement, the respect of protected sites or 
areas destined to conservation.  

Justification 

Based on the above, this indicator is covered by 
the standard. 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

x. 

Autres* 

A.1a.3.3  Environmental 

requirements 

A.1a.3.3.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
related to 
environmental 
impact assessment 
in connection with 
harvesting, 
acceptable levels of 
damage and 
disturbance of soil 
resources, 
establishment of 
buffer zones (e.g. 
along watercourses, 
open areas, 
breeding sites), 
maintenance of 
retained trees on 
felling sites, 
seasonal limitations 
on harvesting, and 
environmental 
requirements for 
forest machinery. 

RF03 OLB EF Version 3.4 

Section 1.4 - 
nationales, des règlements d'application et autres exigences 
administratives concernant les aspects environnementaux. 

L'entreprise doit démontrer le respect des lois 

L'entreprise a réalisé une étude d'impact environnemental en 

1.4.1 - 
fonction de l’échelle, de l’intensité et du risque des opérations 
d’aménagement et d’exploitation forestière et de la sensibilité de 
l’environnement.  Elle a valorisé les résultats de cette étude par un 
programme opérationnel. 

Findings 

Scheme info 

Covered 

Organisations are required to demonstrate 
compliance with all regulation concerning 
environmental aspects (i.e. water, air, soil, 
biodiversity, energy, noise, when applicable).  

In addition, the organisation must develop an 
environmental impact assessment and take its 
results into account via an operational program.  

L'entreprise respecte toutes les exigences 

1.4.2 - 
environnementales réglementaires concernant l'eau, l'air, le sol, la 
biodiversité, l'énergie, le bruit, quand cela est applicable.  

Justification 

Based on the above, this indicator is covered by 
the standard. 

1.4.6 - 
appropriée.* 

Les hydrocarbures utilisés sont traités de manière 

Les déchets générés lors des opérations de gestion 

1.4.7 - 
forestières (y  compris les déchets domestiques sur les bases  vies) 
sont traités de manière appropriée.* 

1.4.8 - 
Les dispositions et recommandations relatives à 
l'environnement qui figurent dans le plan d'aménagement approuvé et 
dans l’étude d’impact sont appliquées.* 

919 

 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1a.3.4  Health and 

safety 

A.1a.3.4.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with Health & Safety 
legislation. 

RF03 OLB EF Version 3.4 

L’entreprise dispose d’une politique de sécurité et de santé 

1.3.2 - 
au travail en conformité avec les exigences légales et réglementaire et 
clairement établie en concertation avec les travailleurs. 

Note: l’entreprise doit être en conformité avec les recommandations du 
BIT sur la santé et la sécurité du travail forestier. 

Les travailleurs présents sur  les chantiers forestiers isolés 

1.3.3 - 
bénéficient de conditions de vie décentes (et selon les réglementations 
en vigueur si elles existent)*: 

Findings 

Scheme info 

Covered 

The organisation must have a Health and Safety in 
the workplace policy, aligned with the legal and 
regulatory requirements.  

The organisation must respect the internal 
conventions and treaties adhered by the country.  

Justification 

1.5.2 - 
internationaux dont le pays est signataire. 

L'entreprise respecte les conventions et traités 

Based on the above, this indicator is covered by 
the standard. 

A.1a.3.5 

Legal 
employment 

A.1a.3.5.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation for 
employment of 
personnel involved 
in harvesting (and 
in-forest 
processing) 
activities including 
but not limited to 
requirements for: 
contracts and 
working permits, 
obligatory 
insurances, 
certificates of 

Note: Les conventions de l’OIT qui ont un impact sur les opérations et 
pratiques forestières sont les suivantes: 29, 87, 97, 98, 100, 105, 111, 
131, 138, 141, 142, 143, 155, 169, 182 et les Directives du BIT sur la 
santé et la sécurité en milieu forestier. 
RF03 OLB EF Version 3.4 

L'entreprise doit démontrer le respect des lois nationales, 

1.3 - 
des règlements d'application et autres exigences administratives 
concernant les aspects sociaux. 

Exigences relatives aux travailleurs : 

1.3.1 - 
relatives à l'embauche et au travail, dont les exigences suivantes*: 

L'entreprise respecte les lois et réglementations essentielles 

Les travailleurs embauchés disposent de documents 

i. 
formalisés et conformes à la réglementation en vigueur prouvant leur 
lien avec l'entreprise et en relation avec le travail fourni. 
ii. 
convenues (respectant les salaires minimums en vigueur). 
iii. 
négocier leurs conditions d'embauche selon les conventions 87 et 98 
du Bureau International du Travail. 

Les travailleurs doivent être libres de s'organiser et de 

Les travailleurs sont déclarés et reçoivent les rémunérations 

920 

Findings 

Scheme info 

Covered 

The organisation must respect national laws and 
other regulatory and administrative requirements 
regarding social aspects.  

Indicator 1.3.1 lists the requirements related to 
legal employment. This is also applicable to 
subcontractors.  

The obligation to have obligatory insurances, 
certificates of competence and other training 
requirements, and payment of social and income 
taxes is not included.  

 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

competence and 
other training 
requirements, and 
payment of social 
and income taxes.  

A.1a.3.5.2 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation for 
minimum working 
age and minimum 
age for personnel 
involved in 
hazardous work, 
legislation against 
forced and 
compulsory labour, 
and discrimination 

Les délégués du personnel sont élus conformément à la 

L'âge minimum d'embauche réglementaire est respecté 
Les temps et horaires de travail, sont respectés, et les 

iv. 
v. 
heures supplémentaires sont comptabilisées et rémunérées.  
vi. 
réglementation en vigueur et disposent des moyens et des conditions 
nécessaires à la réalisation de leur fonction. 
vii. 
connaissance des travailleurs. 
viii. 
ou partiel respectent la règlementation en vigueur. 

Les procédures de licenciement ou de chômage technique 

Un règlement intérieur du travail est élaboré et porté à la 

Direct interviews/ discussions / Stakeholder input 

In reaction to the original conclusion ‘partially 
covered” and the justification “Part of the 
requirement is not met: the obligation to have 
obligatory insurances, certificates of competence 
and other training requirements, and payment of 
social and income taxes are not included”, BV 
points out:  

“Covered with 1.3.1 for Employment Contract, 
Social Security, Social Taxes and Income Taxes in 
the pay slip demanded by the repository  and 
covered with 4.1.4  which meets the requirements 
of competence and training of personnel involved 
in maintaining compliance with the legality and 
traceability of the woods.” 

Justification 

BV’s input has been taken into consideration and 
based on the above this indicator is covered.   

RF03 OLB EF Version 3.4 

1.3.1 : L'entreprise respecte les lois et réglementations essentielles 
relatives à l'embauche et au travail, dont les exigences suivantes*: 

Findings 

Scheme info 

Covered 

Les travailleurs doivent être libres de s'organiser et de 

iii. 
négocier leurs conditions d'embauche selon les conventions 87 et 98 
du Bureau International du Travail. 
iv. 
vi. Les délégués du personnel sont élus conformément à la 
réglementation en vigueur et disposent des moyens et des conditions 
nécessaires à la réalisation de leur fonction. 

L'âge minimum d'embauche réglementaire est respecté 

1.6.3 - 
1.1.1 et 1.1.3. 

Les entreprises sous-traitantes remplissent les exigences 

921 

The organisation must respect national laws and 
other regulatory and administrative requirements 
regarding social aspects.  

Indicator 1.3.1 lists the requirements related to 
legal employment, including minimum working age 
and discrimination and legislation allowing for 
freedom of association. 

This is also applicable to subcontractors. 

 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

and legislation 
allowing for freedom 
of association. 

L’entreprise a vérifié que les travailleurs de ses sous-

1.6.4 - 
traitants exercent leurs activi tés dans un cadre légal. Les indicateurs 
1.3.1, 1.3.2 et 1.3.3 sont applicables aux employés des sous-traitants 
travaillant dans le périmètre évalué. 

In addition, the organisation must respect the 
international conventions and treaties adhered by 
the country, including ILO conventions 29, 87, 97, 
98, 100, 105, 111, 131, 138, 141, 142, 143, 155, 
169, 182 and ILO directives on health and safely in 
the forestry sector.   

1.5.2 - 
internationaux dont le pays est signataire. 

L'entreprise respecte les conventions et traités 

Justification 

Note: Les conventions de l’OIT qui ont un impact sur les opérations et 
pratiques forestières sont les suivantes: 29, 87, 97, 98, 100, 105, 111, 
131, 138, 141, 142, 143, 155, 169, 182 et les Directives du BIT sur la 
santé et la sécurité en milieu forestier. 

Based on the above, this indicator is covered by 
the standard. 

A.1a.4 Third parties’ legal rights 
concerning use and tenure that 
are affected by tim ber 
harvesting 

A.1a.4.1  Customary 

rights 

A.1a.4.1.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with respect for 
customary tenure 
rights relevant to 
forest harvesting 
activities. 

RF03 OLB EF Version 3.4 

L’entreprise détient les droits légaux et les autorisations 

1.2.2 - 
officielles et valides pour la gestion et l’exploitation des surfaces 
forestières évaluées. 

1.3.4 - 
L'entreprise a réalisé une étude d'impact social en fonction 
de l’échelle, de l’intensité et du risque des opérations d’aménagement 
et d’exploitation forestière et de la spécificité du contexte social.  Elle a 
valorisé les résultats de cette étude par un programme opérationnel. 

L'ensemble des communautés locales (y compris les 

i. 
peuples autochtones), autour ou au sein des concessions forestières, 
ayant des droits traditionnels ou légaux, sont identifiées et 
cartographiées. 
ii. 
ressources)   des communautés concernées par les surfaces 
forestières évaluées sont identifiés par le biais d'une concertation* 
avec ces populations. 

Les droits fonciers (propriété) et droits d'usage (accès aux 

1.3.5 - 

Les communautés locales ont été consultées au préalable et 

922 

Findings 

Scheme info 

Covered 

The organisation must have the legal rights and 
valid official authorisations to manage and harvest 
the assessed  forest areas.  

To avoid conflicts with third parties, the 
organisation must perform a social impact 
assessment  and take its results into account via 
an operational program.  

Justification 

Based on the above, this indicator is covered by 
the standard. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

sont impliquées dans les activités de gestion/ exploitation forestière 
pouvant avoir une incidence sur leurs droits) 

L’entreprise, par le biais de la concertation culturellement 

1.3.6 - 
appropriée avec les communautés concernées par les surfaces 
forestières évaluées, met en œuvre des mesures pour identifier en 
permanence, prévenir, éviter ou atténuer les impacts négatifs 
potentiels de ses activités sur leurs droits coutumiers et/ou légaux  

1.3.7 -  Des  mécanismes et des mesures appropriés doivent être 
employés pour prévenir et rechercher des solutions aux conflits relatifs 
aux droits fonciers (propriété) et aux droits d'usage d'usages (accès 
aux ressources). 

RF03 OLB EF Version 3.4 

1.1.1 L'entreprise a réalisé une étude d'impact social en fonction de 
l’échelle, de l’intensité et du risque des opérations d’aménagement et 
d’exploitation forestière et de la spécificité du contexte social.  Elle a 
valorisé les résultats de cette étude par un programme opérationnel. 

L'ensemble des communautés locales (y compris les 

i. 
peuples autochtones), autour ou au sein des concessions forestières, 
ayant des droits traditionnels ou légaux, sont identifiée s et 
cartographiées. 
ii. 
ressources)  des communautés concernées par les surfaces forestières 
évaluées sont identifiés par le biais d'une concertation* avec ces 
populations. 

Les droits fonciers (propriété) et droits d'usage (accès aux 

Les communautés locales ont été consultées au préalable et 

1.1.2 - 
sont impliquées dans les activités de gestion/ exploitation forestière 
pouvant avoir une incidence sur leurs droits) 

L’entreprise, par le biais de la concertation culturellement 

1.1.3 - 
appropriée avec les communautés concernées par les surfaces 
forestières évaluées, met en œuvre des mesures pour identifier en 
permanence, prévenir, éviter ou atténuer les impacts négatifs 

923 

A.1a.4.1.2 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legal 
obligations 
concerning benefit 
sharing they have 
negotiated with 
communities or 
customary users. 
E.g. social 
agreements or 
social responsibility 
agreements or 
cahier de charges, 
dependent on the 
country. 

Findings 

Scheme info 

Partially 
Covered 

The organisation must put in place appropriate 
measures to prevent, avoid and solve conflicts 
related to customary tenure rights and the access 
to resources,  including the identification and 
consultation with all local communities, and 
indigenous peoples with customary or legal rights.  

However, requirements to comply with legal 
obligations concerning benefit sharing are not 
included.   

Direct interviews/ discussions / Stakeholder input 

In reaction to the original conclusion ‘partially 
covered” and the justification “Part of the indicator 
is not met: requirements to comply with legal 
obligations concerning benefit sharing are not 
included”, BV points out:  

The company must be up to date with the payment 
of all taxes, duties or other royalties (RFA, 

 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

verification of the payment of all shares including 
those intended for municipalities and communities) 
applicable and provided by law. 

However, it is not written as such in the standard 
indicators and may be subject to interpretations.  

Justification 

Part of the indicator is not met: requirements to 
comply with legal obligations concerning benefit 
sharing are not included in the description of the 
standard indicators.   

Findings 

Scheme info 

Covered 

The organisation must consult local communities 
prior to management and harvesting activities and 
involve them in the management and harvesting 
activities that may have an impact on their rights.  

As part of this “culturally appropriated” 
consultation, the organisation must implement 
measures to continuously identify, prevent, avoid 
or mitigate the potential negative impacts of their 
activities on their legal or customary rights.  

Justification 

Based on the above, this indicator is covered by 
the standard. 

A.1a.4.2 

Free, Prior and 
Informed 
Consent 

A.1a.4.2.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with the 
internationally 
adopted principles 
of 'Free, Prior and 
Informed Consent' 
in connection with 
granting rights to 
forest management. 

RF03 OLB EF Version 3.4 

Les communautés locales ont été consultées au préalable et 

1.3.5 - 
sont impliquées dans les activités de gestion/ exploitation forestière 
pouvant avoir une incidence sur leurs droits) 

L’entreprise, par le biais de la concertation culturellement 

1.3.6 - 
appropriée avec les communautés concernées par les surfaces 
forestières évaluées, met en œuvre des mesures pour identifier en 
permanence, prévenir, éviter ou atténuer les impacts négatifs 
potentiels de ses activités sur leurs droits coutumiers et/ou légaux 

924 

 
 
 
 
 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1a.4.3

Indigenous and 
traditional 
peoples' rights 

A.1a.4.3.1 The 
Scheme shall
include
requirements that
ensure compliance
with national
legislation and
international
conventions ratified 
that respect the
tenure rights of
indigenous and
tribal peoples to
forest land as well
as their right to
FPIC.

RF03 OLB EF Version 3.4 

L'entreprise a réalisé une étude d'impact social en fonction 
1.3.4 - 
de l’échelle, de l’intensité et du risque des opérations d’aménagement 
et d’exploitation forestière et de la spécificité du contexte social.  Elle a 
valorisé les résultats de cette étude par un programme opérationnel. 

L'ensemble des communautés locales (y compris les 

i.
peuples autochtones), autour ou au sein des concessions forestières,
ayant des droits traditionnels ou légaux, sont identifiées et
cartographiées.
ii.
ressources)   des communautés concernées par les surfaces 
forestières évaluées sont identifiés par le biais d'une concertation*
avec ces populations 

Les droits fonciers (propriété) et droits d'usage (accès aux

Findings 

Scheme info 

Covered 

Requirements for the development of a social 
impact assessment include the identification and 
localisation of local communities, including 
indigenous peoples. Consultation with local 
communities and other social requirements (e.g. 
right to Free Prior and Informed Consent) includes 
indigenous peoples. 

Indicator 1.5.2 - 
international  conventions and treaties adhered by 
the country. 

requires the respect of 

1.3.7 -  Des  mécanismes et des mesures appropriés doivent être 
employés pour prévenir et rechercher des solutions aux conflits relatifs 
aux droits fonciers (propriété) et aux droits d'usage d'usages (accès 
aux ressources). 

Justification 

Based on the above, this indicator is covered by 
the standard. 

Il existe des procédures écrites basées sur la législation 

i.
nationale et/ou les règl es coutumières, pour la prévention et la gestion
des conflits et des dégâts dans les cas de perte ou de dommages 
affectant les propriétés, les ressources,  la santé et les conditions de
subsistance des populations locales, y compris les peuples 
autochtones.
ii.
Les procédures élaborées pour la prévention et la gestion 
des conflits et la réparation des dégâts dans les cas de pertes ou de
dommages affectant les propriétés, les ressources  et les conditions de
subsistance des populations locales et autochtones doivent être mises 
en application de manière objective, constructive, et documentée.
iii.
l’entreprise est tenu, enregistré et archivé, comprenant la 
documentation y afférente, et les preuves des actions prises pour les 
résoudre.

Un dossier complet et actualisé des conflits et griefs contre

1.5.2 - 
internationaux dont le pays est signataire. 

L'entreprise respecte les conventions et traités 

925 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1a.5 Trade and custom s, in so 
far as the forest sector is 
concerned 

A.1a.5.1  Classification of 

species, 
quantities, 
qualities 

A.1a.5.1.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
regulating how 
harvested material 
is classified in terms 
of species, 
Quantities and 
qualities in 
connection with 
trade and transport.  

RF03 OLB EF Version 3.4 

Les factures de vente et autres documents 
5.2 - 
d’accompagnement concernant des bois OLB mentionnent les 
informations nécessaires. 

5.2.1 - 
- 
- 
- 
- 
- 

Les factures de produits OLB mentionnent : 
nature et essence des produits ; 
nature OLB des produits dans leur désignation ;  
volumes concernés; 
numéro et période de validité du certificat OLB ; 
le(s) pays d’origine des bois. 

5.2.2 -  Chaque vente de produits OLB est accompagné d'un 
bordereau spécifique de suivi OLB qui mentionne uniquement les 
produits OLB et précise 
- 
- 
- 
- 

La nature et essence des produits ; 
Les volumes concernés ; 
Le numéro et la période de validité du certificat OLB; 
le(s) pays d’origine. 

Findings 

Scheme info 

Covered 

It is required that the organisation complies with all 
applicable national and international legislation 
related to timber transport and commercialisation. 

Sales invoices must include products classification 
in terms of type of product, species and quantities, 
among other information.  

Justification 

Based on the above, this indicator is covered by 
the standard. 

A.1a.5.2 

Trade and 
transport 

L’entreprise doit prouver sa conformité avec toutes les lois 
5.3 - 
nationales et internationales applicables relatives au transport et à la 
commercialisation du bois 
RF03 OLB EF Version 3.4 

L’entreprise doit prouver sa conformité avec toutes les lois 
5.3 - 
nationales et internationales applicables relatives au transport et à la 
commercialisation du bois. 

A.1a.5.2.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 

Findings 

Scheme info 

Covered 

It is required that the organisation complies with all 

926 

 
 
 
 
 
 
 
 
 
 
 
 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1a.5.3

Offshore 
trading and 
transfer pricing 

A.1a.5.4

Customs 
regulations 

with legally required 
trading permits as 
well as legally 
required transport 
documents that 
accompany 
transport of wood 
from forest 
operations. 

A.1a.5.3.1 The 
Scheme shall
include
requirements that
ensure compliance
with legislation
regulating offshore
trading and transfer 
pricing.

A.1a.5.4.1 The 
Scheme shall
include
requirements that
ensure compliance
with legislation
covering areas such
as export/import
licenses, and
product
classification related
to customs (codes,

5.3.1 - 
Les preuves documentées de la conformité avec les 
prescriptions légales du pays d'origine du bois en matière de transport 
et de commerce sont disponible (documents légaux de transport, 
déclaration en douanes, payement des droits de douanes, etc.). 

5.3.2 - 
L’entreprise détient les preuves documentées de sa 
conformité à la réglementation applicable du commerce offshore et les 
tarifs et taxes y afférents si applicable. 

RF03 OLB EF Version 3.4 

5.3.2 - 
L’entreprise détient les preuves documentées de sa 
conformité à la réglementation applicable du commerce offshore et les 
tarifs et taxes y afférents si applicable. 

RF03 OLB EF Version 3.4 

Les preuves documentées de la conformité avec les 

5.3.1 - 
prescriptions légales du pays d'origine du bois en matière de transport 
et de commerce  sont disponible (documents légaux de transport, 
déclaration en douanes, payement des droits de douanes, etc.). 

927 

applicable national and international legislation 
related to timber transport and commercialisati on. 

Organisation must ensure that legally required 
trading permits as well as legally required 
transport documents that accompany transport of 
wood from forest operations are available. 

Justification 

Based on the above, this indicator is covered by 
the standard. 

Findings 

Scheme info 

Indicator 5.3.2 requires organisations to keep 
documented proof of compliance with applicable 
offshore trading regulation and related tariffs and 
taxes if applicable.  

Justification 

Based on the above, this indicator is covered by 
the standard. 

Findings 

Scheme info 

It is required that the organisation complies with all 
applicable national and international legislation 
related to timber transport and commercialisation. 

The organisation must have documented evidence 
of compliance with the country of origin's legal 
transport and trade requirements (legal transport 
documents, customs declarations, customs fees, 

Covered 

Covered 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

A.1a.5.5  CITES 

A.1a.5.6 

Legislation 
requiring due 
diligence / due 
care 
procedures 

quantities, qualities 
and species). 

A.1a.5.5.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
related to CITES 
permits (the 
Convention on 
International Trade 
in Endangered 
Species of Wild 
Fauna and Flora, 
also known as the 
Washington 
Convention). 
A.1a.5.6.1 The 
scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
covering due 
diligence/due care 
procedures, 
including e.g. due 
diligence/due care 
systems, 
declaration 
obligations, and /or 
the keeping of trade 
related documents, 

RF03 OLB EF Version 3.4 

Les exigences des traités internationaux tels que CITES, les 

1.5 - 
conventions du BIT et de l'OIBT, et la convention sur la diversité 
biologique doivent être respectées* 

1.5.1 - 
L'entreprise respecte les réglementations sur les espèces 
protégées et listées par CITES qui sont présentes dans les surfaces 
forestières évaluées 

etc.). 

Justification 

Based on the above, this indicator is covered by 
the standard. 

Findings 

Scheme info 

Covered 

The standard includes requirements to respect 
international treaties such as CITES and specifies 
that CITES listed species are identified and that 
the management and harvesting of CITES listed 
species is done following the established protocol.  

i. 
ii. 
iii. 
listées par CITES correspondent aux protocoles établis 

Les espèces protégées listées par CITES sont identifiées 
Les espèces protégées ne sont pas récoltées 
Les modalités d'exploitation et de gestion des espèces 

Justification 

Based on the above, this indicator is covered by 
the standard. 

RF03 OLB EF Version 3.4 

5.3 
 L’entreprise doit prouver sa conformité avec toutes les lois 
nationales et internationales applicables relatives au transport et à la 
commercialisation du bois 

5.3.1 Les preuves documentées de la conformité avec les 
prescriptions légales du pays d'origine du bois en matière de 
transport et de commerce sont disponible (documents 
légaux de transport, déclaration en douanes, payement des 
droits de douanes, etc.). 

Findings 

Scheme info 

Partially 
Covered 

The standard requires all forest management 
certificate holders to be “in compliance with 
national and international related to timber trade 
and transport”. But the scheme does not ensure 
that all types of certificate holder sre required to 
comply with specific legislation regarding 
implementation of due diligence systems. 

Justification 

Based on the above this indicator is partially covered. 

928 

 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and Justification 

Conclusion 

legislation 
establishing 
procedures to 
prevent trade in 
illegally harvested 
timber and products 
derived from such 
timber, etc. 

Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

A.1b Legal Requirements at the forest level – Non-Certified input - COC Standard Annex 1: Supplier Evaluation Program 

This principle relates to how the scheme ensures that Certificate Holders comply with all applicable legislation. This section relates to requirements of the Scheme that applies to Ce rtificate Holders - or 
other entities subject to the normative requirements of the Scheme (e.g. included within the scope of a certified due diligence system) - within the Country of Harvest. 

A.1b.1.1 

A.1b.1 Rights to harvest tim ber 
w ithin legally gazetted 
boundaries  
Land tenure 
and 
management 
rights 

A.1b.1.1.1. The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
covering land 
tenure rights, 
including customary 
rights as  well as 
management rights.  

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program 

Findings 

Covered 

Le fournisseur doit détenir les droits légaux pour la gestion et 

- 
l’exploitation forestière ; 
- 
Le fournisseur doit apporter la preuve que la zone forestière 
exploitée est légalement classée comme forêt de production, et qu'il a 
reçu les autorisations nécessaires pour exercer des activités 
forestières; 
Le fournisseur doit apporter la preuve que les droits 
- 
traditionnels et légaux des communautés riveraines de la (des) forêt(s) 
concernée(s) sont respectées 

Scheme info 

The evaluation program requires proof that the 
supplier (Forest Management Enterprise) holds 
the legal rights to manage and harvest the forest, 
and that customary rights are respected.    

Justification 

Based on the above, this indicator is covered by 
the standard. 

A.1b.1.1.2. The 
Scheme shall 
include 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program 

Findings 

- 

Les limites de la zone de production forestière sont 

Partially 
Covered 

929 

 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

requirements to 
ensure that 
licenses, right of 
tenure and 
management rights, 
have been issued: 

i)  according to the 
legally prescribed 
procedure, 

ii) in compliance 
with third parties' 
legal rights 
concerning tenure, 

iii) specifying the 
legally-gazetted 
boundaries, and; 

iv) with absence of 
corrupt practices. 
A.1b.1.1.3 The 
Scheme shall 
include 
requirements that 
ensure the 
existence of legal 
business 
registration, and 
other relevant 
legally required 
licenses.  

matérialisées et l’entreprise n’exploite pas en dehors des limites de la 
zone attribuée; 

Scheme info 

Le fournisseur doit apporter la preuve que les droits 

- 
traditionnels et légaux des communautés riverains de la (des) forêt(s) 
concernée(s) sont respectées 

Supplier must prove that the boundaries are 
respected and that third parties’ legal rights are 
respected.  

However, the requirement to ensure that licenses 
and rights have been obtained according to the 
legally prescribed procedure and in absence of 
corrupt practices is not included.  

Justification 

Part of the indicator is not met: Organisations are 
not required to have procedures in place to ensure 
absence of corrupt practices.  

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program 

Findings 

Covered 

- 

- 

- 

- 

Le fournisseur doit être une société exploitation forestière 
légalement établie; 

Scheme info 

Supplier must be a legally registered forest 
harvesting company and have the legal rights for 
the forest management and harvesting.  

Justification 

Based on the above, this indicator is covered by 
the standard. 

Le fournisseur doit détenir les droits légaux pour la gestion et 
l’exploitation forestière ; 

Le fournisseur doit s’être acquitté de ses obligations fiscales 
de droit commun ainsi que de toutes les taxes et redevances 
forestières applicables  

Le fournisseur doit apporter la preuve que la zone forestière 
exploitée est légalement classée comme forêt de production, 
et qu'il a reçu les autorisations nécessaires pour exercer des 
activités forestières; 

930 

 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

- 

Le fournisseur doit élaborer et mettre en œuvre un document 
de planification de ses opérations forestières ou un plan 
d'aménagement forestier (lorsque la réglementation locale 
l'exige); 

- 

Si la réglementation locale l’exige, le plan d'aménagement 
forestier doit être approuvé par l'autorité compétente; 

A.1b.1.2  Concession 

licenses 

A.1b.1.3  Management 

and harvesting 
planning 

A.1b.1.2.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
regulating 
procedures for the 
issuing of 
concession 
licenses, including 
use of legal 
methods to obtain 
concession licenses 
and that licenses 
are covering only 
legally gazetted 
areas 
A.1b.1.3.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation and 
legal obligations for 
management 
planning, including 
conducting forest 
inventories, having 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program 

Findings 

Partially 
Covered 

Le fournisseur doit détenir les droits légaux pour la gestion et 

- 
l’exploitation forestière ; 
- 
Le fournisseur doit apporter la preuve que la zone forestière 
exploitée est légalement classée comme forêt de production, et qu'il a 
reçu les autorisations nécessaires pour exercer des activités 
forestières; 

Scheme info 

The standard requires that the organisation has 
the official legal rights for the management and 
harvesting of the forest management area but 
does not mention the requirement of having 
procedures to ensure the use of legal methods to 
obtain these.  

Justification 

Part of the indicator is not met: Organisations are 
not required to have procedures in place to ensure 
the use of legal methods to obtain official 
authorisations.  

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program 

Findings 

Covered 

Le fournisseur doit élaborer et mettre en œuvre un document 

- 
de planification de ses opérations forestières ou un plan d'aménagement 
forestier (lorsque la réglementation locale l'exige); 

- 
forestier doit être approuvé par l'autorité compétente; 

Si la réglementation locale l’exige, le plan d'aménagement 

Scheme info 

When legally required, suppliers must have an 
approved forest management plan, and in all 
cases  at least a forest operation planning 
document.  

- 
volumes autorisés, diamètres minimum, essences exploitables, marquage 

Les prescriptions en matière d'exploitation sont respectées : 

Justification 

931 

 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

a forest 
management plan 
and related 
planning and 
monitoring. 

A.1b.1.3.2 The 
Scheme shall 
include 
requirements that 
all legally required 
planning documents 
have been 
approved prior to 
implementation of 
forest harvesting 
activities. 

A.1b.1.4.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
regulating the 
issuing of 
harvesting permits, 
licenses or other 
legal documents 
required for specific 
harvesting 
operations. 

A.1b.1.4  Harvesting 

permits 

réglementaire, utilisation des documents légaux d’enregistrement de la 
récolte et de transport obligatoires, les essences protégées ne sont pas 
récoltées ; 

Based on the above, this indicator is covered by 
the standard. 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Scheme info 

Partially 
Covered 

- 
Le fournisseur doit apporter la preuve que la zone forestière 
exploitée est légalement classée comme forêt de production, et qu'il a 
reçu les autorisations nécessaires pour exercer des activités forestières; 

It is not explicitly mentioned that “[…] have been 
approved prior to implementation of forest 
harvesting activities”. 

Le fournisseur doit élaborer et mettre en œuvre un document 

- 
de planification de ses opérations forestières ou un plan d'aménagement 
forestier (lorsque la réglementation locale l'exige); 

- 
forestier doit être approuvé par l'autorité compétente; 

Si la réglementation locale l’exige, le plan d'aménagement 

Justification 

Part of the indicator is not met: it is not explicitly 
mentioned that legally required planning 
documents have been approved prior to 
implementation of forest harvesting activities. 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Covered 

Le fournisseur doit détenir les droits légaux pour la gestion et 

Le fournisseur doit être une société exploitation forestière 

- 
légalement établie; 
- 
l’exploitation forestière ;  
- 
Le fournisseur doit apporter la preuve que la zone forestière 
exploitée est légalement classée comme forêt de production, et qu'il a 
reçu les autorisations nécessaires pour exercer des activités 
forestières; 
- 
de planification de ses opérations forestières ou un plan 
d'aménagement forestier (lorsque la réglementation locale l'exige); 
- 
forestier doit être approuvé par l'autorité compétente;  
- 
attributs des sites  dédiés à la protection ou la conservation sont 
respectés.  

Les modalités de gestion des essences CITES ainsi que les 

Si la réglementation locale l’exige, le plan d'aménagement 

Le fournisseur doit élaborer et mettre en œuvre un document 

932 

Scheme info 

As part of the supplier evaluation program, 
requirements that ensure compliance with 
legislation regulating the issuing of harvesting 
permits, licenses or other legal documents 
required for specific harvesting operations must be 
checked. 

Justification 

Based on the above this indicator is covered. 

 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

A.1b.2 Paym ents for harvest 
rights and tim ber including 
duties related to tim ber 
harvesting 

A.1b.2.1  Payment of 

royalties and 
harvesting fees 

A.1b.2.2  Value-added 

taxes and other 
sales taxes 

A.1b.2.1.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
covering payment of 
all legally required 
forest harvesting-
specific fees such 
as royalties, 
stumpage fees and 
other volume-based 
fees, as  well as land 
area taxes or fees. 
A.1b.2.2.2 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
covering different 
types of sales taxes 
that apply to the 
material being sold, 
including selling 
material as growing 
forest (standing 
stock  sales). 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Le fournisseur doit s’être acquitté de ses obligations fiscales 

- 
de droit commun ainsi que de toutes les taxes et redevances 
forestières applicables 

Scheme info 

Standard requires organisations to be in 
compliance with all their fiscal obligations, 
including fees related to their forest harvesting 
activities. There are no mentions of land areas 
taxes. 

Justification 

Based on the above, this indicator is partially 
covered by the standard. 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Partially 
Covered 

Partially 
Covered 

Le fournisseur doit s’être acquitté de ses obligations fiscales 

- 
de droit commun ainsi que de toutes les taxes et redevances 
forestières applicables 
- 
nationales et internationales applicables en matière de commerce et 
de transport du bois 

Le fournisseur doit apporter la preuve du respect des lois 

Scheme info 

Standard requires organisations to be in 
compliance with all their fiscal obligations, 
including taxes related to wood harvesting and 
commercialisation of timber. There is not specific 
mention of VAT or other sales taxes. 

Justification 

Based on the above, this indicator is partially 
covered by the standard. 

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Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

A.1b.3.1 

A.1b.3 Timber harv esting, including 
env ironmental and forest legislation 
including forest management and 
biodiv ersity conservation, where 
directly related to timber harv esting 
Timber 
harvesting 
regulations 

A.1b.3.1.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legal 
obligations for 
harvesting 
techniques and 
technology 
including timing of 
harvest, selective 
cutting, shelter 
wood regeneration, 
clear felling, 
transport of timber 
from felling sites 
and seasonal 
limitations etc. 

This includes the 
mis-use of 
salvaging permits or 
other specific 
ministerial permits, 
with the intention of 
circumventing 
harvest regulations 

A.1b.3.2.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 

A.1b.3.2  Protected sites 

and species 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Partially 
Covered 

Le fournisseur doit élaborer et mettre en œuvre un document 

Si la réglementation locale l’exige, le plan d'aménagement 

- 
de planification de ses opérations forestières ou un plan 
d'aménagement forestier (lorsque la réglementation locale l'exige); 
- 
forestier doit être approuvé par l'autorité compétente; 
- 
volumes autorisés, diamètres minimum, essences exploitables, 
marquage réglementaire, utilisation des documents légaux 
d’enregistrement de la récolte et de transport obligatoires, les 
essences  protégées ne sont pas récoltées ; 

Les prescriptions en matière d'exploitation sont respectées : 

Scheme info 

Supplier must develop and implement and forest 
operation planning document or an approved 
management plan (this last one when legally 
required) and all requirements must be met. There 
are no specific requirements to assess  the 
potential mis-use of salvaging permits or other 
specific ministerial permits, with the intention of 
circumventing harvest regulations. 

Justification 

Part of the indicator is not met: there are no 
specific requirements to assess  the potential mis-
use of salvaging permits or other specific 
ministerial permits, with the intention of 
circumventing harvest regulations. 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Partially 
Covered 

Le fournisseur doit élaborer et mettre en œuvre un document 

- 
de planification de ses opérations forestières ou un plan 
d'aménagement forestier (lorsque la réglementation locale l'exige); 

Scheme info 

Supplier must develop and implement a forestry 

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Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

with legislation 
related to protected 
areas as well as 
protected, rare, or 
endangered 
species, including 
their habitats and 
potential habitats. 

Les prescriptions en matière d'exploitation sont respectées : 

Si la réglementation locale l’exige, le plan d'aménagement 

- 
forestier doit être approuvé par l'autorité compétente; 
- 
volumes autorisés, diamètres minimum, essences exploitables, 
marquage réglementaire, utilisation des documents légaux 
d’enregistrement de la récolte et de transport obligatoires, les 
essences  protégées ne sont pas récoltées ; 
- 
attributs des sites  dédiés à la protection ou la conservation sont 
respectés. 

Les modalités de gestion des essences CITES ainsi que les 

operation planning document (or forest 
management plan, if required by local regulation) 
that ensures that protected species are not 
harvested. 

However, when a forest management plan is not 
required, it is not specified the contents of the 
forestry operations planning document, which may 
not include requirements for rare or endangered 
species, including their habitats and potential 
habitats. 

On the other hand, CITES requirements and sites 
destined to protection or conservation are 
respected.  

Direct interviews/ discussions / Stakeholder input 

BV points out: “Covered by point B. Requirements 
to be checked of supplier evaluation program 
relating to operating requirements”. 

However, the “protection of rare or endangered 
species, including their habitats and potential 
habitats” is not mentioned in the requirements of 
the Supplier Evaluation Program. 

Justification 

Part of the indicator is not met: protection of rare 
or endangered species, including their habitats 
and potential habitats is not included in the 
Supplier Evaluation Program. 

A.1b.3.2.2 
Requirements that 
ensure compliance 
with legislation 
related to protected 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Partially 
Covered 

Le fournisseur doit élaborer et mettre en œuvre un document 

- 
de planification de ses opérations forestières ou un plan 
d'aménagement forestier (lorsque la réglementation locale l'exige); 

Scheme info 

The standard requires that suppliers implement a 

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Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

areas and habitats, 
shall include that 
the identification of 
protected areas is 
conducted 
according to the 
legal requirements. 

A.1b.3.3.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
related to 
environmental 
impact assessment 
in connection with 
harvesting, 
acceptable levels of 
damage and 
disturbance of soil 
resources, 
establishment of 
buffer zones (e.g. 
along watercourses, 

A.1b.3.3  Environmental 

requirements 

Les prescriptions en matière d'exploitation sont respectées : 

Si la réglementation locale l’exige, le plan d'aménagement 

- 
forestier doit être approuvé par l'autorité compétente; 
- 
volumes autorisés, diamètres minimum, essences exploitables, 
marquage réglementaire, utilisation des documents légaux 
d’enregistrement de la récolte et de transport obligatoires, les 
essences  protégées ne sont pas récoltées ; 
- 
attributs des sites  dédiés à la protection ou la conservation sont 
respectés. 

Les modalités de gestion des essences CITES ainsi que  les 

forestry operation planning document or, when 
required by the legislation, a management plan 
duly approved by the competent authority.  

However, when a forest management plan is not 
required, it is not specified the contents of the 
forestry operations planning document, which may 
not include that the identification of protected 
areas is conducted according to the legal 
requirements. 

Justification 

Part of the indicator is not met: identification of 
protected areas is conducted according to the 
legal requirements is not required for non-
mandatory forestry operation planning document 
in the Supplier Evaluation Program. 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Partially 
Covered 

Le fournisseur doit apporter la preuve du respect de la 

- 
réglementation sur la protection de l’environnement (à minima : 
Mesures du respect des plans d’eau lors des opérations d’exploitation, 
gestion des déchets et de tout type de pollution généré par les activités 
de l’entreprise) 

Scheme info 

The supplier must prove compliance with 
environmental protection regulation, but it is not 
specified regulation related to acceptable levels of 
damage and disturbance of soil resources, 
establishment of buffer zones (e.g. along 
watercourses, open areas, breeding sites), 
maintenance of retained trees on felling sites, 
seasonal limitations on harvesting, and 
environmental requirements for forest machinery.  

Justification 

Part of the indicator is not met: it is not specified 
regulation related to acceptable levels of damage 

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Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

A.1b.3.4  Health and 

safety 

A.1b.3.5 

Legal 
employment 

open areas, 
breeding sites), 
maintenance of 
retained trees on 
felling sites, 
seasonal limitations 
on harvesting, and 
environmental 
requirements for 
forest machinery. 
A.1b.3.4.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with Health & Safety 
legislation. 

A.1b.3.5.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation for 
employment of 
personnel involved 
in harvesting (and 
in-forest 
processing) 
activities including 
but not limited to 
requirements for: 
contracts and 

and disturbance of soil resources, establishment of 
buffer zones (e.g. along watercourses, open 
areas, breeding sites), maintenance of retained 
trees on felling sites, seasonal limitations on 
harvesting, and environmental requirements for 
forest machinery. 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Covered 

Le fournisseur doit apporter la preuve du respect de la 

- 
réglementation sur la santé et la sécurité (Au minimum, les travailleurs 
disposent des équipements de protection individuelle appropriés, les 
moyens permettant d'évacuer et prendre en charge les travailleurs 
victimes d'accidents sont disponibles). 

Scheme info 

The organisation must respect Health and Safety 
legislation. At a minimum, appropriate protective 
individual equipment and the means to evacuate 
and care for accident-affected workers are 
available. 

Justification  

Based on the above, this indicator is covered by 
the standard. 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Partially 
Covered 

Le fournisseur doit apporter la preuve du respect des droits 

- 
des travailleurs conformément à la législation applicable (au minimum, 
l’entreprise doit vérifier : lien contractuel entre le fournisseur et ses 
employés, les travailleurs sont déclarés et reçoivent les rémunérations 
qui respectent les salaires minimum en vigueur, l’âge minimum 
d’embauche règlementaire est respecté, les temps et horaires de 
travail sont respectés et les heures supplémentaires sont 
comptabilisées et rémunérées…). 

Scheme info 

The organisation must respect applicable 
legislation related to workers’ rights. At a 
minimum, workers have a contract and perceive 
the minimum wage. Minimum working age is 
respected, and working hours are respected (and 
extraordinary worked hours are accounted and 
compensated).  

It is not required to check obligatory insurances, 
certificates of competence and other training 
requirements, and payment of social and income 

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Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

working permits, 
obligatory 
insurances, 
certificates of 
competence and 
other training 
requirements, and 
payment of social 
and income taxes.  
A.1b.3.5.2 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation for 
minimum working 
age and minimum 
age for personnel 
involved in 
hazardous work, 
legislation against 
forced and 
compulsory labour, 
and discrimination 
and legislation 
allowing for freedom 
of association. 

A.1b.4 Third parties’ legal rights 
concerning use and tenure that 
are affected by tim ber 
harvesting 

A.1b.4.1  Customary 

rights 

A.1b.4.1.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with respect for 

taxes. 

Justification 

Part of the indicator is not met: it is not required to 
check obligatory insurances, certificates of 
competence and other training requirements, and 
payment of social and income taxes. 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Partially 
Covered 

Le fournisseur doit apporter la preuve du respect des droits 

- 
des travailleurs conformément à la législation applicable (au minimum, 
l’entreprise doit vérifier : lien contractuel entre le fournisseur et ses 
employés, les travailleurs sont déclarés et reçoivent les rémunérations 
qui respectent les salaires minimums en vigueur, l’âge minimum 
d’embauche règlementaire est respecté, les temps et horaires de 
travail sont respectés et les heures supplémentaires sont 
comptabilisées et rémunérées…). 

Scheme info 

The organisation must respect applicable 
legislation related to workers’ rights. Minimum 
working age is respected, and working hours are 
respected (and extraordinary worked hours are 
accounted and compensated).  

Legislation against discrimination and legislation 
allowing for freedom of association are not 
mentioned. 

Justification 

Part of the indicator is not met: legislation against 
discrimination and legislation allowing for freedom 
of association are not mentioned. 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program 

Findings 

Covered 

Le fournisseur doit apporter la preuve que les droits 
- 
traditionnels et légaux des communautés riveraines de la (des) forêt(s) 
concernée(s) sont respectées 
- 

Le fournisseur doit détenir les droits légaux pour la gestion et 

Scheme info 

Supplier must prove that customary and legal 
rights of local communities affected by harvesting 

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Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

customary tenure 
rights relevant to 
forest harvesting 
activities. 

l’exploitation forestière ; 
- 
Le fournisseur doit apporter la preuve que la zone forestière 
exploitée est légalement classée comme forêt de production, et qu'il a 
reçu les autorisations nécessaires pour exercer des activités 
forestières; 

activities are respected. 

Justification 

Based on the above, this indicator is covered by 
the standard. 

A.1b.4.1.2 The 
Scheme  shall 
include 
requirements  that 
ensure 
compliance  w ith 
legal  obligations 
concerning 
benefit sharing 
they have 
negotiated  w ith 
communities  or 
customary users. 
E.g.  social 
agreements  or 
social 
responsibility 
agreements  or 
cahier de 
charges, 
dependent  on the 
country. 
A.1b.4.2.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with the 

A.1b.4.2 

Free, Prior and 
Informed 
Consent 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Partially 
Covered 

- 
Le fournisseur doit apporter la preuve que les droits 
traditionnels et légaux des communautés riveraines de la (des) forêt(s) 
concernée(s) sont respectées 

Scheme info 

The standard requires that organisations prove 
that the rights of local communities are respected. 

Requirements to comply with legal obligations 
concerning benefit sharing are not included. 

Justification 

Part of the indicator is not met: requirements to 
comply with legal obligations concerning benefit 
sharing are not included. 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Partially 
Covered 

- 
Le fournisseur doit apporter la preuve que les droits 
traditionnels et légaux des communautés riveraines de la (des) forêt(s) 
concernée(s) sont respectées 

Scheme info 

It is required to comply with the traditional and 
legal rights of the local communities, but in the 

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Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

A.1b.4.3 

Indigenous and 
traditional 
peoples' rights 

internationally 
adopted principles 
of 'Free, Prior and 
Informed Consent' 
in connection with 
granting rights to 
forest management. 

A.1b.4.3.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with national 
legislation and 
international 
conventions ratified 
that respect the 
tenure rights of 
indigenous and 
tribal peoples to 
forest land as well 
as their right to 
FPIC. 

Supplier Evaluation Program it is not explicitly 
mentioned the requirement to comply with the 
internationally adopted principles of 'Free, Prior 
and Informed Consent' in connection with granting 
rights to forest management.  

Justification 

'Free, Prior and Informed Consent' in connection 
with granting rights to forest management is not 
mentioned in the Supplier Evaluation Program. 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Partially 
Covered 

- 
Le fournisseur doit apporter la preuve que les droits 
traditionnels et légaux des communautés riveraines de la (des) forêt(s) 
concernée(s) sont respectées 

Scheme info 

It is only required to comply with the traditional and 
legal rights of the “local communities”, but it is not 
required to prove respect the tenure rights of 
indigenous and tribal peoples to forest land as well 
as their right to FPIC. 

Justification 

Part of the indicator is not met: it is not required to 
prove respect the tenure rights of indigenous and 
tribal peoples to forest land as well as their right to 
FPIC. 

A.1b.5 Trade and custom s, in so 
far as the forest sector is 
concerned 

A.1b.5.1  Classification of 

species, 
quantities, 
qualities 

A.1b.5.1.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
regulating how 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Partially 
Covered 

Les prescriptions en matière d'exploitation sont respectées : 

- 
volumes autorisés, diamètres minimum, essences exploitables, 
marquage réglementaire, utilisation des documents légaux 
d’enregistrement de la récolte et de transport obligatoires, les 
essences  protégées ne sont pas récoltées ; 

Scheme info 

Harvesting requirements must be respected, 
including authorized volumes, minimum diameters, 
harvestable species, regulatory marking, use of 

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Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

harvested material 
is classified in terms 
of species, 
Quantities and 
qualities in 
connection with 
trade and transport.  

A.1b.5.2.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legally required 
trading permits as 
well as legally 
required transport 
documents that 
accompany 
transport of wood 
from forest 
operations. 

A.1b.5.2 

Trade and 
transport 

- 
Le fournisseur doit apporter la preuve du respect des lois  
nationales et internationales applicables en matière de commerce et 
de transport du bois 

mandatory legal harvest registration and transport 
documents, protected species are not harvested. 

There are not specific requirements to comply with 
legislation regulating how harvested material is 
classified in terms of species, quantities and 
qualities in connection with trade and transport.  

Justification 

Part of the indicator is not met: there are not 
specific requirements to comply with legislation 
regulating how harvested material is classified in 
terms of species, quantities and qualities in 
connection with trade and transport. 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Covered 

Les prescriptions en matière d'exploitation sont respectées : 

- 
volumes autorisés, diamètres minimum, essences exploitables, 
marquage réglementaire, utilisation des documents légaux 
d’enregistrement de la récolte et de transport obligatoires, les 
essences  protégées ne sont pas récoltées ; 
- 
Le fournisseur doit apporter la preuve du respect des lois  
nationales et internationales applicables en matière de commerce et 
de transport du bois 

Scheme info 

It is required that the organisation complies with all 
applicable national and international legislation 
related to timber transport and commercialisation. 

Supplier must provide proof that must ensure that 
legally required trading permits as well as legally 
required transport documents that accompany 
transport of wood from forest operations are 
available. 

Justification 

Based on the above, this indicator is covered by 
the standard. 

A.1b.5.3  Offshore 

trading and 
transfer pricing 

A.1b.5.3.1 The 
Scheme shall 
include 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Not Covered 

- 

Le fournisseur doit apporter la preuve du respect des lois 

Scheme info 

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Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

A.1b.5.4  Customs 

regulations 

A.1b.5.5  CITES 

requirements that 
ensure compliance 
with legislation 
regulating offshore 
trading and transfer 
pricing.  

A.1b.5.4.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
covering areas such 
as export/import 
licenses, and 
product 
classification related 
to customs (codes, 
quantities, qualities 
and species). 

A.1b.5.5.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
related to CITES 
permits (the 
Convention on 
International Trade 
in Endangered 
Species of Wild 
Fauna and Flora, 

nationales et internationales applicables en matière de commerce et 
de transport du bois 

Suppliers must respect applicable national and 
international laws related to timber trade and 
transport. However, offshore trading and transfer 
pricing are not explicitly mentioned. 

Justification 

This indicator is not covered: it is not detailed how 
to prove compliance with offshore trading and 
transfer pricing. 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program 

Findings 

Partially 
Covered 

Le fournisseur doit apporter la preuve du respect des lois 

- 
nationales et internationales applicables en matière de commerce et 
de transport du bois 

Scheme info 

It is required that the supplier complies with 
applicable trade and transport legislation, but it is 
not detailed how to prove compliance with 
customs regulations.  

Justification 

Part of the indicator is not met: it is not detailed 
how to prove compliance with customs 
regulations.  

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program 

Findings 

Covered 

Les modalités de gestion des essences CITES ainsi que les 

- 
attributs des sites  dédiés à la protection ou la conservation sont 
respectés. 

The standard includes requirements to respect 
how CITES species are managed.  

Scheme info 

Justification 

Based on the above, this indicator is covered by 
the standard. 

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Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

A.1b.5.6 

Legislation 
requiring due 
diligence / due 
care 
procedures 

also known as the 
Washington 
Convention). 
A.1b.5.6.1 The 
scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
covering due 
diligence/due care 
procedures, 
including e.g. due 
diligence/due care 
systems, 
declaration 
obligations, and /or 
the keeping of trade 
related documents, 
legislation 
establishing 
procedures to 
prevent trade in 
illegally harvested 
timber and products 
derived from such 
timber, etc. 

RF03 OLB CdC v3.6 

Findings 

Scheme info 

Partially 
Covered 

The company implementing a Supplier Evaluation 
program must comply with all requirements in the 
main text of the COC standard, including “[…] that 
any commercial transaction (purchase and sale) of 
timber is carried out in accordance with applicable 
national and international laws and regulations, 
including those relating to the transport and 
marketing of timber.”. Section 1.2 includes 
requirements related to the system, including 
appointment of competent responsible persons, 
maintenance of documented procedures and 
record keeping. 

There are no requirements ensuring that certificate 
holders implement a due diligence system, where 
applicable.  

Justification 

Based on the above, this indicator is partially 
covered by the standard. 

1.1.7 - 
L’entreprise s’assure  que toute transaction commerciale (achat 
et vente) de bois se fasse  en conformité avec les lois et règlementations 
nationales et internationales applicables, y compris celles relatives au 
transport et à la commercialisation des  bois. 

1.2. Exigences relatives au système 

Organisation et responsabilités 

- L’entreprise doit nommer un membre du personnel ayant 

1.2.1  
suffisamment de compétences, de responsabilité et d'autorité pour la mise 
en place et le suivi du système de Chaîne de contrôle OLB. 

1.2.2 - 
responsabilités sont clairement identifiées.  

 L'entreprise doit mettre en place une organisation où les 

1.2.3 -   Chaque membre du personnel connaît et comprend ses 
propres responsabilités relatives au maintien du système de traçabilité.  

1.2.4  -   L'entreprise doit s'assurer que les employés intervenant dans la 
mise en œuvre des procédures de traçabilité sont formés. 

Les membres du personnel participant au maintien et au suivi 

- 
des      procédures de traçabilité sont suffisamment qualifiés pour 
exécuter les tâches qui leur sont assignées. 

Les intervenants, les membres du personnel et les sous-

- 
traitants concernés ont été sensibilisés et formés à la mise en œuvre de 
la chaîne de contrôle. 

Système documenté 

1.2.5 -  

L’entreprise doit élaborer et mettre en œuvre un système 

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Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

documenté qui répond aux exigences du présent Référentiel.  

Traitement des réclamations 

1.2.6.- 
moyens de traitement des réclamations  

L’entreprise doit enregistrer et mettre en œuvre des 

Enregistrement 

L'entreprise doit établir et mettre en œuvre des procédures 

1.2.7 -  
adaptées à l'importance et à la complexité de ses activités pour identifier, 
classer et sauvegarder les enregistrements qui sont nécessaires pour 
apporter la preuve du respect de la légalité et de la traçabilité de 
l'ensemble des bois à commercialiser. 

- 
Les données de production sont enregistrées et conservées. 
Elles présentent des synthèses périodiques par essence et par type de 
produit. 

- 

Les enregistrements sont clairs et accessibles.  

Les enregistrements mentionnent systématiquement le volume 

- 
et la référence des bois ou lots de bois et permettent d'identifier l'origine 
géographique du bois avant transformation. 

NB: Il est recommandé que les enregistrements permettent d'établir la 
correspondance entre les entrées de matières premières et les sorties de 
produits finis. 

1.2.8 -  
pendant 5 ans. Les enregistrements sont mis à disposition sur demande. 

L'entreprise doit conserver ces enregistrements au minimum 

1.4.5 
- En cas d’approvisionnement en bois non certifiés, l’entreprise 
s’assure  et démontre que ceux-ci ne proviennent pas de sources illégales. 

Méthode d’évaluation : mise en place d’une diligence raisonnée voir 
ANNEXE 1 

944 

 
  
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program 

Définition du Programme d'évaluation des fournisseurs 
A. 
L'entreprise doit se conformer à minima aux exigences suivantes: 
- 
Définir et mettre en œuvre un processus en vue de 
l'évaluation régulière et de l'audit des fournisseurs de bois non 
certifiés. Ce processus  doit comprendre à minima :  
Les fréquences de l’évaluation de chaque fournisseur (Au moins une 
évaluation annuelle sur site de chaque fournisseur de bois non certifié) 
Une définition claire des compétences des employés qui réalisent les 
évaluations en respectant les dispositions relatives aux techniques 
d’audit. 
Une identification des enregistrements qui prouvent la conformité des 
fournisseurs évalués et les modalités de conservation (5 ans au 
minimum) 
La définition du contenu minimum des rapports d’évaluation avec une 
formulation claire des éventuels écarts et une précision des délais de 
résolution et la conclusion de l’équipe d’évaluateurs. 
- 
élaborée(s) selon les exigences de cette annexe et approuvée par 
Bureau Veritas. 

Tenir une (des) liste(s) de contrôle doit (doivent) être 

A.2a Legal requirements for supply chain entities – COC Standard (Main text) 

This section shall apply to Certificate Holders - or other entities subject to the norm ative requirements of the Schem e (e.g. included w ithin the scope of a certified due 
diligence system ) - w ithin the Country of Harvest. 

A.2a.1.1 

A.2a.1. Legal registration 
Legal 
Registration 

A.2a.1.1.1 The 
scheme shall 
include 
requirements that 
ensure the 
existence of legal 
business 
registration, and 
other relevant 

RF03 OLB CdC v3.6 

L'entreprise doit être légalement établie selon la 

1.1.1 - 
réglementation locale en vigueur, et disposer d'une copie des 
documents officiels et valides démontrant son existence légale 
(document d'immatriculation ou d'enregistrement) - à la fois généraux 
et spécifiques à son (ses)  activité(s) 

Findings 

Scheme info 

Covered 

The standard requires that companies be legally 
established and that they detain documented proof 
of their legal registration.  

Justification 

945 

 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

legally required 
licenses. 

A.2a.2 Taxes and fees  

A.2a.2.1  Payment of 

taxes, royalties 
and fees 

A.2a.2.2  Value-added 

taxes and other 
sales taxes 

A2.2.1.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
covering payment of 
all legally required 
taxes, royalties and 
fees. 

A2.2.2.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
covering different 
types of sales taxes 
that apply to the 
material being sold, 
including selling 
material as growing 
forest (standing 
stock  sales). 

RF03 OLB CdC v3.6 

1.1.4 L’ organisme est en règle vis-à-vis de ses  obligations fiscales de 
droit commun applicables ainsi que des obligations fiscales et taxes 
liées à son (ses)  activité(s) de transformateur ou négociant de bois 
(Patente, TVA, taxes et redevances liées au volume, au transport et à 
la commercialisation du bois, …)   

RF03 OLB CdC v3.6 

1.1.4 L’ organisme est en règle vis-à-vis de ses  obligations fiscales de 
droit commun applicables ainsi que des obligations fiscales et taxes 
liées à son (ses)  activité(s) de transformateur ou négociant de bois 
(Patente, TVA, taxes et redevances liées au volume, au transport et à 
la commercialisation du bois, …)   

L’entreprise s’assure  que toute transaction commerciale 

1.1.7 - 
(achat et vente) de bois se fasse en conformité avec les lois et 
règlementations nationales et internationales applicables, y compris 
celles relatives au transport et à la commercialisation des  bois. 

Covered 

Covered 

Based on the above, this indicator is covered by 
the standard. 

Findings 

Scheme info 

The standard requires that companies are in 
compliance with their legal fiscal obligations  (VAT, 
taxes and royalties related to the volume, transport 
and marketing of wood, ...)   

Justification 

Based on the above, this indicator is covered by 
the standard. 

Findings 

Scheme info 

The standard requires that companies are in 
compliance with their legal fiscal obligations  (VAT, 
taxes and royalties related to the volume, transport 
and marketing of wood, ...) and must ensure that 
all commercial transaction is in compliance with 
national and international legislation, including 
legislation related to timber commercialization and 
transport.  

Justification 

Based on the above, this indicator is covered by 
the standard. 

A.2a.3 Trade and transport 

A.2a.3.1  Classification of 

species, 

A.2a.3.1.1 The 
Scheme shall 

RF03 OLB CdC v3.6 

Findings 

Covered 

946 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

quantities, 
qualities 

include 
requirements that 
ensure compliance 
with legislation 
regulating how 
products are 
classified in terms 
of species, volumes 
and qualities in 
connection with 
trade and transport.  

A.2a.3.2 

Trade and 
transport 

A.2a.3.2.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with required 
trading permits as 
well as legally 
required transport 
documents that 
accompany 
transport of wood. 

L’entreprise s’assure  que toute transaction commerciale 

1.1.7 - 
(achat et vente) de bois se fasse en conformité avec les lois et 
règlementations nationales et internationales applicables, y compris 
celles relatives au transport et à la commercialisation des  bois. 

L'entreprise doit clairement identifier tous les produits OLB 

1.4.6 
qui sont vendus en tant que tels. Les factures de vente de produits 
OLB doivent mentionner: 

- la nature et l'essence des produits; 
- la nature des produits OLB  figurant dans leur désignation; 
- les quantités concernées (volume ou autre unité); 
- le numéro et la période de validité du certificat OLB. 
- le lien avec la référence des articles 
- le (s)  pays d'origine du bois. 

Chaque vente de produit OLB doit être accompagnée d'un 

1.4.7 
bordereau spécifique de suivi OLB mentionnant uniquement les 
produits OLB et précisant: 
- la nature et l'essence des produits; 
- les quantités concernées (volume ou autre unité); 
- le numéro et la période de validité du certificat OLB. 
- le lien avec la référence des articles 
- le (s)  pays d'origine du bois. 

RF03 OLB CdC v3.6 

L’entreprise s’assure  que toute transaction commerciale 

1.1.7 - 
(achat et vente) de bois se fasse en conformité avec les lois et 
règlementations nationales et internationales applicables, y compris 
celles relatives au transport et à la commercialisation des bois. 

947 

Scheme info 

The standard requires that organisations ensure 
that all commercial transaction is in compliance 
with national and international legislation, including 
legislation related to timber commercialization and 
transport.  

OLB certified sales and transport documents must 
include, among other requirements, species, 
volumes and qualities. 

Justification 

Based on the above, this indicator is covered by 
the standard. 

Findings 

Scheme info 

Covered 

The standard requires that organisations ensure 
that all commercial transaction is in compliance 
with national and international legislation, including 
legislation related to timber commercialization and 
transport.  

OLB certified sales must be accompanied by 
invoices and waybills. 

 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

A.2a.3.3

Offshore 
trading and 
transfer pricing 

A.2a.3.4

Customs 
regulations 

A.2a.3.3.1 The 
Scheme shall
include
requirements that
ensure compliance
with legislation
regulating offshore
trading.

A.2a.3.3.2 The 
Scheme shall
include
requirements that
ensure compliance
with legislation
regulating transfer 
pricing.

A.2a.3.4.1 The 
Scheme shall
include
requirements that
ensure compliance
with legislation
covering areas such
as export/import
licenses, and
product

RF03 OLB CdC v3.6 

L’entreprise n’est pas impliquée dans le commerce offshore 

1.1.8 - 
illégal ou dans la manipulation illégale des prix de transfert si 
applicable. 

RF03 OLB CdC v3.6 

L’entreprise n’est pas impliquée dans le commerce offshore 

1.1.8 - 
illégal ou dans la manipulation illégale des prix de transfert si 
applicable. 

RF03 OLB CdC v3.6 

L’entreprise s’assure  que toute transaction commerciale 

1.1.7 - 
(achat et vente) de bois se fasse en conformité avec les lois et 
règlementations nationales et internationales applicables, y compris 
celles relatives au transport et à la commercialisation des bois.  

948 

Justification 

Based on the above, this indicator is covered by 
the standard. 

Findings 

Scheme info 

Standard requires that organisation be not 
involved in illegal offshore trading. 

Justification 

Based on the above, this indicator is covered by 
the standard. 

Findings 

Scheme info 

Standard requires that organisation be not 
involved in illegal transfer pricing if applicable. 

Justification 

Based on the above, this indicator is covered by 
the standard. 

Findings 

Scheme info 

The standard only mentions that all “commercial 
transactions” must be in conformity with the 
applicable national and international legislation. It 
is not detailed the requirement of having 
import/export licenses, or product classifi cation 
related to customs (codes, quantities, qualities and 

Covered 

Covered 

Partially 
Covered 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

A.2a.3.5  CITES 

A.2a.3.6 

Legislation 
requiring due 
diligence / due 
care 
procedures 

classification related 
to customs (codes, 
quantities, qualities 
and species). 

A.2a.3.5.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
related to CITES 
permits (the 
Convention on 
International Trade 
in Endangered 
Species of Wild 
Fauna and Flora, 
also known as the 
Washington 
Convention). 
A.2a.3.6.1 The 
scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
covering due 
diligence/due care 
procedures, 
including e.g. due 
diligence/due care 
systems, 
declaration 

RF03 OLB CdC v3.6 

L’entreprise s’assure  que toute transaction commerciale 

1.1.7 - 
(achat et vente) de bois se fasse en conformité avec les lois et 
règlementations nationales et internationales applicables, y compris 
celles relatives au transport et à la commercialisation des boi s.  

species). 

Justification 

Part of the indicator is not met: i t is not detailed the 
requirement of having import/export licenses, or 
product classification related to customs (codes, 
quantities, qualities and species). 

Findings 

Scheme info 

Partially 
Covered 

CITES specific requirements for OLB inputs are 
not included in the chain of custody standard, but it 
is required that all commercial transaction be 
compliant with national and international laws and 
regulations, including issues related to timber 
trade and transport.  

Justification 

Based on the above, this indicator is partially 
covered by the standard. 

RF03 OLB CdC v3.6 

1.1.7 - 
L’entreprise s’assure  que toute transaction commerciale (achat 
et vente) de bois se fasse  en conformité avec les lois et règlementations 
nationales et internationales applicables, y compris celles relatives au 
transport et à la commercialisation des bois. 

1.2. Exigences relatives au système 

Organisation et responsabilités 

1.2.1  
suffisamment de compétences, de responsabilité et d'autorité pour la mise 

- L’entreprise doit nommer un membre du personnel ayant 

Findings 

Scheme info 

Partially 
Covered 

All COC companies must ensure “[…] that any 
commercial transaction (purchase and sale) of 
timber is carried out in accordance with applicable 
national and international laws and regulations, 
including those relating to the transport and 
marketing of timber.”. Section 1.2 includes 
requirements related to the system, including 
appointment of competent responsible persons, 
maintenance of documented procedures and 

949 

 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

obligations, and /or 
the keeping of trade 
related documents, 
legislation 
establishing 
procedures to 
prevent trade in 
illegally harvested 
timber and products 
derived from such 
timber, etc. 

en place et le suivi du système de Chaîne de contrôle OLB. 

record keeping.  

1.2.2 - 
responsabilités sont clairement identifiées.  

 L'entreprise doit mettre en place une organisation où les 

1.2.3 -   Chaque membre du personnel connaît et comprend ses 
propres responsabilités relatives au maintien du système de traçabilité.  

1.2.4  -   L'entreprise doit s'assurer que les employés intervenant dans la 
mise en œuvre des procédures de traçabi lité sont formés. 

Les membres du personnel participant au maintien et au suivi 

- 
des      procédures de traçabilité sont suffisamment qualifiés pour 
exécuter les tâches qui leur sont assignées. 

The company implementing a Supplier Evaluation 
program must comply with all requirements in the 
main text of the COC standard. Further details for 
non-certified inputs are provided in Annex 1, 
Supplier Evaluation Program.  

However, requirements for COC companies to 
comply with declaration obligations in the context 
of a Due Diligence/Due Care legislation are not 
included. 

Justification 

Les intervenants, les membres du personnel et les sous-

- 
traitants concernés ont été sensibilisés et formés à la mise en œuvre de 
la chaîne de contrôle. 

Based on the above, this indicator is partially 
covered by the standard. 

Système documenté 

1.2.5 -  
documenté qui répond aux exigences du présent Référentiel.  

L’entreprise doit élaborer et mettre en œuvre un système 

Traitement des réclamations 

1.2.6.- 
moyens de traitement des réclamations  

L’entreprise doit enregistrer et mettre en œuvre des 

Enregistrement 

L'entreprise doit établir et mettre en œuvre des procédures 

1.2.7 -  
adaptées à l'importance et à la complexité de ses activités pou r identifier, 
classer et sauvegarder les enregistrements qui sont nécessaires pour 
apporter la preuve du respect de la légalité et de la traçabilité de 
l'ensemble des bois à commercialiser. 

- 
Les données de production sont enregistrées et conservées. 
Elles présentent des synthèses périodiques par essence et par type de 

950 

 
  
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

produit. 

- 

Les enregistrements sont clairs et accessibles.  

- 
Les enregistrements mentionnent systématiquement le volume 
et la référence des bois ou lots de bois et permettent d'identifier l'origine 
géographique du bois avant transformation. 

NB: Il est recommandé que les enregistrements permettent d'établir la 
correspondance entre les entrées de matières premières et les sorties de 
produits finis. 

1.2.8 -  
pendant 5 ans. Les enregistrements sont mis à disposition sur demande. 

L'entreprise doit conserver ces enregistrements au minimum 

1.4.5 
- En cas d’approvisionnement en bois non certifiés, l’entreprise 
s’assure  et démontre que ceux-ci ne proviennent pas de sources illégales. 

Méthode d’évaluation : mise en place d’une diligence raisonnée voir 
ANNEXE 1 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program 

A. 
Définition du Programme d'évaluation des fournisseurs 
L'entreprise doit se conformer à minima aux exigences suivantes: 
- 
Définir et mettre en œuvre un processus en vue de 
l'évaluation régulière et de l'audit des fournisseurs de bois non 
certifiés. Ce processus  doit comprendre à minima :  
Les fréquences de l’évaluation de chaque fournisseur (Au moins une 
évaluation annuelle sur site de chaque fournisseur de bois non certifié) 
Une définition claire des compétences des employés qui réalisent les 
évaluations en respectant les dispositions relatives aux techniques 
d’audit. 
Une identification des enregistrements qui prouvent la con formité des 
fournisseurs évalués et les modalités de conservation (5 ans au 
minimum) 
La définition du contenu minimum des rapports d’évaluation avec une 
formulation claire des éventuels écarts et une précision des délais de 
résolution et la conclusion de l ’équipe d’évaluateurs. 

951 

 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

Tenir une (des) liste(s) de contrôle doit (doivent) être 

- 
élaborée(s) selon les exigences de cette annexe et approuvée par 
Bureau Veritas. 

A.2b Legal requirements for supply chain entities – COC Standard Annex 1: Supplier Evaluation Program 

This section shall apply to Certificate Holders - or other entities subj ect to the normativ e requirements of the Scheme (e.g. included w ithin the scope of a certified due dili gence system) - 
w ithin the Country  of Harv est. 

A.2b.1. Legal registration 

A.2b.1.1 

Legal 
Registration 

A.2b.1.1.1 The 
scheme shall 
include 
requirements that 
ensure the 
existence of legal 
business 
registration, and 
other relevant 
legally required 
licenses. 

A 2.2. Taxes and Fees 

A.2b.2.1  Payment of 

taxes, royalties 
and fees 

A2.2.1.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
covering payment of 
all legally required 
taxes, royalties and 
fees. 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program 

Findings 

Covered 

-Le fournisseur doit être une société exploitation forestière légalement 
établie; 

Scheme info 

The standard requires that suppliers be legally 
established.  

Justification 

Based on the above, this indicator is covered by 
the standard. 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program 

Findings 

Covered 

-Le fournisseur doit s’être acquitté de ses obligations fiscales de droit 
commun ainsi que de toutes les taxes et redevances forestières 
applicables 

Scheme info 

The standard requires that companies are in 
compliance with their legal fiscal obligations  as 
well as all forest taxes and royalties. 

Justification 

Based on the above, this indicator is covered by 
the standard. 

952 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

A.2b.2.2  Value-added 

taxes and other 
sales taxes 

A2.2.2.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
covering different 
types of sales taxes 
that apply to the 
material being sold, 
including selling 
material as growing 
forest (standing 
stock  sales). 

A 2b.3. Trade and Transport 

A.2b.3.1  Classification of 

species, 
quantities, 
qualities 

A.2b.3.1.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
regulating how 
products are 
classified in terms 
of species, volumes 
and qualities in 
connection with 
trade and transport.  

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

-Le fournisseur doit s’être acquitté de ses obligations fiscales de droit 
commun ainsi que de toutes les taxes et redevances forestières 
applicables 

Le fournisseur doit apporter la preuve du respect des lois 

- 
nationales et internationales applicables en matière de commerce et 
de transport du bois 

Scheme info 

Standard requires organisations to be in 
compliance with all their fiscal obligations, 
including taxes related to wood harvesting and 
commercialisation of timber, but does not 
specifically mention sales taxes.  

Justification 

Based on the above, this indicator is partially 
covered by the standard. 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Partially 
Covered 

Partially 
Covered 

Les prescriptions en matière d'exploitation sont respectées : 

- 
volumes autorisés, diamètres minimum, essences exploitables, 
marquage réglementaire, utilisation des documents légaux 
d’enregistrement de la récolte et de transport obligatoires, les 
essences  protégées ne sont pas récoltées ; 

- 
Le fournisseur doit apporter la preuve du respect des lois  
nationales et internationales applicables en matière de commerce et 
de transport du bois 

Scheme info 

Harvesting requirements must be respected, 
including authorized volumes, minimum diameters, 
harvestable species, regulatory marking, use of 
mandatory legal harvest registration and transport 
documents, protected species are not harvested. 

There are not specific requirements to comply with 
legislation regulating how harvested material is 
classified in terms of species, quantities and 
qualities in connection with trade and transport. 

Justification 

Part of the indicator is not met: there are not 
specific requirements to comply with legislation 
regulating how harvested material is classified in 

953 

 
 
 
 
 
 
 
 
 
 
 
 
 
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Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

A.2b.3.2 

Trade and 
transport 

A.2b.3.3  Offshore 

trading and 
transfer pricing 

A.2b.3.2.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with required 
trading permits as 
well as legally 
required transport 
documents that 
accompany 
transport of wood. 

A.2b.3.3.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
regulating offshore 
trading.  

A.2b.3.3.2 The 
Scheme shall 
include 
requirements that 

terms of species, quantities and qualities in 
connection with trade and transport. 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Covered 

Les prescriptions en matière d'exploitation sont respectées : 

- 
volumes autorisés, diamètres minimum, essences exploitables, 
marquage réglementaire, utilisation des documents légaux 
d’enregistrement de la récolte et de transport obligatoires, les 
essences  protégées ne sont pas récoltées ; 

- Le fournisseur doit apporter la preuve du respect des lois nationales 
et internationales applicables en matière de commerce et de transport 
du bois 

Scheme info 

Supplier must comply with harvesting 
requirements including the use of mandatory 
registration and transport legal documents and 
compliance with national and international 
legislation related to timber trade and transport.  

Justification 

Based on the above, this indicator is covered by 
the standard. 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Not Covered 

Le fournisseur doit apporter la preuve du respect des lois 

- 
nationales et internationales applicables en matière de commerce et 
de transport du bois 

Scheme info 

Suppliers must respect applicable national and 
international laws related to timber trade and 
transport. However, offshore trading and transfer 
pricing are not explicitly mentioned. 

Justification 

This indicator is not covered: it is not detailed how 
to prove compliance with offshore trading and 
transfer pricing. 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program  

Findings 

Not Covered 

- 
Le fournisseur doit apporter la preuve du respect des lois  
nationales et internationales applicables en matière de commerce et 

Scheme info 

954 

 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

A.2b.3.4  Customs 

regulations 

A.2b.3.5  CITES 

ensure compliance 
with legislation 
regulating transfer 
pricing. 

A.2b.3.4.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
covering areas such 
as export/import 
licenses, and 
product 
classification related 
to customs (codes, 
quantities, qualities 
and species). 

A.2b.3.5.1 The 
Scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
related to CITES 
permits (the 
Convention on 
International Trade 
in Endangered 
Species of Wild 
Fauna and Flora, 

de transport du bois 

Transfer pricing is not mentioned. 

Justification 

Transfer pricing is not included in the Supplier 
Evaluation Program. 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program 

Findings 

Partially 
Covered 

Le fournisseur doit apporter la preuve du respect des lois 

- 
nationales et internationales applicables en matière de commerce et 
de transport du bois 

Scheme info 

It is required that the supplier complies with 
applicable trade and transport legislation, but it is 
not detailed how to prove compliance with 
customs regulations.  

Justification 

Part of the indicator is not met: it is not detailed 
how to prove compliance with customs 
regulations.  

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program 

Findings 

Covered 

Les modalités de gestion des essences CITES ainsi que les 

- 
attributs des sites  dédiés à la protection ou la conservation sont 
respectés. 

The standard includes requirements to respect 
how CITES species are managed.  

Scheme info 

Justification 

Based on the above, this indicator is covered by 
the standard. 

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ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

A.2b.3.6 

Legislation 
requiring due 
diligence / due 
care 
procedures 

also known as the 
Washington 
Convention). 
A.2b.3.6.1 The 
scheme shall 
include 
requirements that 
ensure compliance 
with legislation 
covering due 
diligence/due care 
procedures, 
including e.g. due 
diligence/due care 
systems, 
declaration 
obligations, and /or 
the keeping of trade 
related documents, 
legislation 
establishing 
procedures to 
prevent trade in 
illegally harvested 
timber and products 
derived from such 
timber, etc. 

RF03 OLB CdC v3.6 

Findings 

Scheme info 

Partially 
Covered 

1.1.7 - 
L’entreprise s’assure  que toute transaction commerciale (achat 
et vente) de bois se fasse  en conformité avec les lois et règlementations 
nationales et internationales applicables, y compris celles relatives au 
transport et à la commercialisation des  bois. 

1.2. Exigences relatives au système 

Organisation et responsabilités 

- L’entreprise doit nommer un membre du personnel ayant 

1.2.1  
suffisamment de compétences, de responsabilité et d'autorité pour la mise 
en place et le suivi du système de Chaîne de contrôle OLB. 

1.2.2 - 
responsabilités sont clairement identifiées.  

 L'entreprise doit mettre en place une organisation où les 

1.2.3 -   Chaque membre du personnel connaît et comprend ses 
propres responsabilités relatives au maintien du système de traçabilité.  

1.2.4  -   L'entreprise doit s'assurer que les employés intervenant dans la 
mise en œuvre des procédures de traçabil ité sont formés. 

The company implementing a Supplier Evaluation 
program must comply with all requirements in the 
main text of the COC standard, including “[…] that 
any commercial transaction (purchase and sale) of 
timber is carried out in accordance with applicable 
national and international laws and regulations, 
including those relating to the transport and 
marketing of timber.”. Section 1.2 includes 
requirements related to the system, including 
appointment of competent responsible persons, 
maintenance of documented procedures and 
record keeping. 

Further details for non-certified inputs are provided 
in Annex 1, Supplier Evaluation Program.  

There are no requirements related to the 
implementation of a due diligence system by the 
certificate holders. 

Les membres du personnel participant au maintien et au suivi 

- 
des      procédures de traçabilité sont suffisamment qualifiés pour 
exécuter les tâches qui leur sont assignées. 

Based on the above, this indicator i s partially 
covered by the standard. 

Justification 

Les intervenants, les membres du personnel et les sous-

- 
traitants concernés ont été sensibilisés et formés à la mise en œuvre de 
la chaîne de contrôle. 

Système documenté 

1.2.5 -  

L’entreprise doit élaborer et mettre en œuvre un système 

956 

 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

documenté qui répond aux exigences du présent Référentiel. 

Traitement des réclamations 

1.2.6.- 
moyens de traitement des réclamations  

L’entreprise doit enregistrer et mettre en œuvre des 

Enregistrement 

L'entreprise doit établir et mettre en œuvre des procédures 

1.2.7 -  
adaptées à l'importance et à la complexité de ses activités pour identifier, 
classer et sauvegarder les enregistrements qui sont nécessaires pour 
apporter la preuve du respect de la légalité et de la traçabilité de 
l'ensemble des bois à commercialiser. 

- 
Les données de production sont enregistrées et conservées.
Elles présentent des synthèses périodiques par essence et par type de
produit.

- 

Les enregistrements sont clairs et accessibles.

- 
Les enregistrements mentionnent systématiquement le volume
et la référence des bois ou lots de bois et permettent d'identifier l'origine
géographique du bois avant transformation.

NB: Il est recommandé que les enregistrements permettent d'établir la 
correspondance entre les entrées de matières premières et les sorties de 
produits finis. 

1.2.8 -  
pendant 5 ans. Les enregistrements sont mis à disposition sur demande. 

L'entreprise doit conserver ces enregistrements au minimum 

1.4.5 
- En cas d’approvisionnement en bois non certifiés, l’entreprise 
s’assure  et démontre que ceux-ci ne proviennent pas de sources illégales. 

Méthode d’évaluation : mise en place d’une diligence raisonnée voir 
ANNEXE 1 

957 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Code 

Criterion 

Indicators 

Standard reference 

Findings and j ustification 

Conclusion 

RF03 OLB CoC v3.6_FR Annex 1 – Supplier Evaluation Program 

Définition du Programme d'évaluation des fournisseurs 
A. 
L'entreprise doit se conformer à minima aux exigences suivantes: 
- 
Définir et mettre en œuvre un processus en vue de 
l'évaluation régulière et de l'audit des fournisseurs de bois non 
certifiés. Ce processus  doit comprendre à minima :  
Les fréquences de l’évaluation de chaque fournisseur (Au moins une 
évaluation annuelle sur site de chaque fournisseur de bois non certifié) 
Une définition claire des compétences des employés qui réalisent les 
évaluations en respectant les dispositions relatives aux techniques 
d’audit. 
Une identification des enregistrements qui prouvent la con formité des 
fournisseurs évalués et les modalités de conservation (5 ans au 
minimum) 
La définition du contenu minimum des rapports d’évaluation avec une 
formulation claire des éventuels écarts et une précision des délais de 
résolution et la conclusion de l ’équipe d’évaluateurs. 
- 
élaborée(s) selon les exigences de cette annexe et approuvée par 
Bureau Veritas. 

Tenir une (des) liste(s) de contrôle doit (doivent) être 

A.3 Requirements for material control 

Applicable  to all types of material,  from both the FM  verified material  and material  verified under the Supplier  Verification Program 

A.3.1.1  Material 

origin 
and 
identific
ation 

A.3.1 Material control  
A.3.1.1.1 The 
Scheme shall 
require systematic 
processes  to 
enable the 
identification of the 
country of harvest 
of the material, 
and where 

RF03 OLB CdC v3.6 

L’entreprise doit tenir une liste à jour de tous les fournisseurs des bois 

1.4.1 
utilisés dans ses  groupes de produits OLB, avec les informations minimales : 
type(s) de matière fourni(s), essences  (noms communs et noms scientifiques), 
numéro du titre de provenance, pays de récolte, nature certifiée ou pas des 
produits fournis. 

Supplier Evaluation Program (for uncertified inputs in the credit system):  

Findings 

Scheme info 

Covered 

For certified inputs, only country of origin is required.  

For non-certified inputs (credit system), the evaluation 
is based at the forest management enterprise level. 

958 

 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

applicable to a 
higher level of 
detail, such as the 
sub-national 
region or 
concession level.  

A.3.1.1.2 The
Scheme shall
require systematic
processes  to
enable the
identification of the 
species included
in materials or 
products included 
in the scope of
certification. 

A.3.1.1.3 The
Scheme shall
include clear and
effective
measures to
prevent material
from non-
negligible risk,
unverified or 
potentially illegal
sources  from
entering the
supply chain and

B.

Exigences à vérifier

Lors des évaluations des fournisseurs, l'entreprise doit vérifier les exigences 
suivantes : 

Le fournisseur doit être une société exploitation forestière légalement

- 
établie;
RF03 OLB CdC v3.6 

1.3 - Définition d'un groupe de produits 

 L'entreprise doit définir des groupes de produits dont chacun 

1.3.1 - 
correspond à une gamme de produits homogènes en termes de nature et 
d'essence. 

1.3.2 -   La liste des groupes de produits OLB doit être mise à jour et 
disponible sur demande. 

1.3.3  - L'entreprise doit préciser pour chaque groupe de produits finis: 
Le type de matières premières (nature et essence);
- 
Le système de traçabilité utilisé.
- 

L’entreprise doit tenir une liste à jour de tous les fournisseurs des bois 

1.4.1 
utilisés dans ses  groupes de produits OLB, avec les informations minimales : 
type(s) de matière fourni(s), essences  (noms communs et noms scientifiques), 
numéro du titre de provenance, pays de récolte, nature certifiée ou pas des 
produits fournis. 
RF03 OLB EF Version 3.4 

3 - 

Traçabilité des bois OLB depuis la forêt 

Justification 

Based on the above, this indicator is covered by the 
standard. 

Findings 

Scheme info 

Covered 

The organisation must maintain a list of product 
groups included in the scope of the certification. For 
all supplier used in the OLB product groups, the 
following minimum information must be obtained and 
kept up-to-date:  type (s) of material supplied, species 
(common names and scientific names), harvest 
country, certified or uncertified nature of the products 
supplied. 

Justification 

Based on the above, this indicator is covered by the 
standard. 

Findings 

Scheme info 

Covered 

3.1 - 
L'entreprise doit mettre en place et documenter l'organisation 
permettant la traçabilité des bois jusqu'à leur vente ou transformation. 

Two possible traceability systems at the COC level : 

3.1.1 -  Ce système doit comprendre une identification physique et 
documentaire des bois, à tous les niveaux appropriés : exploitation forestière, 
transport, stockage et expédition.  

3.1.2 -  Ce système doit permettre de connaître l'origine géographique des 
bois, par unité ou par lot, depuis la forêt jusqu'au client, ou le cas échéant, 

- 

- 

Physical separation

Credit system

The credit system requires evaluation of uncertified 
inputs to prevent material from specified risk, 
unverified or potentially illegal sources from entering 

959 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

mixed with 
conforming 
material. 

jusqu'à l'unité de transformation.  

the supply chain and mixed with conforming material. 

3.2 - 
client, ou le cas échéant, à l'unité de transformation.  

L'entreprise doit assurer la traçabilité des bois OLB de la forêt à son 

Note: the credit system cannot be used by trade 
companies (any company that does not transform or 
process  wood). 

3.2.1 -  Des  bordereaux d'abattage sont fournis au personnel de l'entreprise 
ou de son sous-traitant qui les complète lors de chaque abattage. 

Justification 

Based on the above, this indicator is covered by the 
standard. 

3.2.2 -  Concernant le bois d'œuvre, les références des grumes / billes sont 
systématiquement marquées sur les bois abattus et reportées sur les 
bordereaux d'abattage. 
Note: 
marquées par une référence identifiant l'arbre et permettant de retrouver la 
grume qui en est issue.  

il est demandé, quand c'est possible, que les souches soient 

3.2.3 -  Concernant le bois de trituration, le référencement et/ou l'identification 
des lots de bois permettent de remonter jusqu'à la parcelle d'exploitation. 

3.2.4 -  Lors du transport des bois OLB, les bois tombés ou perdus font l'objet 
d'un suivi particulier permettant d'identifier les bois et les volumes concernés. 

Lors de l'intervention de sous-traitants ayant un impact sur la 

3.3 - 
traçabilité, l'entreprise doit assurer le maintien de la traçabilité des grumes et 
billes par ses sous-traitants (abatteurs, débardeurs, transporteurs).  

3.3.1 -  Les sous-traitants ayant un i mpact sur la traçabilité sont identifiés et 
listés. 

3.3.2 -  Lorsque cela est justifié, les sous-traitants sont formés aux exigences 
de la traçabilité afin que chaque intervenant comprenne et connaisse ses 
responsabilités spécifiques au maintien et au suivi de la traçabilité des bois 
OLB. 

3.3.3 -  L’entreprise doit mettre en place un système de contrôle du respect 
des consignes et procédures transmises aux sous-traitants. 

3.4 -  Lors d'achat externe de bois, l'entreprise doit prouver que ces bois ont 
été acquis en toute légalité 

3.4.1 
- Les documents d’achat et/ou de transport et livraison mentionnent 
toutes les informations sur l’origine du bois, telles le pays d’origine, le permis, 

960 

 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

l’AAC,  la localisation géographique du permis et les spécifications des 
produits. 

3.4.2 
- Les produits forestiers venant de fournisseurs externes non certifiés 
doivent être identifiés, au moins par marquage de chaque grume ou de chaque 
lot de bois et ne doit pas être mélangé avec des produits certifiés OLB. 

RF03 OLB CdC v3.6 

1.4.3  Vérification et validation des matières premières OLB à la réception : 
A la réception des matières premières OLB, l’entreprise doit s'assurer que les 
matières livrées correspondent à la description figurant sur les  bons de 
commande et les documents qui accompagnent la matière première 
(documents de transport , BL…) ; elle doit au minimum vérifier et valider : 

   - la nature et l'essence des produits ; 
   - le statut OLB des produits figurant dans leur désignation ; 
   - les volumes concernés ; 
   - le numéro et période de validité du certificat OLB. 

1.4.4 
de produits OLB sont éligibles et restent clairement identifiables et distinctes.  

- L'entreprise doit s'assurer que les entrées utilisées pour les groupes 

1.4.5 
s’assure  et démontre que ceux-ci ne proviennent pas de sources illégales. 

- En cas d’approvisionnement en bois non certifiés, l’entreprise 

Méthode d’évaluation : mise en place d’une diligence raisonnée voir ANNEXE 
2 

2 

- Systèmes de traçabilité 

Il existe deux systèmes de traçabilité possible, à savoir: 
o 
o 

Séparation physique 
Système de crédit  

Pour chaque groupe de produits, l'entreprise doit choisir l'un des deux 
systèmes  et le mettre en œuvre. Quel que soit le système de traçabilité utilisé, 
l’identification des produits est obligatoire le long de la chaîne de contrôle. 

961 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
A.3.1.1.4 Where 
applicable, the 
Scheme shall 
require the 
segregation and 
tracking of 
certified 
(according to each 
individual claim 
type) or verified 
legal wood along 
the supply chain, 
using appropriate 
inventory methods 
and documented 
controls where 
necessary to 
ensure that risks 
of mixing are 
identified, 
managed and 
mitigated. 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

RF03 OLB CdC v3.6 

1.4.3  Vérification et validation des matières premières OLB à la réception : 
A la réception des matières premières OLB, l’entreprise doit s'assurer que les 
matières livrées correspondent à la description figurant sur les  bons de 
commande et les documents qui accompagnent la matière première 
(documents de transport , BL…) ; elle doit au minimum vérifier et valider : 

Findings 

Scheme info 

Partially 
Covered 

The organisation must maintain records of certified 
inputs and output quantities including the following 
information:   

   - la nature et l'essence des produits ; 
   - le statut OLB des produits figurant dans leur désignation ; 
   - les volumes concernés ; 
   - le numéro et période de validité du certificat OLB. 

1.4.4 
de produits OLB sont éligibles et restent clairement identifiables et distinctes. 

- L'entreprise doit s'assurer que les entrées utilisées pour les groupes 

- En cas d’approvisionnement en bois non certifiés, l’entreprise 

1.4.5 
s’assure  et démontre que ceux-ci ne proviennent pas de sources illégales. 

- received and approved inputs. 
- inputs used in production  
- inputs still in stock 
- outputs (production) 
- outputs sold 
 - outputs still in stock 

The standard includes requirements to ensure the 
chain of custody using two possible systems:  

 - Physical separation 

Méthode d’évaluation : mise en place d’une diligence raisonnée voir ANNEXE 
2 

 - Credit system 

However, the CoC system  does not include any 
validation of volumes transferred from seller to 
purchaser, which is considered as a major gap in the 
system. 

Justification 

Based on the above, this indicator is partially covered 
by the standard. CoC verification does not include any 
validation of volumes transferred from seller to 
purchaser, which is considered as a major gap in the 
system. 

1.4.10 - Un registre des quantités de matières doit être tenu à jour. 

1.4.11 - L'entreprise doit tenir et mettre à disposition des registres de suivi des 
quantités des entrées et des sorties  incluant les informations suivantes: 

- les entrées réceptionnées et approuvées; 
- les entrées ayant servi dans la production (utilisées) 
- les entrées encore en stock 
- les sorties (production) 
- les sorties vendues 
- les sorties encore en stock 

Le système de séparation physique est utilisé dans la production des groupes de 
produit OLB à partir des matières en entrée de mêmes catégories.  

Le système de séparation physique n’admet pas d’entrée de groupe de produit 
constituée de matières de catégori es différentes de l’OLB et autres schémas 
reconnus  

962 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Le système de séparation physique est applicable pour tout type de groupe de 
produits et d’activité.  

Identification 

2.2.1 - Les produits certifiés, indépendamment de leur niveau de transformation, 
sont identifiés de façon unitaire. 

2.2.2 - A chaque fois que c'est possible, cette identification doit permettre de partir 
du produit et remonter jusqu'à l'origine de la matière première certifiée. 

2.2.3 -  A chaque fois que c'est possible, les approvisionnements, la production en 
cours et les produits finis certifiés font l'objet d'un marquage physique. 

Ségrégation 

2.2.4 - Les approvisionnements certifiés sont stockés  séparément des 
approvisionnements non certifiés. 

2.2.5 - L'en-cours utilisant des matières premières certifiées est séparé des autres 
en-cours, dans l'espace ou dans le temps. 

2.2.6 - Les produits finis certifiés sont stockés  séparément des autres produits finis. 

NB: Ces  deux méthodes (identification et ségrégation)  peuvent être utilisées 
de façon conjointe. 

2.3.1 - Lors de l'achat de bois non certifié devant être intégré dans une 
production OLB, l'entreprise doit acheter uniquement du bois provenant de 
sources  acceptables. 

2.3.2 -  Le bois provenant de sources acceptables doivent être soit: 
- couverts par le «programme d'évaluation fournisseurs»: voir Annexe 1  
- couverts par l'un des programmes de vérification reconnus par l'OLB  

2.3.3 - La conformité du programme d'évaluation fournisseurs mis en place doit 
être démontrée par l’entreprise, conformément aux prescriptions de l'annexe 1. 
Bureau Veritas se réserve le droit d'effectuer si nécessaire des vérifications 
chez les fournisseurs  de bois acceptable 

963 

 
 
 
 
 
 
  
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

2.3.4 - Les fournisseurs de bois acceptables sont conscients d'une potentielle 
visite de l'équipe d'audit et l'ont acceptée. 

2.3.5 - Pour le bois qui ne peut pas être classé comme provenant de « sources 
acceptable», l'entreprise doit mettre en place un système de traçabilité de 
manière à s'assurer qu'il n'est pas mélangé au bois acceptable o u au bois 
OLB. 

2.3.6 - Les approvisionnements OLB  qui entrent dans la production sont 
portés au compte de crédit. 

2.3.7 - L'entreprise déduit du compte les quantités de produits qui sont vendus 
en tant que produits OLB.  

2.3.8 -L'entreprise doit fixer un délai pour la gestion (addition et déduction de 
crédit OLB) de ses  comptes de crédit (3 mois au maximum)  

2.3.9 - L’entreprise doit créditer le compte de crédit OLB après avoir 
réceptionné la matière et avant qu'elle n'entre dans le processus de 
production. 

2.3.11 - Le crédit à la production OLB qui n'est pas utilisé pendant la période 
de crédit peut ensuite être reporté sur les mois suivants, dans un délai 
maximum de 12 mois.  

2.3.12 - A la fin du 12ième   mois, tout crédit à la production OLB qui n 'est pas 
utilisé est perdu. 

A.3.2 Recycled m aterial  

A.3.2.1  Waste 

material 

N/A 

A.3.2.1.1 The 
Scheme shall 
have a definition 
of waste  material 
which at least 
covers the 
definition of waste 
material as 
described by the 
EUTR Guidance 
document. 

Findings 

Scheme info 

Not Covered 

Reclaimed material is not covered by the scheme) 

Justification 

N/A 

964 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
N/A 

N/A 

A.3.2.1.2 The 
Scheme shall 
require systematic 
processes  to 
enable the 
identification of 
waste material 
that has 
completed its life 
cycle and to 
differentiate this 
material from 
virgin or material 
that are by-
products of a 
manufacturing 
process  which has 
not completed its 
lifecycle as 
defined by the 
EUTR. 

A.3.2.1.3 The 
Scheme shall include 
clear and effective 
measures to prevent 
“timber products of a 
kind covered by the 
Annex of the EUTR”, 
produced from i) 
reclaimed material 
that has NOT 
completed its 
lifecycle and would 
otherwise have been 
discarded as waste”, 
ii) unverified or iii) 
virgin material (as 
defined by the EUTR) 
from, entering the 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Findings 

Scheme info 

Not 
Covered 

Reclaimed material is not covered by the scheme) 

Justification 

N/A 

Findings 

Scheme info 

Not 
Covered 

Reclaimed material is not covered by the scheme) 

Justification 

N/A 

965 

 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

supply chain.  

A.4 General requirements for Certificate Holders 

Findings 

Scheme info 

Partially 
Covered 

The Forest Enterprise shall implement appropriate 
measures to prevent and find solutions to conflicts 
related to tenure and customary rights.  

These procedures must be implemented objectively, 
constructively, and documented. Documents include a 
complete and up-to-date record of conflicts and 
grievances against the company including evidence of 
actions taken to resolve them. 

There is no requirement to excluded areas where 
tenure is disputed  (point ii). 

Justification 

Based on the above, this indicator is partially covered 
by the standard. 

A.4.1 

Conflict 
resolutio
n 

A.4.1.1 The 
Scheme shall 
include 
requirements that 
ensure that 
disputes are 
identified, 
recorded and 
managed, in a 
way that: 

i) ensures  there is 
a transparent 
ongoing process 
to address the 
issue 
ii) requires for the 
exclusion from the 
scope of the 
certificate 
situations or areas 
or forest where the 
legality of tenure 
or 
management/harv
esting is not 
defined or is 
unclear and 
disputed. 
iii ensures respect 
for legally-
enshrined 
customary tenure 
rights of local 
communities. 

RF03 OLB EF Version 3.4 

1.3.7 -  Des  mécanismes et des mesures appropriés doivent être employés 
pour prévenir et rechercher des solutions aux conflits relatifs aux droits fonciers 
(propriété) et aux droits d'usage d'usages (accès aux ressources). 

Les procédures élaborées pour la prévention et la gestion des conflits 

Il existe des procédures écrites basées sur la législation nationale 

i. 
et/ou les règles coutumières, pour la prévention et la gestion des conflits et des 
dégâts dans les cas de perte ou de dommages affectant les propriétés, les 
ressources,  la santé et les conditions de subsistance des populations locales, y 
compris les peuples autochtones.  
ii. 
et la réparation des dégâts dans les cas  de pertes ou de dommages affectant 
les propriétés, les ressources  et les conditions de subsistance des populations 
locales et autochtones doivent être mises en application de manière objective, 
constructive, et documentée. 
iii. 
l’entreprise est tenu, enregistré et archivé, comprenant la documentation y 
afférente, et les preuves des actions prises pour les résoudre. 

Un dossier complet et actualisé des conflits et griefs contre 

RF03 OLB CdC v3.6 

1.2.6.- 
moyens de traitement des réclamations  

L’entreprise doit enregistrer et mettre en œuvre des 

966 

 
 
 
 
 
 
 
 
  
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Findings 

Scheme info 

Covered 

It is required that the Forest Management Enterprise be 
not involved in controversial activities or practices that 
may impair its legal integrity. 

COC certificate holders « do not participate in an activity 
or is released in a practice likely to give rise to 
controversies and legal requirements ». 

Justification 

Based on the above, this indicator is covered by the 
standard. 

A.4.2 

Corrupti
on  

A.4.1.2 The scheme 
shall include 
requirements to 
ensure that certificate 
holders do not 
engage in corrupt 
practices related to 
illegal harvesting. 

RF03 OLB EF Version 3.4 

L'entreprise doit être légalement établie selon les dispositions 

1.1 - 
réglementaires locales en vigueur, en conformité avec les exigences du (des) 
secteur(s)  d'activité dans le(s)quel(s) elle exerce, et à jour de ses obligations 
fiscales. 

L'entreprise dispose des documents officiels et valides d'existence 

1.1.1 - 
légale (document d'immatriculation ou d'enregistrement), généraux et 
spécifiques à son (ses)  activité(s). 

L'entreprise respecte les exigences du (des) secteur(s)  d'activité dans 

1.1.2 - 
le(s)quel(s) elle exerce (si elles existent, dans une convention collective ou un 
syndicat par exemple) * 

1.1.3 - 
L’entité forestière est en règle vis-à-vis de ses obligations fiscales de 
droit commun applicables, ainsi que de ses obligations fiscales et taxes liées à 
son (ses)  activité(s) forestières (Patente, TVA, taxes et redevance liées à la 
récolte du bois, au volume, au transport et à la commercialisation du bois, …)   

1.1.4 - 
portant à controverse et pouvant porter atteinte à son intégrité légale* 

L'entreprise n'est pas impliquée dans des activités ou des pratiques 

RF03 OLB CdC v3.6 

L'entreprise doit être légalement établie selon la réglementation locale 

1.1.1 - 
en vigueur, et disposer d'une copie des documents officiels et valides 
démontrant son existence légale (document d'immatriculation ou 
d'enregistrement) - à la fois généraux et spécifiques à son (ses)  activité(s) 

L’entreprise respecte les exigences juridiques du (des) secteur(s) 

1.1.2 - 
d'activité dans le(s)quel(s) elle exerce (le cas échéant, les exigences juridiques 
ou contractuelles définies dans les conventions collectives ou par un syndicat 
par exemple). 

1.1.3 - 
des traités internationaux en matière de sécurité et environnement. 

L'entreprise respecte les lois nationales et les obligations découlant 

 L’ organisme est en règle vis-à-vis de ses  obligations fiscales de droit 

1.1.4 - 
commun applicables ainsi que des obligations fiscales et taxes liées à son (ses) 
activité(s) de transformateur ou négociant de bois (Patente, TVA, taxes et 

967 

 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

redevances liées au volume, au transport et à la commercialisation du bois, ....)   

 L’entreprise ne participe pas à une activité ou ne se livre pas à une 

1.1.5 - 
pratique susceptible de donner lieu à des controverses et l'empêcher de 
respecter les exigences juridiques. 

A.5 Quality and procedural requirements for Certificate Holders 

RF03 OLB EF Version 3.4 

4.2.1 - 
permettant de répondre aux exigences du présent référentiel. 

L'entreprise doit établir et mettre en œuvre un système documenté 

RF03 OLB CdC v3.6 

1.2.5 -  
qui répond aux exigences du présent Référentiel. 

L’entreprise doit élaborer et mettre en œuvre un système documenté 

A.5.1 

Internal 
procedu
res  for 
Certifica
te 
Holders 

A.5.1.1 The 
Scheme shall 
include 
requirements for 
the Certificate 
Holders to have in 
place - and 
implement - 
systems  and 
procedures 
covering all 
requirements of 
the Scheme. 

A.5.1.2 The 
Scheme shall 
include 
requirements for 
the Certificate 
Holders to 
regularly review 
the proper 
functioning of their 
own procedures. 

Findings 

Scheme info 

Both FM and COC standards require organisations to 
develop and implement a documented system to 
cover the requirements of the FM and COC standard, 
respectively. 

Justification 

Based on the above, this indicator is covered by the 
standard. 

Findings 

Scheme info 

This requirement is not specified in the FM or COC 
standard.  

Justification 

This is not included in the FM or COC standard.  

A.5.2 

Qualific
ation 
and 
compete
nce 

A.5.2.1 The 
Scheme shall 
include 
requirements that 
ensure that 
certified 
organisations 

RF03 OLB EF Version 3.4 

4.1.1 - 
L'entreprise doit nommer un membre du personnel qui a les 
compétences, la responsabilité et l'autorité suffisantes pour la mise en place et 
le suivi de l'organisation nécessaire au respect des exigences de ce référentiel.  

Note: 

il est recommandé d'attribuer la responsabilité de la traçabilité à un 

Findings 

Scheme info 

Both FM and COC standards include requirements to 
ensure that there is an appointed responsible person 
with overall responsibility to implement the 

968 

Covered 

Not 
Covered 

Covered 

 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

have personnel 
with sufficient 
qualifications and 
competencies to 
implement 
Scheme 
requirements 
consistently and 
effectively. 

autre membre du personnel 

requirements of the standard, and that other staff 
involved are adequately trained and competent.   

4.1.2 - 
responsabilités sont identifiées et les tâches clairement définies. 

L'entreprise doit mettre en place une organisation où les 

Justification 

4.1.3 -  Chaque membre du personnel connaît et comprend ses 
responsabilités spécifiques concernant le respect de la légalité et le maintien de 
la traçabilité des bois. 

This requirement is not specified in the FM or COC 
standard.  

4.1.4 - 
système mis en place. 

L'entreprise doit assurer la formation du personnel intervenant dans le 

Les membres du personnel intervenant dans le maintien du respect 

i. 
de la légalité et de la traçabilité des bois ont la qualification nécessaire pour 
effectuer les travaux qui leur sont confiés.  
ii. 
informés ou formés à la mise en œuvre du système. 

Les intervenants, personnels et sous-traitants pertinents ont été 

RF03 OLB CdC v3.6 

1.2.1  
- L’entreprise doit nommer un membre du personnel ayant 
suffisamment de compétences, de responsabilité et d'autorité pour la mise en 
place et le suivi du système de Chaîne de contrôle OLB. 

1.2.2 - 
responsabilités sont clairement identifiées.  

 L'entreprise doit mettre en place une organisation où les 

1.2.3 -   Chaque membre du personnel connaît et comprend ses propres 
responsabilités relatives au maintien du système de traçabilité.  

1.2.4  -   L'entreprise doit s'assurer que les employés intervenant dans la mise 
en œuvre des procédures de traçabilité sont formés. 

Les membres du personnel participant au maintien et au suivi des  

- 
procédures de traçabilité sont suffisamment qualifiés pour exécuter les tâches 
qui leur sont assignées. 
- 
concernés ont été sensibilisés et formés à la mise en œuvre de la chaîne de 
contrôle. 

Les intervenants, les membres du personnel et les sous-traitants 

969 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
A.5.3 

Risk 
based 
approac
hes to 
sourcing
, trade 
or 
producti
on 

A.5.3.1 If the Scheme 
includes an option to 
implement a risk-
based approach to 
sourcing non-certified 
material (Due 
Diligence System), it 
shall: i) contain clear 
requirements and ii) 
ensure consistent 
implementation of the 
Due Diligence 
System, for all 
activities, materials 
and suppliers 
included within the 
scope of the 
certification. 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

RF03 OLB CdC v3.6 

Annex 1 

Findings 

Scheme info 

Not 
Applicable 

The COC standard accepts the use of a credit 
system, where non-certified inputs are evaluated to 
ensure illegal sources are excluded.  

The criteria are listed and complete, however there 
are not clear indicators and/or guidance to ensure that 
all certificate holders and auditors interpret the 
requirements consistently. 

It is not considered that this system is a “due diligence 
system”  as it is not risk  based, but rather a first party 
verification system within the scheme. 

Justification 

Part of the indicator is not met: there are not clear 
indicators and/or guidance to ensure that the 
requirements are evaluated consistently. 

A.5.3.2 The 
Scheme shall 
include 
requirements that 
ensure that 
whenever there is 
a change in the 
risk  related to 
illegal harvest, 
trade or transport 
in a supply chain – 
or a supply chain 
covered by a DDS 
– the risk  shall be 
assessed  and 
mitigated prior to 

RF03 OLB CdC v3.6 

1.3.2 -  
disponible sur demande. 

La liste des groupes de produits OLB doit être mise à jour et 

L’entreprise doit tenir une liste à jour de tous les fournisseurs des bois 

1.4.1 
utilisés dans ses  groupes de produits OLB, avec les informations minimales : 
type(s) de matière fourni(s), essences  (noms communs et noms scientifiques), 
numéro du titre de provenance, pays de récolte, nature certifiée ou pas des 
produits fournis. 

2.3.1 - Lors de l'achat de bois non certifié devant être intégré dans une 
production OLB, l'entreprise doit acheter uniquement du bois provenant de 
sources  acceptables. 

2.3.2 -  Le bois provenant de sources acceptables doivent être soit: 

Findings 

Scheme info 

Not 
Applicable 

The scheme requires that the information regarding 
inputs is “up to date”, and that every time there is a 
purchase of non-certified material, this material is 
evaluated and in conformance with the requirements 
of the Supplier Evaluation Program in Annex 1.  

It is not considered that this system is a “due diligence 
system”  as it is not risk  based, but rather a first party 
verification system within the scheme. 

Justification 

Based on the above, this indicator is not applicable. 

970 

 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

shipping and sale. 

- couverts par le «programme d'évaluation fournisseurs»: voir Annexe 1  
- couverts par l'un des programmes de vérification reconnus par l'OLB 

Annexe 1 : Programme d'évaluation des fournisseurs 

A. 
Définition du Programme d'évaluation des fournisseurs 
L'entreprise doit se conformer à minima aux exigences suivantes: 

Définir et mettre en œuvre un processus en vue de l'évaluation 

- 
régulière et de l'audit des fournisseurs de bois non certifiés. Ce processus  doit 
comprendre à minima :  
Les fréquences de l’évaluation de chaque fournisseur (Au moins une évaluation 
annuelle sur site de chaque fournisseur de bois non certifié) 
Une définition claire des compétences des employés qui réalisent les 
évaluations en respectant les dispositions relatives aux techniques d’audit. 
Une identification des enregistrements qui prouvent la conformité d es 
fournisseurs évalués et les modalités de conservation (5 ans au minimum) 
La définition du contenu minimum des rapports d’évaluation avec une 
formulation claire des éventuels écarts et une précision des délais de résolution 
et la conclusion de l’équipe d’évaluateurs. 

- 
selon les exigences de cette annexe et approuvée par Bureau Veritas. 

Tenir une (des) liste(s) de contrôle doit (doivent) être élaborée(s) 

A.5.3.3 In cases 
where other 3rd 
party schemes 
permitted to be 
used by the due 
diligence system 
as meeting 
specific due 
diligence 
requirements, the 
scheme shall 
include 
requirements that 
ensure that it is 
clear: 
i) on what basis 
recognition is 

RF03 OLB CdC v3.6 

Findings 

Annexe 2 : Programmes de vérification reconnus par le système OLB  

Scheme info 

Partially 
Covered 

Pour  le  choix  des  programmes  repris  ci -dessous  Bureau  Veritas  Certification 
France s’est  basé sur les critères d’évaluation de légalité adoptés par : Keurhout, le 
CPET  du gouvernement britannique et l’ « Assessment of Legality Verification 
Schemes » du gouvernement danois.   

En  cas  de  contradiction  entre  les  résultats  de  ces  évaluations,  Bureau Veritas 
Certification France a choisi de le retenir le plus exigent.  

Le choix des programmes ci -dessous repris par Bureau Veritas Certification France 
repose sur les systèmes reconnus dans le cadre de la Charte Enviro nn e me n t al e 
pour l’activité forestière et par le PEFC international 

The OLB standard does allow for material certified 
against other scheme to be include das OLB certified. 

The scheme includes a list of certification systems 
accepted as inputs and that after transformation may 
be sold as OLB, and a second list of schemes that 
may be used as acceptable sources in the credit 
system (and that therefore do not need to go through 
all the requirements of the Supplier Evaluation 
Program in Annex 1) 

The criteria to accept these systems, and how it is 
verified that other Schemes ensure conformance with 

971 

 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

the specific due diligence requirements, is explained 
in Annex 2 of the FSC COC standard: “[…]was based 
on the legality assessment criteria adopted by: 
Keurhout, the UK government's CPET and the Danish 
government's Assessment of Legality Verification 
Schemes.”  

However, there is not a detailed procedure for BV to 
internally evaluate certification systems – or other 
parties’ procedures to evaluate certification systems - 
against specific due diligence requirements such as 
the EUTR.  

Justification 

Part of the indicator is not met: there is not a 
procedure requirements to verify how other Schemes 
ensure conformance with the specific due diligence 
requirements. . 

made and;  
ii) how it is verified 
that other 
Schemes ensure 
conformance with 
the specific due 
diligence 
requirements. 

Keurhout Legality and/ or Sustainability 
FSC 
PEFC – Allemagne, Australie, Autriche, Biélorussie, Belgique, République 
Tchèque, Danemark, Espagne, Estonie, Finlande, France, Hongrie, Ireland, 
Italie, Lettonie, Luxembourg, Norvège, Pays-Bas, Pologne, Portugal, Roumanie, 
Russie, Slovaquie,  Slovénie, Suède, Suisse, UK, Uruguay  
SFI – Canada - USA 
CSA – Canada 
ATFS - USA 
MTCC – Malaisie  
CERFOAR - Argentine 
CERFLOR - Brésil 
CERTFOR - Chili 
CFCC  - Chine 
PAFC -  Gabon 
NCCF  - Inde 
IFCC – Indonésie  
LEI - Indonésie 
SGEC - Japon 
NZFCA – Nouvelle Zélande  
KoFPI – République de Corée  
SAFAS – Afrique du Sud 
F.T.I – Thailande 
VNFOREST- Vietnam 
PAFC – Cameroun 
KHEUROUT – Pays Bas 

Bois de sources acceptables pour la méthode de crédit uniquement : 
Legalsource TM 
BV DDS 

Seul les bois couverts par un des programmes de vérification/certification repris 
dans la liste ci-dessus sont considérés comme « bois acceptables » par le 
système OLB.  

La liste mise à jour est disponible sur le site www.bureauveritas.com/ 

A.5.3.4 The 
Scheme shall 
include 

RF03 OLB CdC v3.6 

Findings 

Annexe 1 : Programme d'évaluation des fournisseurs 

Not 
Applicable 

972 

 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

requirements to 
ensure that the 
DDS comprises, at 
a minimum, the 
following 
elements: i) a 
quality 
management 
system, ii) 
procedures for 
obtaining access 
to information 
pertinent to the 
identification of 
risk;  iii) risk 
assessments,  and 
iv) the 
implementation of 
mitigations 
measures when 
risks  are identified. 

L’équipe d’audit devra vérifier la consistance et la fiabilité de ce programme 
d’évaluation fournisseur et émettre au besoin, des non-conformités mineures ou 
majeures à l’endroit de l’entreprise évaluée pour la conformité aux exigences ci -
dessous. 

A. 
Définition du Programme d'évaluation des fournisseurs 
L'entreprise doit se conformer à minima aux exigences suivantes: 

Définir et mettre en œuvre un processus en vue de l'évaluation 

- 
régulière et de l'audit des fournisseurs de bois non certifiés. Ce processus  doit 
comprendre à minima :  
Les fréquences de l’évaluation de chaque fournisseur (Au moins une évaluation 
annuelle sur site de chaque fournisseur de bois non certifié) 
Une définition claire des compétences des employés qui réalisent les 
évaluations en respectant les dispositions relatives aux techniques d’audit. 
Une identification des enregistrements qui prouvent la conformité des 
fournisseurs évalués et les modalités de conservation (5 ans au minimum) 
La définition du contenu minimum des rapports d’évaluation avec une 
formulation claire des éventuels écarts et une précision des délais de résolu tion 
et la conclusion de l’équipe d’évaluateurs. 

- 
selon les exigences de cette annexe et approuvée par Bureau Veritas. 

Tenir une (des) liste(s) de contrôle doit (doivent) être élaborée(s) 

Scheme info 

Annex 1 of the CoC standard includes the 
requirements to implement verification of non-certified 
inputs. It requires that the CH defines a system for a 
regular evaluation of the supplier, and that the 
employees that perform this evaluation (“assessors”) 
must be duly competent.  

It is not considered that this system is a “due diligence 
system”  as it is not risk  based, but rather a first party 
verification system within the scheme. 

Justification 

Based on the above, this indicator is not applicable. 

B. Requirements for Certification Bodies 

Scheme requirements for Certification Bodies shall be clear and unambiguous and allow the Scheme  owner to verify the level o f conformance of each Certification Body to these requirements. 

B.1 General Certification Body requirements 

B.1.1 

Comp
etenc
e and 
qualifi
cation
s 

B.1.1.1 The 
Scheme shall 
have mechanisms 
to ensure that 
auditors, and other 
relevant personnel 
of the Certification 

PL-CAM-CER-002 rev1.3.,  

9.1, Qualification des auditeurs 
Bureau Veritas Douala fait appel à des spécialistes de la filière Forêt-Bois, en 
privilégiant les points suivants :  

- La connaissance professionnelle de la filière bois  

Findings 

Scheme info 

Covered 

According to PL-CAM-CER-002 rev1.3., 9.1, PL-
CAM-CER-014 V2.4_GP01 OLB CoC 9.1 auditors 
conducting FM and CoC audits should be qualified 

973 

 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Body, are qualified 
and competent to 
evaluate 
organisations’ 
compliance with 
specific Scheme 
requirements. 

- L'expertise dans les techniques et procédés de gestion forestière.  
La sélection, la qualification et le suivi des auditeurs pour la certification OLB 
sont assurés  suivant une procédure spécifique interne de Bureau Veritas 
Douala. Globalement, les responsables d'audit de Bureau Veritas Douala 
doivent:  

and to have competence on the standard 
requirements. ISO standards are not used as based 
to build the auditor's competence.  

Justification 

- Prouver la compétence technique et une expérience professionnelle dans 
l'industrie forestière  

- Avoir suivi la formation spécifique d'auditeur pour les techniques d'audit et 
l'évaluation du référentiel OLB avoir réalisé au moins trois audits de terrain  

OLB did not rely on ISO to prepare the competence of 
auditors. OLB developed an internal standard to 
explain the requirements for auditors. As the standard 
is comprehensive and includes all requirements of 
this indicator, the conclusion is covered. 

- Enfin les auditeurs de Bureau Veritas Douala sont sélectionnés pour réaliser 
les audits selon les critères suivants  

> La compétence selon le type de forêt évaluée  

> La disponibilité pour l'audit programmé  

> L'indépendance.  

Les auditeurs de Bureau Veritas Douala privilégient une approche terrain et 
pragmatique. Leur priorité est d'évaluer le système OLB mis en place dans 
l'entreprise comme un outil permettant à l'entité candidate de maîtriser ses 
activités et de les améliorer. 

PL-CAM-CER-014 V2.4_GP01 OLB CoC,9.1, Auditor’s qualification 

Bureau Veritas Douala recruits as auditors only specialists from the timber 
industry in order to ensure the following: 

- Independence  

- Thorough knowledge of the industry, and of the process and industrial 
techniques Additionally, to be considered as a BV  

Certification auditor, these specialists shall: 

- 

- 

demonstrate technical competence and professional experience in the 
specific industry sector 
have followed a specific auditing training and training on the OLB standard 
- Have validated that training by having achieved at least three audits  

974 

 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Finally, Bureau Veritas Certification specialized auditors are appointed for 
certification audits according to the following three criteria: 

- 
- 
- 

Knowledge of the Company's industry sector. 
Based as close as possible to the Company's offices  
Availability on the audit dates proposed  

BV Certification auditor promote a pragmatic and efficient approach. Priority is 
given to the evaluation of the OLB Chain of Custody system as a tool allowing 
the company to better manage its activities and to improve its processes. 

Findings 

Scheme info 

Not 
Applicable 

Due Diligence System is not included in the OLB 
certification.  

Justification 

Not applicable 

https://certification.bureauveritas.com/who-we-are/our-resources/impartiality 

Findings 

Covered 

PL-CAM-CER-002 rev1.3., 9.1 Qualification des auditeurs 
… 
- Enfin les auditeurs de Bureau Veritas Douala sont sélectionnés pour réaliser 
les audits selon les critères suivants: 
… 

- L'indépendance.  

… 

Scheme info 

The scheme owner (Bureau Veritas) includes a policy 
related to impartiality for all certification service that 
they are providing. In addition, PL-CAM-CER-002 
rev1.3., 9.1 and PL-CAM-CER-014 V2.4_GP01 OLB 
CoC 9.1 state that Bureau Veritas recruits only 
specialist that are independent. 

975 

B.1.1.2 If the 
Scheme includes 
an option for the 
Certificate Holder 
to implement a 
Due Diligence 
System, the 
scheme shall 
ensure that the 
auditors and other 
relevant personnel 
of the Certification 
Body are qualified 
and competent to 
evaluate 
organisations’ 
compliance with 
related Scheme 
requirements. 
B.1.2.1 The 
scheme shall 
include 
requirements to 
ensure that 
auditors, and other 
personnel relevant 
to the 
conformance 
evaluation of an 
organisation shall 
be impartial to the 

B.1.2 

Impart
iality 

 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

entity(-ies) under 
evaluation. 

PL-CAM-CER-014 V2.4_GP01 OLB CoC 9.1, Auditor’s qualification 

Justification 

Bureau Veritas Douala recruits as auditors only specialists from the timber 
industry in order to ensure the following: 

Based on the above, this indicator is covered by the 
scheme. 

Findings 

Scheme info 

Covered 

According to PL-CAM-CER-002 rev1.3., 13.1 and PL-
CAM-CER-014 V2.4_GP01 OLB CoC 13.1 the 
certification decision is made by Wood and Forestry 
Department Manager for FM and CoC. Certification 
Committee is established for FM and COC. For FM, 
based on findings, the Committee may request an 
additional on-site assessment.  

Justification 

Based on the above, this indicator is covered by the 
scheme. 

B.1.2.2 The 
Scheme shall 
include 
requirements that 
ensure that the 
certification 
decision process 
is;  
i) well defined and; 
ii) ensures that the 
decision on 
certification is 
conducted by 
positions/bodies 
that are impartial 
to the auditee. 

- Independence  

PL-CAM-CER-002 rev1.3.,  

13.1 DECISION DE CERTIFICATION  

Sur la base du rapport d'audit initial, des commentaires du candidat à la 
certification, la décision de certification est prise lors d'une réunion du Comité de 
certification dans un délai de deux mois après réception de tous ces documents.  

Avant de prendre la décision de certification, le Comité de certification peut 
demander un audit complémentaire afin de clarifier certaines parties.  

La décision de certification est prise par le Responsable du Département Forêt 
Bois sur  la base des éléments contenus dans le rapport final d'audit et après 
avoir reçu les preuves que toutes les non-conformités majeures ont été fermées 
et que l'entreprise est en conformité avec les exigences du référentiel.  

Le Comité d'impartialité de Bureau Veritas Douala se réuni une fois par an et 
une fois par an et analyse un échantillon de dossiers de certification OLB, puis 
émet des commentaires et recommandations afin d'améliorer la performance de 
Bureau Veritas.  

Le Comité d'impartialité est composé de personnes de référence dans toutes 
les composantes relatives à la certification et la gestion forestière responsable 
(ONG environnementales et sociales, associations, entreprise, etc.). Le rôle du 
Comité d'impartialité est de s'assurer  de la performance, de l'intégrité et de la 
crédibilité du système du Département Forêt-Bois de Bureau Veritas Douala. 

PL-CAM-CER-014 V2.4_GP01 OLB CoC  

13.1. CERTIFICATION DECISION  

The certification decision is made by the Wood and Forestry Department 
Manager (WFD) based on the audit findings as reported in the final audit report 

976 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

and after having received evidence that all major nonconformities have been 
closed and that the company is in conformity with the standard requirements.  

Bureau Veritas impartiality Committee meets once a year and a sample  of 
certification files are randomly taken for evaluation and comments in order to 
improve Bureau Veritas' performance. Bureau Veritas Certification Committee is 
made of personalities from all fields related to certification and responsible forest 
management and wood industry (environmental and social NGOs, associations, 
companies, etc).  

The role of the Committee is to ensure the performance, integrity and credibility 
of Bureau Veritas Certification - Wood and Forestry Department's system. The 
time limit between the initial audit and awarding the certificate granting is 
estimated at around 03 months, but this delay may be shorter in case of a clear 
and justified request by the applicant. 

B.2 Certification Body requirements for auditing and certification 

B.2.1 

Auditi
ng 
proce
ss 

B.2.1.1 The 
Scheme shall 
include 
requirements that 
ensure that 
Certification 
Bodies apply a 
documented 
methodology for 
the evaluation 
(assessments  and 
audits) of clients.  

Specific Instructions OLB: Chain of Custody and Forestry Companies 
Certification process  

Findings 

Scheme info 

1. Subject and application scope  

Covered 

The present instructions detail the specific requirements for implementing OLB 
certification of Forestry  
Companies and of OLB timber chain of custody, including the following 
documents:  

- RF03 OLB Forestry  Companies  

- RF03 OLB COC  

- RF03 OLB+ COC  

- DO100901 Scheme approved by OLB  

- RF03 OLB Multisite  

977 

The only certification body of the OLB scheme is the 
owner of the standard (Bureau Veritas). 

Auditors and other staff involved in the certification 
process  must follow the general procedure (Specific 
Instructions OLB: Chain of Custody and Forestry 
Companies Certification process), describing the 
process  from the proposal stage until the issuance of 
the certificate, including auditor qualifications and 
audit process.  

In addition, BV follows specific instructions for FM 
(GP01-OLB-EF) and COC certification (GP01-OLB-
COC). 

Justification 

Based on the above, this indicator is covered by the 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

B.2.1.2 As a 
minimum, this 
methodology shall 
include 
procedures for the 
following activities: 
i) Evaluation of 
conformity of 
organisations to 
the Schemes (e.g. 
audit of sites, or 
inspection of 
records or of self-
assessment 
declarations); 
ii) Review and 
certification 
decision; 
iii) Issuance of a 
certificate; and 
iv)  Periodic re-
assessment. 

- RF03 OLB graphic chart  

Specific Instructions OLB: Chain of Custody and Forestry Companies  
Certification process 

3. Audit Process  

1.1  Processing applications, proposal and contract  

… 

1.2  Documentary Review 

… 

3.3 Audit length 

The duration of audits are defined or validated by the WFD Manager or the OLB 
product manager who issues or  
approves the proposal. For OLB COC certification the m inimum duration is half 
a day.   
But in any case The duration varies according to the company’s size, its 
activities, the complexity of its  
organisation and the selected method.   

3.4 Certification Audit  

The audit process is identical to the one described in BMS (5. Production/Audit 
Preparation and Audit Realisation), completed with GP01 OLB. Auditors will 
verify that the specific requirements from OLB standards are respected during 
each audit (initial  
audit, surveillance and renewal audits). 

[…] 

4. Audit Report  

scheme. 

Findings 

Scheme info 

Covered 

The OLB certification process is described in the 
documents:  

- 

Specific Instructions OLB: Chain of Custody 
and Forestry Companies Certification 
process 

-  Description du processus de certification 
OLB Entreprises forestières (GP01-OLB-
EF)  

-  Description du processus de certification 
OLB COC certification (GP01-OLB-COC). 
Evaluations are based on documentation review and 
onsite audits. A report, with non-conformities if 
applicable, is issued after each audit. There are three 
types of audits: (initial audit, surveillance and renewal 
audits). Surveillance audits are planned yearly. 

The process of review and certification decision and 
issuance of the certificate are described in GP01-
OLB-EF and GP01-OLB-COC:  

The certification decision is taken by the Head of the 
Forest-Timber Department on the basis of the 
elements contained in the final audit report and after 
having received proof that all major non-conformities 
have been closed and that the company is in in 
accordance with the requirements of the standard. 

[…] 

When the certification decision is favorable, 
certification is granted for a maximum of five years. 

The process described in the BMS applies.  
The auditor issues a OLB audit report after each audit. 

[…] 

978 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

[…] 

6 –Certificate Maintenance  

Thanks to surveillance audits, the certificate is maintained during its validity 
period as long as the certified entity complies with standards’ requirements.  

Bureau Veritas Certification prepares a public 
summary (general and non-confidential data) on the 
certification process with the certification decision. 
This public summary will be submitted to the 
Company for two weeks for validation and will be 
published on the Bureau Veritas website. 

Surveillance audits are planned yearly. Some flexibility is admitted for the audit 
date but must be validated either by the WFD manager or the OLB product 
manager. is one month before or after the certificate validity date as a 
maximum.  

Justification 

Based on the above, this indicator is covered by the 
scheme. 

GP01-OLB-EF : 

7 - Certification  

7.1 - Décision de certification  
La décision de certification est prise par le Responsable du Département Forêt -
Bois sur  la base des éléments contenus dans le rapport final d’audit et après 
avoir reçu les preuves que toutes les non-conformités majeurs ont été fermées 
et que l’entreprise est en en conformité avec les exigences du référentiel.  
Le Comité de Bureau Veritas Certification se réuni une fois par an et tous les 
dossiers  de certification OLB sont présentés pour évaluation et commentaires 
afin d’améliorer la performance de Bureau Veritas.   
Le Comité de certification est composé de personnes de référence dans toutes 
les composantes relatives à la certification et la gestion forestière responsable 
(ONG environnementales et sociales, associations, entreprise, etc.). Le rôle du 
Comité est de s’assurer  de la performance, de l’intégrité et de la crédibilité du 
système du Département Forêt-Bois de Bureau Veritas Certification.  

7.2 - Octroi du certificat  
Lorsque la décision de certification est favorable, la certification est octroyée 
pour cinq ans maximum.  
Un numéro de certificat est délivré à l’entité candidate qui devient une 
entreprise certifiée.  
L’entreprise peut alors utiliser la marque OLB en respectant les conditions 
d’usage de la marque et après validation par Bureau Veritas Certification.  
Bureau Veritas Certification prépare un résumé public (données générales et 
non confidentielles) sur le processus  de certification avec la décision de 
certification. Ce résumé public sera soumis pendant deux semaines à 
l’Entreprise pour validation, et sera publié sur le site internet de Bureau Veritas.  

979 

 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

B.2.1.3 The
Scheme shall
include
requirements that
ensure that
Certification
Bodies have in
place - and
implement –
specific
procedures for 
audits that include
at least the
following:
i) frequency of
audits; (no longer 
than every 12
months);
ii) requirements for 
on-site (field) visits 
where applicable;
iii) sampling
protocol for audits 
(if applicable);
iv) structure and
competencies of
the audit team;
v) the minimum 
set of aspects that
need to be
checked in every
audit;
vi) minimum 
content of audit 
reports, including 
non-
conformances,
clarification of
scope, audit
process  and

GP01 OLB EF 

10.1 -  Audits de Surveillance  

Findings 

Scheme info 

Covered 

Les audits de surveillance à réaliser sont programmés chaque année. Bureau 
Veritas Certification ou ASI peut également effectuer des contrôles inopinés 
dans les bureaux ou sur le terrain de l'organisme certifié.  

Les audits de surveillance à réaliser sont programmés chaque année mais 
pourraient être plus fréquents en fonction de la complexité des opérations et du 
niveau de conformité de l’entité certifiée, et du temps requis pour résoudre les 
non-conformités identifiées.  

En plus des audits de surveillance annuels, Bureau Veritas Certification peut 
procéder à des audits inopinés de l’entité certifiée ou des audits de suivi afin de 
s’assurer  que les non- 
conformités identifiées ont été traitées et résolues dans le délai fixé.  

Specific Instructions OLB: Chain of Custody and Forestry Companies  
Certification process 

6 –Certificate Maintenance 

Thanks to surveillance audits, the certificate is maintained during its validity 
period as long as the certified entity complies with standards’ requirements. 

Surveillance audits are planned yearly. Some flexibility is admitted for the audit 
date but must be validated either by the WFD manager or the OLB product 
manager. is one month before or after the certificate validity date as a 
maximum.  

3.5 Multi-sites Certification  

The process is described in GP01 OLB and in the standard RF03 OLB Multisite.  

A group or a multi-site certification process type refers to a group of entities 
(mainly for OLB FC) or a multi -site  
entity applying for a single OLB certificate under the responsibility of central 

The OLB FM and COC certification procedures 
describe the frequency of surveillance audits, which 
take place every 12 months, with a flexibility of one 
month before or after the certificate anniversary date. 

As explained, “The surveillance audits to be 
performed are scheduled every year but could be 
more frequent depending on the complexity of the 
operations and the level of compliance of the certified 
entity, and the time required to resolve the non-
conformities identified. 

In addition to annual surveillance audits, Bureau 
Veritas Certification may carry out unannounced 
audits of the certified entity or follow-up audits to 
ensure that non-identified conformities were 
processed and resolved within the set deadline.” 

For OLB FM certificates, audits must be on-site, and 
the audit plan is described in the certification 
procedure.  

At the COC level, for the companies that are already 
FSC and/or PEFC Chain of Custody certified by 
Bureau Veritas Certification, the surveillance audit 
can be done through a document review on the basis 
of the already existing FSC and/or PEFC audit 
reports, and of the chain of custody procedure which 
the company will have implemented to demonstrate 
compliance with the OLB standard's requirements. 
The companies that are not FSC and/or PEFC chain 
of custody certificate holder, will be audited on-site 
annually.  

The audit process and sampling methodology for 
multi-site certificates is also described in the 

980 

evaluation 
findings. 
vii) ability for 
unannounced or 
short-notice audits 
in case of 
substantiated 
claims or for other 
reasons.  

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

organisation.  

procedures.   

For the audit report, it is explained that :  

“The audit report explicitly mentions all the documents 
that were assessed  and controlled” 

The audit report templates for FM and COC include 
non-conformances, clarification of scope, audit 
process  and evaluation findings. 

Justification 

Based on the above, this indicator is covered by the 
scheme. 

When the differences among the sites or the group is important, smaller groups 
of sites/entities must be created  
according to:   
 the type of activities carried out by/on the entities/sites  
 for OLB FC, the type of forest (population, stands, size, environment issues, 
forest objectives, etc)  

Then the sites sampling method shall be applied to each activity or homogenous 
group of site/entity:   
The minimum number of sites to be visited per audit is:  
- Initial audit:  
the size of the sample should be the square root of the number of remote sites: 
(y=√x ), rounded to the upper  
whole number.  
- Surveillance audit:  
the size of the annual sample should be the square root of the number of 
remote sites with 0.6 as a coefficient  
(y=0.6 √x), rounded to the upper whole number.  
- Re-certification audit:  
the size of the sample should be the same as for an initial audit. Nevertheless, 
where the management system has  
proved to be effective over a period of three years, the size of the sample could 
be reduced by a factor 0.8, i.e.:  
(y=0.8 √x), rounded to the upper whole number.   

When new sites are included in the scope of the certificate, the sampling rate to 
be used shall be the one for  
initial audit. 

4. Audit Report  

The process described in the BMS applies.  
The auditor issues a OLB audit report after each audit.  

The audit report explicitly mentions all the documents that were assessed and 
controlled.   
The audit report is examined by a WFD account manager who did not take part 

981 

 
   
 
 
 
  
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

in the audit 

PL-CAM-CER-014 V2.4_GP01 OLB CoC, Surveillance audits 

Surveillance audits will take place at least annually but may be more frequent 
depending on the complexity of the operation and of the certificate holder's level 
of conformity, and on the time needed to resolve the non-conformities detected. 
For the companies that are already FSC and/or PEFC Chain of Custody certified 
by Bureau Veritas Certification, the surveillance audit can be done through a 
document review on the basis of the already existing FSC and/or PEFC audit 
reports, and of the chain of custody procedure which the company will have 
implemented to demonstrate compliance with the OLB standard's requirements. 
The companies that are not FSC and/or PEFC chain of custody certificate 
holder, will be audited on-site annually. Surveillance audits allow Bureau Veritas 
to monitor:  

- The conformity of the organization as assessed  during the initial audit;  
The implementation of corrective actions to address minor nonconformities and 
eventual recommendations;  
- The correct use of the OLB trademark by the certified organization If Bureau 
Veritas Certification identifies significant non-conformities leading to one or 
several major corrective action requests during the period of validity of the 
certificate (maximum 5 years), the company is given a specific timeline 
determined by Bureau Veritas' audit team (3 months maximum) to implement 
the necessary corrective 

RF03 OLB EF Version 3.4 

Findings 

Covered 

Exigences relatives aux communautés concernées par les activités forestières: 

Scheme info 

L'entreprise a réalisé une étude d'impact social en fonction de 

1.3.4 - 
l’échelle, de l’intensité et du risque des opérations d’aménagement et 
d’exploitation forestière et de la spécificité du contexte social.  Elle a valorisé les 
résultats de cette étude par un programme opérationnel. 
i. 
autochtones), autour ou au sein des concessions forestières, ayant des droits 
traditionnels ou légaux, sont identifiées et cartographiées. 
ii. 
ressources)  des communautés concernées par les surfaces forestières 
évaluées sont identifiés par le biais d'une concertation* avec ces populations.  

L'ensemble des communautés locales (y compris les peuples 

Les droits fonciers (propriété) et droits d'usage (accès aux 

The OLB standard requires the candidates to OLB FM 
certification to conduct a stakeholder consultation. 
This is described in the OLB FM standard (1.3).  

As described in the “Description of the process OLB 
certification Forestry companies”, OLB auditors are 
required to evaluate the stakeholder consultation 
carried out by the certificate holder, as well as to 
involve relevant stakeholders in different stages of the 
audit process (pre-assessment,  assessment  and 

982 

B.2.2 

Stake
holder 
consul
tation 

B.2.2.1 The 
Scheme shall 
include 
mechanisms to 
ensure that 
Certification 
Bodies conduct 
consultation with 
stakeholder 
(including rights 
holders) as 
appropriate in 
relation to audits 
(only applicable 

 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

annual audits). 

The scheme owner includes a system to manage 
complaints. The system is publicly available in the 
owner’s website. In addition, FM and CoC standards 
include a chapter explaining that complains will be 
managed by Bureau veritas.  

Justification 

Based on the above, this indicator is covered. 

where necessary** 
for evaluating 
compliance of 
certificate 
holders).  

The scheme shall 
ensure that the 
certification holder 
has a proper 
stakeholder 
consultation 
process  in place. 

Les communautés locales ont été consultées au préalable et sont 

1.3.5 - 
impliquées dans les activités de gestion/ exploitation forestière pouvant avoir 
une incidence sur leurs droits) 

Il existe des procédures écrites basées sur la législation nationale 

L’entreprise, par le biais de la concertation culturellement appropriée 

1.3.6 - 
avec les communautés concernées par les surfaces forestières évaluées, met 
en œuvre des mesures  pour identifier en permanence, prévenir, éviter ou 
atténuer les impacts négatifs potentiels de ses activités sur leurs droits 
coutumiers et/ou légaux  
1.3.7 -  Des  mécanismes et des mesures appropriés doivent être employés 
pour prévenir et rechercher des solutions aux conflits relatifs aux droits fonciers 
(propriété) et aux droits d'usage d'usages (accès aux ressources). 
i. 
et/ou les règles coutumières, pour la prévention et la gestion des con flits et des 
dégâts dans les cas de perte ou de dommages affectant les propriétés, les 
ressources,  la santé et les conditions de subsistance des populations locales, y 
compris les peuples autochtones.  
ii. 
et la réparation des dégâts dans les cas  de pertes ou de dommages affectant 
les propriétés, les ressources  et les conditions de subsistance des populations 
locales et autochtones doivent être mises en application de manière objective, 
constructive, et documentée. 
iii. 
l’entreprise est tenu, enregistré et archivé, comprenant la documentation y 
afférente, et les preuves des actions prises pour les résoudre. 

Un dossier complet et actualisé des conflits et griefs contre 

Les procédures élaborées pour la prévention et la gestion des conflits 

GP01 OLB FC - 1.2 version  

4 - Pré-audit  

4.1 - Intérêt et réalisation du pré-audit  

[…] 
Un pré-audit n’est pas nécessairement obligatoire dans le processus de 
certification, toutefois c’est une exigence lorsque les opérations de gestion 
forestière sont complexes, quand la surface forestière à évaluer est importante 
et lorsqu’il y a un environnement particulièrement sensible (aussi bien social 
qu’environnemental). De plus, un pré-audit permet à l’entité candidate de 

983 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

s’assurer  que son système d’organisation ne présente pas des non -conformités 
majeures.  
[…] 
Par ailleurs, un pré-audit est important dans la mesure où il facilité le processus 
de consultation des parties prenantes. Avant le pré-audit, l'entité candidate et 
Bureau Veritas Certification doivent effectuer une première identification des 
parties prenantes, afin  
d’organiser un premier contact qui aura lieu lors du pré-audit.  
NB : Il est fortement recommandé que l’identification et la prise de contact entre 
les parties prenantes et le candidat soient faites avant début du processus de 
certification. Les candidats n'ayant pas réalisé ce travail seront invités à le faire. 

5.2.2 - Déroulement de l’audit  

Le travail de l'équipe d'audit se fait sur documents ou à partir d'inspections de 
terrain et d'interviews des employés, d'intervenants extérieurs, et de 
représentants de parties prenantes.  
Les principales missions de l'audit initial sont les suivantes :  
• Evaluer la conformité avec les exigences légales au niveau local et 
international ;  
• Rencontrer les représentants des parties prenantes identifiée s ;  
• Réaliser des visites de terrain et des bureaux du candidat ;  
L’équipe d’audit effectue une évaluation du système de l’entreprise en place 
pour s’assurer  que toutes les activités sont réalisées en conformité avec les 
exigences légales, de la planifi cation à la mise en œuvre des activités de 
gestion forestière, la gestion des ressources humaines, la gestion documentaire 
et le suivi des activités telles  
que décrites dans le plan d’aménagement.  
• Visiter les forêts et rencontrer les responsables/gesti onnaires de sites 
(ouvriers, marteleurs, gardes forestiers, bûcherons, débardeurs, sous-traitants, 
etc.).  
• Etablir les non-conformités identifiées et les présenter aux responsables de 
l'entité forestière et le personnel concerné. 

8.3 - Liste des documents à préparer pour le premier audit  
Après avoir envoyé les documents indiqués au paragraphe 8.1 et une fois que 
la candidature a été acceptée par Bureau Veritas, certains documents devront 
être préparés et mis à la disposition de l'équipe d'audit afin de réaliser le 
premier audit (pré-audit ou audit  
initial) :  

984 

 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

• Éléments de consultation des parties prenantes ;  
• Informations relatives aux contraintes environnementales, sociales et 
paysagères ;  
• Éléments de prises en compte des exigences de la certification vis à vis des 
exploitants,  
entrepreneurs et autres intervenants forestiers ;  
• Tout renseignement concernant les droits et usages (mandats, baux, usages, 
servitudes  
légales…) ;  
• Les volumes (en équivalent bois rond s'il y a eu une transformation) de bois 
exploité par  
l'entité forestière, volume de bois vendu par l'entité forestière et chiffre d'affaires 
durant  
les 3 dernières années. 

9- Gestion des litiges liés au certificat  
Bureau Veritas Certification a développé dans le cadre du système de 
certification OLB, un processus basé en grande partie sur la consultation et la 
concertation.  
Celle-ci s'opère au travers de l'information et de la consultation de l'entité 
forestière, aux différentes étapes du processus de certification, mais aussi par la 
consultation de l'ensemble des parties prenantes dans la gestion forestière 
pratiquée.  
Ces  consultations avec les tierce-parties et les parties prenantes pertinentes 
permettent d’assurer que le risque de litiges et de plaintes est minimisé.  
Cependant, si un différend apparaît dans le cadre d’une décision de 
certification, Bureau Veritas Certification a mis en place des procédures de 
résolution des litiges, permettant de traiter ces derniers ave c le maximum 
d'indépendance et selon les particularités suivantes :  
• Bureau Veritas Certification s’assure que tout est mis en œuvre pour résoudre 
le conflit à l’amiable pour les parties impliquées ;  
• lorsque le conflit concerne une décision de certification, le Comité de 
certification intervient dans la résolution. 

Complaints and Appeals Management for Certification Services, rev 3.1.5  

The definitions used by Bureau Veritas Certification are the following: 

-Complaint (ISO/IEC 17000:2020, 8.7): expression of dissatisfaction, other than 
appeal (8.6), by any person or organization to a conformity assessment body 

985 

 
  
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

(4.6) relating to the activities of that body, where a response is expected. 
-Appeal (ISO/IEC 17000:2020, 8.6): request by the person or organization that 
provides, or that is, the object of conformity 
assessment  (4.2) to a conformity assessment body (4.6) for reconsideration by 
that body of a decision (7.2) it 
has made relating to that object. 

Common Process Steps 
2.1 Receipt and Acknowledgement 
Complaint can be written (Formal Letter, Email, Website) or verbal (Phone Call, 
Feedback during sales visit or 
audit). The process of management of the complaints registered in our Website 
is the following: 
• The acknowledgment of the complaint is done automatically 
• On HO level, the dispatch of the email is done. If this is a complaint, this is 
transferred to a generic mailbox (groupqhseinbv@bureauveritas.com) 
• Then the complaint is transferred to the QHSE manager concerned for 
investigation and actions. 
Complaints are handled at contracting entity level. An audit may be initiated to 
proceed with investigation, and the client shall be notified with reasons for the 
audit. 
The complaint form and the complaint/appeal process are publicly available in 
the same languages as the public certification summaries published by Bureau 
Veritas Certification. 
Upon receipt, complaints and appeals are acknowledged to sender within five 
working days, unless otherwise specified. 
The Recipient of the complaint is either the person who received it directly or the 
one who entered the information. 
They are assigned to the validator who will determine the severity and decide 
actions according to this rating 

… 

2.3 Resolution process 
The resolution process includes the following steps. 
• Investigation, and analysis of the situation, 
• Structured response (root cause analysis, correction, corrective action) if the 
severity is rated high 
• Implementation of correction and corrective action, 
• Information to the client of findings and actions taken, 
• Monitoring of results: check if the solution is implemented and effective, 

986 

 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

• Record and traceability of documents, 
• Follow up on sustainability of results and of resolution. 
• The timeframe for resolution is four weeks, unless otherwise specified in 
appendices. However, this may be affected by responsiveness of the client or 
other third parties. 
Bureau Veritas retains the anonymity of the complainant in relation to the client 
if this is requested by the complainant and shall treat anonymous complaints 
and expressions of dissatisfaction that are not substantiated as complaints as 
stakeholder comments and address these during the next audit. 
On case-by-case basis, BVC, the Complainant and the Cl ient shall decide if 
information needs to be made public. 
There has to be formal authorization from Complainant and Client when the 
decision is to make the complaint public. 
Any instances where failure to publicly disclose the complaint could affect other 
stakeholders, should be made public. 
Examples of these instances are complaints about: 
• Defects that could have catastrophic consequences (injuries, death, etc.,).  
• Failures in environmental management systems that could cause severe 
damage to environment and stakeholders. 
• Quality of food products; etc. 
• A final written response is provided to the complainant 
• Specific complaints and appeals handling procedure are applied for following 
schemes based on scheme owner requirements and a copy of these can  be 
made available on request from LTM 
o ASC Services 
o MSC 
o FSC FARM 
o IATF 16949 
o SA8000 
o CDM 

Appeals are dealt at the level where certification decision making was done 
(Critical Location, Hub, ICC) and coordinated by Local Technical Manager with 
concerned Accreditation Manger and CL, Hub, or ICC to maintain impartiality. 
Appeals related to QHSE schemes are communicated to CER Accreditation 
Manager. 

https://certification.bureauveritas.com/contact-us-0 

B.2.2 

Corru
ption 

B.2.2.2 The 
Scheme shall 

RF03 OLB EF Version 3.4 

Findings 

Partially 
Covered 

987 

 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

include 
mechanisms to 
identify (or for the 
Certification Body 
to do so) 
companies 
sanctioned for 
engagement in 
corrupt practices 
relevant to the 
forest sector. 

L'entreprise doit être légalement établie selon les dispositions 

1.1 - 
réglementaires locales en vigueur, en conformité avec les exigences du (des) 
secteur(s)  d'activité dans le(s)quel(s) elle exerce, et à jour de ses obligations 
fiscales. 

L'entreprise dispose des documents officiels et valides d'existence 

1.1.1 - 
légale (document d'immatriculation ou d'enregistrement), généraux et 
spécifiques à son (ses)  activité(s). 

L'entreprise respecte les exigences du (des) secteur(s)  d'activité dans 

1.1.2 - 
le(s)quel(s) elle exerce (si elles existent, dans une convention collective ou un 
syndicat par exemple) * 

1.1.3 - 
L’entité forestière est en règle vis-à-vis de ses obligations fiscales de 
droit commun applicables, ainsi que de ses obligations fiscales et taxes liées à 
son (ses)  activité(s) forestières (Patente, TVA, taxes et redevance liées à la 
récolte du bois, au volume, au transport et à la commercialisation du bois, …)   

1.1.4 - 
portant à controverse et pouvant porter atteinte à son intégrité légale* 

L'entreprise n'est pas impliquée dans des activités ou des pratiques 

Scheme info 

It is required that the organisation is not involved in 
controversial activities or practices that may impair its 
legal integrity. But it does not directly require auditors to 
evaluate if companies have been sanctioned or 
otherwise involved in corrupt practices.

Justification 

Based on the above, this indicator is partially covered. 

C. Requirements for Certification Schemes

C.1 Transparency

C.1.1

Trans
paren
cy 

C.1.1.1 Scheme
requirements for 
both Certificate 
Holders and
Certification
Bodies shall be
publicly available
online. 

https://www.bureauveritas.fr/sites/g/files/zypfnx146/files/media/document/PL -
CAM-CER-014%20V2.4_GP01%200LB%20CoC.pdf 
https://www.bureauveritas.fr/sites/g/files/zypfnx146/files/media/document/PL -
CAM-CER-002%20V1.3_GP01%20OLB%20EF.pdf 
https://certification.bureauveritas.com/sustainable-forestry-certification 
https://certification.bureauveritas.com/who-we-are/our-resources/impartiality 
https://w ww.bureauveritas.fr/besoin/certification-olb 

Findings 

Scheme info 

Covered 

Information related to the scheme owner and policies 
of the owner are available on the website: 
www.bureauveritas.fr. As scheme did not include 
Certification Bodies, is nothing to make publicly 
available.  

Requirements for certificate holders are publicly 
available in website. 

988 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Available online, without beta versions of standards. 

Justification 

Based on the above, this indicator is covered.  

C.1.1.2 Schemes 
shall include 
requirements that 
ensure that 
relevant 
information about 
the following is 
freely available: 
i) development 
and content of the 
Scheme; 
ii) how the system 
is governed;  
ii) who is 
evaluated and 
under what 
process;   
iv) impact 
information and 
the various ways 
in which 
stakeholders can 
engage. 

Internal instructions:  

OLB Certification Standard setting specific instruction   

Findings 

Scheme info 

Partially 
Covered 

2 - Description of the instruction The   process   to   issue   new   OLB   
standards/documents   or   to   modify   existing   OLB standards/documents is 
composed by different steps as listed below: - setting and adjustment - 
stakeholder’s consultation  - testing - final approval - effective date 

Stakeholders are engaged in the setup of new 
standards, as  described in the internal instruction 
“OLB Certification Standard setting specific 
instruction”. 

The process for evaluation and certification is 
described in the publicly available documents: 

-GP01 OLB EF_PL-CAM-CER-002 V1.3 

-GP01 0LB COC_PL-CAM-CER-014 V2.4 

They include requirements to identify and consult 
stakeholders.  

Justification 

Part of this indicator is not met: the document “OLB 
Certification Standard setting specific instruction”, 
which describes the development and content of the 
Scheme and the various ways in which stakeholders 
can engage, is not freely available. 

… 

2.2 - Stakeholder’s consultation  

2.2.1 - Stakeholders identification of    the    relevant    stakeholder    is    done 
according    to    the    document developed/changed and the people/entities 
concerned by the document (NGOs, companies, clients, partners, governmental 
agencies, individuals, etc...)  This   might   be   done   with   the   help   of   the   
excel   file “stakeholderConsultation_contact list_template”  

2.2.2 - Consultation The  issued  draft  of  the  documents  is  then  sent  to  the  
relevant  identified  stakeholders  for comments for a p eriod of 30 days. The  
means  used  to  communicate  to  the  stakeholders  is  appropriate  to  the  
communication means  used  by  the  concerned  stakeholders  in  order  to  
gather  as  much  as  possible comments (email, phone call, letter, Internet 
communication, etc...).   

2.2.3 - stakeholders’ comments The stakeholders’ comments must be recorded 
in the appropriate “stakeholderConsultationManagement_template”. The  person  
in  charge  of  developing/modify  the  OLB  documents  must  identify  the  
relevant and not relevant comments and justify it. All relevant comments must 
be integrated in the drafted documents.   

Specific Instructions OLB: Chain of Custody and Forestry Companies 
Certification process  

989 

 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Publicly available documents (available at 
https://www.bureauveritas.fr/documents-olb): 

GP01 OLB EF_PL-CAM-CER-002 V1.3: Description du processus de 
certification OLB Entreprises forestières :  

(it is required to identify and consult stakeholders in different stages of the 
process, notably during the audit):  

5.2.2 - Déroulement de l’audit  

Le travail de l'équipe d'audit se fait sur documents ou à partir d'inspections de 
terrain et  d'interviews des employés, d'intervenants extérieurs, et de 
représentants de parties prenantes.  

9 - Gestion des litiges liés au certificat  

Bureau Veritas Certification a développé dans le cadre du système de 
certification OLB, un processus basé en grande partie sur l a consultation et la 
concertation.  

Celle-ci s'opère au travers de l'information et de la consultation de l'entité 
forestière, aux différentes étapes du processus de certification, mais aussi par la 
consultation de l'ensemble des parties prenantes dans la gestion forestière 
pratiquée.  

Ces  consultations avec les tierce-parties et les parties prenantes pertinentes 
permettent d’assurer que le risque de litiges et de plaintes est minimisé.  

Cependant, si un différend apparaît dans le cadre d’une décision de 
certification, Bureau Veritas Certification a mis en place des procédures de 
résolution des litiges, permettant de traiter ces derniers avec le maximum 
d'indépendance et selon les particularités suivantes :  

• Bureau Veritas Certification s’assure que tout est mis en œuvre pour résoudre 
le conflit à l’amiable pour les parties impliquées ;  

• lorsque le conflit concerne une décision de certification, le Comité de 
certification intervient dans la résolution. 

GP01 0LB COC_PL-CAM-CER-014 V2: Description du processus de 

990 

 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

certification OLB CdC 

14 - Gestion des litiges liés au certificat  

Bureau Veritas Certification a développé dans le cadre du système de 
certification OLB, un processus basé en grande partie sur la consultation et la 
concertation.  

Public link for pdf with certificates:  

FM: 
https://www.bureauveritas.fr/sites/g/files/zypfnx146/files/media/document/Liste%
20des%20entreprises%20foresti%C3%A8res%20certifiees%20OLBEFRev.pdf 

COC: 
https://www.bureauveritas.fr/sites/g/files/zypfnx146/files/media/document/Liste%
20des%20organismes%20certifi%C3%A9es%20OLB%20CoCrevfr.pdf 

C.1.1.3 The 
Scheme shall 
include 
requirements that 
ensure that an up-
to-date register of 
certified/verified 
organisations is 
publicly available. 

PL-CAM-CER-015 

8.3. Mise à jour de la base de données OLB 

Findings 

Scheme info 

Covered 

OLB include a public register of certified organisation. 
The register is a PDF file, which is updated in each 
month. The process to update the list is not available.  

Direct interviews/ discussions / Stakeholder input 

During the stakeholder consultation process, BV has 
provided the document PL-CAM-CER-015 (Manuel 
des Procédures de Certification OLB), which states 
when the list of certified organisations is updated.  

La liste des entreprises certifiées OLB EF et/ou CoC est mise à jour à chaque 
nouvelle certification ou renouvellement de certificat, ainsi qu’à chaque fois que 
le périmètre de certification du client est revu (cas d’une extension ou réduction 
de périmètre) ou que le statut de certification d’un client est modifié 
(suspension, retrait de certificat…). 

Justification 

Based on the information above, this indicator is 
covered. 

La version finale du rapport est publiée en français après validation du client 
(qui peut demander le retrait des informations jugées confidentielles du rapport 
avant la publication), dans un délai de 15 jours après la décision de certification. 
Elle peut être traduite en toute autre langue sous la demande du client. 
Toutefois, les frais de traduction sont à la charge du client.  
PL-CAM-CER-002 rev1.3., 

14.4. ELEMENTS A RENDRE PUBLICS.  

Findings 

Scheme info 

Partially 
Covered 

Dans le cadre de la certification, certains éléments doivent être rendus publics. 
Cette exigence s'applique à partir du moment où l'entité forestière reçoit un 
certificat :  

According to PL-CAM-CER-002 rev1.3.,14.4., audit 
report should be publicly available for forest 
management. In addition, certificate holder has 2 
weeks  to highlight confidential information that should 

C.1.1.4 The 
Scheme shall 
make summaries 
(or full reports) 
with relevant 
findings from 
audits available on 
the internet. 

991 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

- nom et coordonnées de l'entité forestière  
- numéro du certificat  
- champ d'application du certificat  
- nom et prénom de la personne à contacter dans le cadre de la certification  
Liste des informations et documents à rendre publics  
- Rapport public d'audit  

Avant publication du rapport, celui -ci est envoyé à l'entreprise certifiée pour 
extraction d'éventuelles informations jugées confidentielles dans un délai de 
deux semaines. 

https://www.bureauveritas.fr/documents-olb 

GP01 OLB EF_PL-CAM-CER-002 V1.3: Description du processus de 
certification OLB Entreprises forestières  

8.4 - Liste des informations et documents à rendre publics  
Dans le cadre de la certification, certains éléments doivent être rendus publics. 
Cette  
exigence s'applique à partir du moment où l'entité forestière reçoit un certificat :  
• nom et coordonnées de l'entité forestière ;  
• numéro du certificat ;  
• champ d’application du certificat ;  
• nom et prénom de la personne à contacter dans le cadre de la certification ;  
• le résumé public qui est un résumé du rapport d’audit sans information 
confidentielle. 
Complaints and Appeals Management for Certification Services, rev 3.1.5   

The definitions used by Bureau Veritas Certification are the following: 

-Complaint (ISO/IEC 17000:2020, 8.7): expression of dissatisfaction, other than 
appeal (8.6), by any person or organization to a conformity assessment body 
(4.6) relating to the activities of that body, where a response is expected. 

-Appeal (ISO/IEC 17000:2020, 8.6): request by the person or organization that 
provides, or that is, the object of conformity 
assessment  (4.2) to a conformity assessment body (4.6) for reconsideration by 
that body of a decision (7.2) it has made relating to that object. 

Common Process Steps 

992 

be removed from report. 

GP01 OLB EF_PL-CAM-CER-002 V1.3 clarifies that 
“the public summary is a summary of the audit report 
without confidential information”. 

The FM audit reports are available upon request via 
e-mail.  

For CoC, there is no requirement related to the 
availability of the reports. 

Justification 

Part of the indicator is not met: a public version of the FM 
report is available, but only upon request (not directly 
available on the internet). COC reports are not publicly 
available.  

Findings 

Scheme info 

Covered 

The scheme owner includes a system to manage 
complaints. The system is publicly available in the 
owner’s website. In addition, FM and CoC standards 
include a chapter explaining that complains will be 
managed by Bureau veritas.  

Justification 

Based on the above, this indicator is covered.  

C.1.2 

Impart
iality 

C.1.2.1 
Procedures for 
handling 
complaints and 
grievances shall 
be in place, made 
publicly available 
and implemented. 
The procedures 
shall be clearly 
publicized, making 
it easy for 
stakeholders to 
submit comments 

 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

or complaints 
where applicable. 

2.1 Receipt and Acknowledgement 

Complaint can be written (Formal Letter, Email, Website) or verbal (Phone Call, 
Feedback during sales visit or audit). The process of management of the 
complaints registered in our Website is the following: 

• The acknowledgment of the complaint is done automatically 
• On HO level, the dispatch of the email is done. If this is a complaint, this is 
transferred to a generic mailbox (groupqhseinbv@bureauveritas.com) 
• Then the complaint is transferred to the QHSE manager concerned for 
investigation and actions. 

Complaints are handled at contracting entity level. An audit may be initiated to 
proceed with investigation, and the client shall be notified with reasons for the 
audit. 

The complaint form and the complaint/appeal process are publicly available in 
the same languages as the public certification summaries published by Bureau 
Veritas Certification. 

Upon receipt, complaints and appeals are acknowledged to sender within five 
working days, unless otherwise specified. 

The Recipient of the complaint is either the person who received it directly or the 
one who entered the information. 

They are assigned to the validator who will determine the severity and decide 
actions according to this rating 

2.2  Responsibility 

Personnel who investigate complaints and appeals are always different from 
those who carried out the audits and made certification decision, without 
discrimination against the appellant or complainant. 

• If (LTM) Local Technical Manager was involved, then a person, internal and 
independent, is appointed 
• If Local Technical Manager was not involved; he or she can carry out the 
investigation. 
Unless otherwise specified, LTM is the default channel for complaints and 

993 

 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

appeals. 

2.3  Resolution process 

The resolution process includes the following steps: 

• Investigation, and analysis of the situation, 
• Structured response (root cause analysis, correction, corrective action) if the 
severity is rated high 
• Implementation of correction and corrective action, 
• Information to the client of findings and actions taken, 
• Monitoring of results: check if the solution is implemented and effective, 
• Record and traceability of documents, 
• Follow up on sustainability of results and of resolution. 
• The timeframe for resolution is four weeks, unless otherwise specified in 
appendices. However, this may be affected by responsiveness of the client or 
other third parties. 

Bureau Veritas retains the anonymity of the complainant in relation to the client 
if this is requested by the complainant and shall treat anonymous complaints 
and expressions of dissatisfaction that are not substantiated as complaints as 
stakeholder comments and address these during the next audit. 

On case-by-case basis, BVC, the Complainant and the Client shall decide if 
information needs to be made public. 

There has to be formal authorization from Complainant and Client when the 
decision is to make the complaint public. 

Any instances where failure to publicly disclose the complaint could affect other 
stakeholders, should be made public. 

Examples of these instances are complaints about: 

• Defects that could have catastrophic consequences (injuries, death, etc,); 
• Failures in environmental management systems that could cause severe 
damage to environment and stakeholders; 
• Quality of food products; etc. 
• A final written response is provided to the complainant 
• Specific complaints and appeals handling procedure are applied for following 
schemes based on scheme owner requirements and a copy of these can be 

994 

 
 
 
 
 
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

made available on request from LTM 
o ASC Services 
o MSC 
o FSC FARM 
o IATF 16949 
o SA8000 
o CDM 

Appeals are dealt at the level where certification decision making was done 
(Critical Location, Hub, ICC) and coordinated by Local Techn ical Manager with 
concerned Accreditation Manger and CL, Hub, or ICC to maintain impartiality. 
Appeals related to QHSE schemes are communicated to CER Accreditation 
Manager. 

https://certification.bureauveritas.com/contact-us-0 

PL-CAM-CER-002 rev1.3., GESTION DES LITIGES LIES AU CERTIFICAT  

Bureau Veritas Douala a développé dans le cadre du système de certification 
OLB, un processus  basé en grande partie sur la consultation e t la concertation.  

Celle-ci s'opère au travers de l'information et de la consultation de l'entité 
forestière, aux différentes étapes du processus de certification, mais aussi par la 
consultation de l'ensemble des parties prenantes dans la gestion foresti ère 
pratiquée.  

Ces  consultations avec les tierce-parties et les parties prenantes pertinentes 
permettent d'assurer que le risque de litiges et de plaintes est minimisé.  

Cependant, si un différend apparaît dans le cadre d'une décision de 
certification, Bureau Veritas Douala a mis en place des procédures de résolution 
des litiges, permettant de traiter ces derniers avec le maximum d'indépendance 
et selon les particularités suivantes :  

- 

- 

Bureau Veritas Douala s'assure que tout est mis en œuvre pour 
résoudre le conflit à l'amiable pour les parties impliquées  
lorsque le conflit concerne une décision de certification, le Comité de 
certification intervient dans la résolution. 

PL-CAM-CER-014 V2.4_GP01 OLB CoC 14. MANAGEMENT OF DISPUTES 
RELATED TO THE CERTIFICATIONPROCESS 

995 

 
 
 
 
 
 
 
 
 
  
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

C1.3 

Confli
ct of 
intere
st  and 
corrup
tion 

C.1.3.1 The 
Certification 
Scheme shall 
have in place 
requirements at all 
levels of the 
scheme 
(normative 
requirements for 
CHs,  requirements 
for CBs,  and for 
the scheme 
functioning) to 
manage risks of 
corruption and 
conflict of interest. 

Bureau Veritas Certification developed within the scope of the OLB certification 
system, a process based on consultation and cooperation with third parties. 
Nevertheless, if a conflict appears within the scope of a certification process, 
Bureau Veritas Certification has developed and implements disputes resolution 
procedures to ensure maximum independence and according to the following 
principles:  

- Bureau Veritas Certification will ensure that everything is done to solve the 
conflict in a professional and satisfactory manner for all parties involved. When 
the conflict concerns a certification decision, Bureau Veritas' Impartiality 
Committee is involved in the resolution 
https://certification.bureauveritas.com/who-we-are/our-resources/impartiality 

PL-CAM-CER-002 rev1.3., 9.1 Qualification des auditeurs 
… 
- Enfin les auditeurs de Bureau Veritas Douala sont sélectionnés pour réaliser 
les audits selon les critères suivants: 
… 

- L'indépendance.  

… 

PL-CAM-CER-014 V2.4_GP01 OLB CoC 9.1, Auditor’s qualification 

Bureau Veritas Douala recruits as auditors only specialists from the timber 
industry in order to ensure the following: 

- Independence  

… 
https://group.bureauveritas.com/sites/g/files/zypfnx196/files/media/document/BP
CC_SEPT_2020_EN.pdf 

BUREAU VERITAS BUSINESS PARTNER CODE OF CONDUCT (BPCC) 

1. Fighting Bribery, Corruption, and Influence Peddling 

This section is without prejudice to the content of the Code of Ethics. Bureau 
Veritas is fully committed to fighting all forms of bribery and corruption, including 
influence peddling, in every country in which it operates and to complying with 
relevant local and international anti -bribery and anti-corruption laws in all 

996 

Findings 

Scheme info 

Covered 

The scheme owner (Bureau Veritas) includes a policy 
related to impartiality for all certification service that 
they are providing. In addition, PL-CAM-CER-002 
rev1.3., 9.1 and PL-CAM-CER-014 V2.4_GP01 OLB 
CoC 9.1 state that Bureau Veritas recruits only 
specialist that are independent.  

Conflict of interest and corruption are also addressed 
in the publicly available document BUREAU 
VERITAS  BUSINESS  PARTNER  CODE  OF 
CONDUCT  (BPCC) 

Justification 

Based on the above, this indicator is covered.  

 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

jurisdictions within which Bureau Veritas is established or performs services. 

Bureau Veritas has a zero-tolerance policy toward bribery and corrupt conduct 
in any form. Bribes, kickbacks,  influence peddling and any other improper 
inducements or arrangements involving public officials, customers, suppliers or 
any other counterparties are strictly prohibited. 

… 

2. Conflicts of Interest 

Business Partners should take steps  to avoid conflicts of interest, whether of a 
personal, activity or organisational nature, that may jeopardise the ability of any 
party associated with the Business Partner, or of any Bureau Veritas employee, 
to act in the best interest of Bureau Veritas and/or its clients. Decisions our 
Business Partners take in regard to Bureau Veritas business transactions may 
not be influenced by personal or private interests. 

Personal or friendly relationships with a Bureau Veritas em ployee may not be 
used to influence the employee’s business judgment. If an employee is related 
to a Bureau Veritas employee, and this may represent any actual or potential 
conflict of interest in a transaction or business relationship, Business Partners 
must promptly disclose this fact to their principal Bureau Veritas point of contact 
or ensure that the Bureau Veritas employee does it. 

C.2 Scheme & standard scope 

Note: section C2 is not specifically referring to EUTR  issues but has been included as part of the evaluation of schem es to u nderstand scheme structures. 

C.2.1 

Stand
ard 
adapt
ation 
to the 
nation
al or 
subna
tional 
contex
t 

C.2.1.1 
International 
standards shall be 
adapted to the 
national or 
subnational 
context in which 
they are being 
implemented and 
contain a list of 
applicable 

OLB LEGISLATION CHART Ref. : DO100902 v1.0  September 2010  

FOREWORD  

Findings 

Scheme info 

Covered 

When a Bureau Veritas office signs the first contract for OLB certification, it must 
establish the inventory of  
all national, regional laws and international treaties that apply to the activities to 
be evaluated (forestry  
activities, employment and work, customary rights, legal establishment, 
environment, etc).   
This chart shall be filled in with the identified texts.   

OLB adapts the international standard to the national 
context.  

The document “Legislation Chart” must be adapted 
when a Bureau Veritas office signs the first contract 
for OLB certification. 

It includes a list of applicable legislation, or the 

997 

 
 
  
legislation, or the 
Scheme shall 
enable/require 
detailed evaluation 
of applicable 
legislation in a 
national context. 

C.2.2 

Intern
ational 
conve
ntions 
and 
treatie
s 

C.2.2.1 The 
Scheme shall 
include a list of the 
relevant 
international 
conventions to 
which the country 
has ratified, and 
which hold legal 
force in the 
country. 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

The chart template includes Criteria and indicators of legality of timber trade in 
[country] 

Based on the document above, an audit checklist is prepared (Exigences pour 
Audit OLB en Gestion Forestière 
Liste de vérification des documents requis- COUNTRY X -) 

Cette liste de vérification énumère l’ensemble des documents légaux du 
CAMEROUN pour un audit de certification OLB en Gestion Forestière. Celle -ci 
doit être utilisée obligatoirement par l’auditeur pour vérifier les documents requis 
transmis par l’organisation auditée.  

Cette liste de vérification a été réalisée sur la base de la grille FLEGT du 
Cameroun (document « LES GRILLES DE LEGALITE FLEGT », édité par le 
Ministère des Forêts et de la Faune, Novembre 2011). 
OLB LEGISLATION CHART Ref. : DO100902 v1.0  September 2010  

FOREWORD  

When a Bureau Veritas office signs the first contract for OLB certification, it must 
establish the inventory of  
all national, regional laws and international treaties that apply to the activities to 
be evaluated (forestry  
activities, employment and work, customary rights, legal establishment, 
environment, etc).   
This chart shall be filled in with the identified texts.   

The chart template includes Criteria and indicators of legality of timber trade in 
[country] 

Based on the document above, an audit checklist is prepared (Exigences pour 
Audit OLB en Gestion Forestière 
Liste de vérification des documents requis- COUNTRY X -) 

Cette liste de vérification énumère l’ensemble des documents légaux du 
CAMEROUN pour un audit de certification OLB en Gestion Forestière. Celle-ci 
doit être utilisée obligatoirement par l’auditeur pour vérifier les documents requis 
transmis par l’organisation auditée.  

998 

Scheme shall enable/require detailed evaluation of 
applicable legislation in a national context. 

Based on the document above, an audit checklist is 
prepared (Exigences pour Audit OLB en Gestion 
Forestière 
Liste de vérification des documents requis - 
COUNTRY X -. Each document on this list is 
reviewed and a conclusion -“C” (« compliant”) or “NC” 
(« non-compliant”) or N/A- is added. 

Justification 

Based on the above, this indicator is covered.  

Findings 

Scheme info 

Covered 

OLB adapts the international standard to the national 
context.  

The document “Legislation Chart” must be adapted 
when a Bureau Veritas office signs the first contract 
for OLB certification. 

It includes a list of the relevant international 
conventions to which the country has ratified, and 
which hold legal force in the country. 

Based on the document above, an audit checklist is 
prepared (Exigences pour Audit OLB en Gestion 
Forestière Liste de vérification des documents requis 
- COUNTRY X -. Each document on this list is 
reviewed and a conclusion -“C” (« compliant”) or “NC” 
(« non-compliant”) or N/A- is added. 

 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Cette liste de vérification a été réalisée sur la base de la grille FLEGT du 
Cameroun (document « LES GRILLES DE LEGALITE FLEGT », édité par le 
Ministère des Forêts et de la Faune, Novembre 2011). 

Justification 

Based on the above, this indicator is covered. 

C.2.3

Use  of 
contra
ctors 

C.2.3.1 The
requirements for 
forest managers 
and supply chain
entities shall be
applicable to the
organisation’s 
contractors and
outsourcing
facilities.

RF03 OLB EF Version 3.4 

1.6 -Lorsque des activités rentrant dans le champ d’application du certificat sont 
sous-traitées, les sous-traitants doivent respecter les lois et règlements liées à 
leurs activité(s) en question.* 

1.6.1 -L’entreprise a une liste des sous-traitants identifiés selon leur implication 
dans les activités de l'entreprise. Cette liste est régulièrement mise à jour.  

1.6.2 -Les entreprises sous-traitantes sont conscientes d’une potentielle visite 
de l’équipe d’audit et l’ont accepté. 

Findings 

Scheme info 

Covered 

Subtractors of Forest Enterprises must comply with 
the legislation and regulation related to their activities: 
they must be legally registered and in compliance with 
their legal obligations, and the legal employment and 
health and safety requirements. 

1.6.3 -Les entreprises sous-traitantes remplissent les exigences 1.1.1 et 1.1.3. 

Justification 

Based on the above this indicator is covered. 

1.6.4 -L’entreprise a vérifié que les travailleurs de ses  sous-traitants exercent 
leurs activités dans un cadre légal. Les indicateurs 1.3.1, 1.3.2 et 1.3.3 sont 
applicables aux employés des sous-traitants travaillant dans le périmètre 
évalué. 

1.6.5 -L’entité candidate fournit des EPI aux employés de ses sous-traitants 
dans le cas où ces  entreprises ne sont pas en mesure de les équiper (cas des 
petites entreprises locales). 

RF03 OLB CoC v3.6_FR 

3.2.1 - L'entreprise peut sous-traiter les opérations de manutention ou de 
transformation de ses produits OLB, à condition que les exigences de traçabilité 
applicables (marquage, ségrégation, etc.) soient reprises dans le contrat avec 
ses  sous-traitants. 

3.2.2 - L’entreprise doit veiller à la conformité des activités sous-traitées à toutes 
les exigences de traçabilité applicables 

C.2.4

Endor
sing 
and 

C.2.4.1 If the
Scheme includes 
the recognition or 

RF03 OLB CdC v3.6 

Findings 

Covered 

999 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

recog
nising 
of 
other 
Sche
mes 
and 
syste
ms 

endorsement of 
other schemes or 
systems,  it shall 
ensure coverage 
and consistent 
implementation of 
EUTR 
requirements at all 
levels. 

Annexe 2 : Programmes de vérification reconnus par le système OLB 

Pour  le  choix  des  programmes  repris  ci -dessous  Bureau  Veritas  Certification 
France s’est  basé sur les critères d’évaluation de légalité adoptés par : Keurhout, le 
CPET  du  gouvernement  britannique et l ’ « Assessment of Legality Verification 
Schemes » du gouvernement danois.   

En  cas  de  contradiction  entre  les  résultats  de  ces  évaluations,  Bureau Veritas 
Certification France a choisi de le retenir le plus exigent.  

Le choix des programmes ci -dessous repris par Bureau Veritas Certification France 
repose sur  les systèmes  reconnus dans le cadre de la Charte Enviro nn e me nt al e 
pour l’activité forestière et par le PEFC international 

C.3 Accreditation and oversight

C.3.1

Accredita
tion 

C.3.1.1 The Scheme
shall include a
system for 
accreditation or 
oversight of
Certification Bodies 
to ensure that CBs 
have in place the
required procedures,
capacity, and
competencies.

1000 

Scheme info 

At the COC level, material certified against the FSC 
scheme and list of PEFC endorsed schemes (see 
Annex 2 of RF03 OLB CdC v3.6) is accepted as OLB 
inputs.  

OLB explains that the accepted schemes have been 
approved as follows:  

“For the choice of the programs listed below Bureau 
Veritas Certification France has based itself on the 
legality assessment criteria adopted by: Keurhout, the 
British government's CPET and the Danish 
government's "Assessment of Legality Verification 
Schemes". 

In case of contradiction between the results of these 
evaluations, Bureau Veritas Certification France has 
chosen to retain the most demanding” 

To be updated based on FSC and PEFC assessment. 

Justification 

Based on the above this indicator is covered.  

Findings 

Scheme info 

Not 
Applicable 

The OLB scheme does not include Accreditation 
process.  Owner of the standard (Bureau Veritas is the 
entity that is conducting the audits and granting 
certification. 

C.3.1.2 The Scheme
shall ensure that the
requirements and
process  for 
accreditation is 
publicly available. 

C.3.1.3 The Scheme
shall make publicly
available, an up-to-
date list and details of
all accredited
Certification Bodies 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Justification 

Since the OLB scheme does not use certification bodies 
other than the scheme owner, BV, this indicator is  not 
applicable. 

. 

Findings 

Scheme info 

Not 
Applicable 

The OLB scheme does not include Accreditation 
process.  Owner of the standard (Bureau Veritas is the 
entity that is conducting the audits and granting 
certification. 

Justification 

Since the OLB scheme does not use certification bodies 
other than the scheme owner, BV, this indicator is not 
applicable. 

Findings 

Scheme info 

Not 
Applicable 

The OLB scheme does not include Accreditation 
process.  Owner of the standard (Bureau Veritas is the 
entity that is conducting the audits and granting 
certification. 

Justification 

Since the OLB scheme does not use certification bodies 
other than the scheme owner, BV, this indicator is not 
applicable. 

1001 

C.3.2

Oversight 
mechanis
m 

C.3.1.4 The
Accreditation Body
shall have
mechanisms to
ensure that relevant
personnel are
qualified and
competent to
evaluate Certification 
Body’s performance
in relation to Scheme
requirements.

C.3.2.1 The
Scheme shall
ensure that the
competence and
consistent
performance of
Certification
Bodies is regularly
evaluated.

Performance shall 
employ both desk-
based AND field 
approaches, 
including: 
i) Stakeholder 
consultation 
ii) In-field
evaluation of the 
performance of
the Certification 
Body, whether via
on-site inspections 
of certified forests/

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Findings 

Scheme info 

Not 
Applicable 

The OLB scheme does not include Accreditation 
process.  Owner of the standard (Bureau Veritas is the 
entity that is conducting the audits and granting 
certification. 

Justification 

Since the OLB scheme does not use certification bodies 
other than the scheme owner, BV, this indicator is not 
applicable. 

Findings 

Scheme info 

Not 
Applicable 

The OLB scheme does not include Accreditation 
process.  Owner of the standard (Bureau Veritas is the 
entity that is conducting the audits and granting 
certification. 

Justification 

Since the OLB scheme does not use certification bodies 
other than the scheme owner, BV, this indicator is not 
applicable. 

1002 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

supply chain 
entities or witness 
audits of audit 
personnel. 

C.3.2.2 The
Scheme shall
include
requirements that
ensure that the
oversight
mechanism
applies a clear 
basis for:
i) establishing
conformance;
ii) raising
corrective actions 
for non-
conformance, and
ensuring closure
within timeframes 
to avoid legal non-
compliance, and;
iii) certification 
issue (or 
maintenance) 
decision making. 

GP01 OLB EF 

7.1 DECISION DE CERTIFICATION  

Findings 

Scheme info 

Partially 
Covered 

Sur la base du rapport d'audit initial, des commentaires du candidat à la 
certification, la décision de certification est prise lors d'une réunion du Comité de 
certification dans un délai de deux mois après réception de tous ces documents.  

Avant de prendre la décision de certification, le Comité de certification peut 
demander un audit complémentaire afin de clarifier certaines parties.  

La décision de certification est prise par le Responsable du Département Forêt 
Bois sur  la base des éléments contenus dans le rapport final d'audit et après 
avoir reçu les preuves que toutes les non-conformités majeures ont été fermées 
et que l'entreprise est en conformité avec les exigences du référentiel.  

(similar language in GP01 OLB CoC)  

PL-CAM-CER-002 rev1.3., 12.NON CONFORMITES ET ACTIONS 
CORRECTIVES 

12.1. NON CONFORMITE 

Bureau Veritas impartiality Committee is part of the 
oversight mechanism applied by OLB for both, FM 
and CoC certification. According to the standard 
requirements, the Committee will meet once per year 
and check sample of certification files. No on-site 
assessment  is done to oversight quality of the audit.  

Non-conformities are part of the certification scheme. 
According to the standard for CoC, the options are 
minor, major or recommendation. For FM: minor, 
major or observation. In justified cases, the OLB 
certificate may be suspended.  

Requirements  for non-conformities  are structured 
in a w ay that there is a potential  risk that a non-
conformity may represent an infringement  of 
legislation  and that, as a result, illegal  w ood may 
enter the EU  market  w ithout mitigation  measures 
to prevent this from occurring for a period  of up to 
3 or 12 months. 

Les écarts rencontrés au cours de l'audit sont notifiés par le responsable d'audit 
au représentant du candidat. L'entreprise peut apporter des éléments 
complémentaires pour démontrer la conformité aux exigences, si ces éléments 
sont disponibles.  

This is described in the documents GP01 OLB 
EF_PL-CAM-CER-002 V1.3 
And GP01 0LB COC_PL-CAM-CER-014 V2.4 

Les non-conformités ainsi formalisées doivent répondent aux 3 critères suivants 
:  

- Être objectives et motivées par le non-respect d'une exigence de la norme ou

Justification 

1003 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Based on the above, this indicator is partially covered. 

d'une disposition prévue par l'entreprise,  
- Être fondées sur des preuves factuelles et en aucun cas sur des 
présomptions,
- Être comprises et acceptées par l'entreprise.
Selon leur importance, les non-conformités apparaissent sous la forme de
demandes d'actions correctives mineures ou de demandes d'actions correctives 
majeures.

12.2. ACTIONS CORRECTIVES  

Il existe deux niveaux d'action corrective : 

- Demandes d'actions correctives mineures (DAC mineures) : l'entité peut être
certifiée mais elle doit se mettre en conformité avec les exigences en question
dans l'année qui suit l'audit initial et au plus tard avant le premier audit de
surveillance
- Demandes d'actions correctives majeures (DAC majeures) : l'entité ne peut
pas être certifiée tant que les non-conformités majeures n'ont pas été corrigées.
Un audit complémentaire spécifique aux non-conformités majeures et leurs 
actions correctives mises en œuvre aura lieu avant toute décision de
certification. 
Si une non-conformité majeure est détectée durant un audit de surveillance,
l'Entreprise doit démontrer que cette non-conformité a été résolue dans un délai
relativement court (maximum de trois mois).

Des  Observations peuvent également être émises :  
Observations: commentaires concernant soit des dysfonctionnements ou des 
risques non traités par le référentiel, soit une adéquation imparfaite entre la 
gestion constatée sur le terrain et les exigences du référentiel OLB. L'entité peut 
être certifiée mais elle doit améliorer les points identifiés.  

L'entreprise peut proposer un plan d'actions, si elle le souhaite, et le transmettre 
au Responsable d'Audit ou le Responsable Technique de Bureau Veritas afin 
d'être validé avant sa mise en œuvre. Néanmoins, l'entreprise peut engager des 
actions correctives pour solutionner les non-conformités dès lors que les 
rapports de non-conformité ont été signés.  

L'original des rapports de non-conformité doit être complété par l'entreprise 
avec une description de l'action corrective mise en œuvre et retourné au 
Responsable d'Audit. Les actions mises en œuvre seront évaluées et validées 
durant le prochain audit de surveillance ou complémentaire par le Responsable 

1004 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

d'Audit et le Responsable Technique de Bureau Veritas. 

(similar language in GP01 OLB CoC)  

GP01 OLB EF  1.2 version 
11 - Suspension et retrait du certificat 

Le Responsable Technique OLB de Bureau Veritas Certification ou le Comité de 
certification prend la décision de suspendre ou retirer un certificat si une(des) 
non-conformité(s) ont été identifiée(s) et qu’elle(s) n’a(ont) pas été traitée(s) 
dans le délai  
requis :  

• Si la non-conformité est due à une action involontaire, elle justifie un maintien
conditionnel du certificat. Le certificat est maintenu sous réserve de la
réalisation de la ou des actions correctives dans un délai défini.
• Si la non-conformité est due à une action délibérée de l’entreprise, elle justifie,
selon la gravité des faits, une suspension temporaire ou un retrait définitif et
immédiat du certificat.
En cas de non-respect grave et indiscutable des exigences du référentiel OLB
ou des conditions d'usage du label OLB, Bureau Veritas Certification s’autorise
à suspendre le certificat temporairement.

Dans le cas d’une suspension, l’entreprise certifiée a un délai d’une semaine 
pour faire appel à cette décision et fournir des informations complémentaires ou 
des clarifications si nécessaires.  

Afin de lever la suspension, un audit complémentaire (par une vérification 
documentaire ou une évaluation de terrain) doit être réalisée afin de vérifier l a 
mise en œuvre des actions correctives pour traiter les non -conformités 
identifiées.  

C.3.2.3 The
Scheme shall
specify the
approach to be
used in oversight,
ensuring that the
oversight

SI OLB Process  v10 

2. OLB Auditors 

Findings 

Scheme info 

Not 
Covered 

Auditors are selected among Bureau Veritas Certification auditors. The chosen 
auditors must have the relevant knowledge of the audit fields he will be in 
charge of (industry, forestry, social, etc). Auditors shall meet the requirements of 

As explained in the Specific Instruction for the OLB 
process,  OLB auditors must comply with qualifications 
requirements and formally approved. The audit 

1005 

mechanism is 
independent of the 
Certification 
Bodies being 
assessed.   

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

ISO 19011. If not, they shall be trained to ISO 19011 requirements. 

The qualification is confirmed by the WFD manager on the basis of:  

• A good knowledge of the OLB requirements (Forest Company and/or Chain of
Custody) 
• An experience and/or knowledge of wood/forestry acquired by:
- initial training in the wood industry
- consulting/expertise in wood/forestry
- sale/trade of wood products or other similar material
- a professional experience of at least one year in wood/forestry.
Approval will be made from CV and/or interview.
• The applicant shall carry out at least two OLB audits in the relevant scheme 
(Forest Company and/or 
Chain of Custody) as a trainee/auditor, and provide a satisfactory contribution to
be qualified as Lead
Auditor.

Knowledge maintenance and its assessment evolve with standards and 
certification measures. The WFD manager defines the necessary actions to take 
with auditors (information sharing, trainings, calibration meetings, etc).  
The list of qualified auditors is updated by the OLB product manager and 
auditors are recorded in WFD database.  

Auditors’ qualification is maintained as they participate in at least one audit per 
year and/or attend an annual update and calibration training.  

4. Audit Report

The process described in the BMS applies.  
The auditor issues a OLB audit report after each audit.  

reports are examined by a WFD (Wood Forest 
Division) account manager who did not take part in 
the audit.  

If Non-Conformities are issued during the audit, the 
corrective actions implemented by the company are 
evaluated and validated during the next supervisory 
or during an additional audit by the Audit Manager 
and the Technical Manager of Bureau Veritas. 

The certification decision is taken by the Head of the 
Forest-Timber Department on the basis of the 
elements contained in the final audit report and after 
having received proof that all major non-conformities 
have been closed and that the company is in in 
accordance with the requirements of the standard. 

The Bureau Veritas Certification Committee meets 
once a year and all OLB certification files are 
presented for evaluation and comments in order to 
improve the performance of Bureau Veritas. 

The Certification Committee is made up of reference 
persons in all the components relating to certification 
and responsible forest management (environmental 
and social NGOs, associations, companies, etc.). The 
role of the Committee is to ensure the performance, 
integrity and credibility of the Forest-Wood 
Department system of Bureau Veritas Certification. 

The audit report explicitly mentions all the documents that were assessed and 
controlled.   
The audit report is examined by a WFD account manager who did not take part 
in the audit. 

Justification 

Because OLB scheme does not include any 
independent oversight apart from BV, this indicator is 
not covered. 

GP01 OLB EF 

L'original des rapports de non-conformité doit être complété par l'entreprise 
avec une description de l’action corrective mise en œuvre et retourné au 

1006 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

Responsable d'Audit. Les actions mises en œuvre seront évaluées et validées 
durant le prochain audit de surveillance ou complémentaire par le Responsable 
d’Audit et le Responsable Technique de Bureau Veritas. 

7.1 - Décision de certification  

La décision de certification est prise par le Responsable du Département Forêt -
Bois sur  la base des éléments contenus dans le rapport final d’audit et après 
avoir reçu les preuves que toutes les non-conformités majeurs ont été fermées 
et que l’entreprise est en en conformité avec les exigences du référentiel.  

Le Comité de Bureau Veritas Certification se réuni une fois par an et tous les 
dossiers  de certification OLB sont présentés pour évaluation et commentaires 
afin d’améliorer la performance de Bureau Veritas.   
Le Comité de certification est composé de personnes de référence dans toutes 
les composantes relatives à la certification et la gestion forestière responsable 
(ONG environnementales et sociales, associations, entreprise, etc.). Le rôle du 
Comité est de s’assurer  de la performance, de l’intégrité et de la crédibilité du 
système du Département Forêt-Bois de Bureau Veritas Certification. 

(similar language is included in section 13 of GP01 OLB COC) 

PL-CAM-CER-014 V2.4_GP01 OLB CoC, Surveillance audits 

Surveillance audits will take place at least annually but may be more frequen t 
depending on the complexity of the operation and of the certificate holder's level 
of conformity, and on the time needed to resolve the non-conformities detected. 
For the companies that are already FSC and/or PEFC Chain of Custody certified 
by Bureau Veritas Certification, the surveillance audit can be done through a 
document review on the basis of the already existing FSC and/or PEFC audit 
reports, and of the chain of custody procedure which the company will have 
implemented to demonstrate compliance with the OLB standard's requirements. 
The companies that are not FSC and/or PEFC chain of custody certificate 
holder, will be audited on-site annually. Surveillance audits allow Bureau Veritas 
to monitor:  

- The conformity of the organization as assessed  during the initial audit;
The implementation of corrective actions to address minor nonconformities and
eventual recommendations;
- The correct use of the OLB trademark by the certified organization If Bureau 

1007 

C.3.2.4 The
Scheme shall
define the
frequency of
oversight or the
procedure for 
determining the
frequency,
applicable in the 
case of risk-based
oversight.

Findings 

Scheme info 

Covered 

The OLB FM and COC certification procedures 
describe the frequency of surveillance audits, which 
take place every 12 months, with a flexibility of one 
month before or after the certificate anniversary date. 

As explained, “The surveillance audits to be 
performed are scheduled every year but could be 
more frequent depending on the complexity of the 
operations and the level of compliance of the certified 
entity, and the time required to resolve the non-
conformities identified. 

In addition to annual surveillance audits, Bureau 
Veritas Certification may carry out unannounced 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

audits of the certified entity or follow-up audits to 
ensure that non-identified conformities were 
processed and resolved within the set deadline.” 

Justification 

Based on the above, this indicator is covered. 

Veritas Certification identifies significant non-conformities leading to one or 
several major corrective action requests during the period of validity of the 
certificate (maximum 5 years), the company is given a specific timeline 
determined by Bureau Veritas' audit team (3 months maximum) to implement 
the necessary corrective 

GP01 OLB EF 

10.1 -  Audits de Surveillance  

Les audits de surveillance à réaliser sont programmés chaque année. Bureau 
Veritas Certification ou ASI peut également effectuer des contrôles inopinés 
dans les bureaux ou sur le terrain de l'organisme certifié.  

Les audits de surveillance à réaliser sont programmés chaque année mais 
pourraient être plus fréquents en fonction de la complexité des opérations et du 
niveau de conformité de l’entité certifiée, et du temps requis pour résoudre les 
non-conformités identifiées.  

En plus des audits de surveillance annuels, Bureau Veritas Certification peut 
procéder à des audits inopinés de l’entité certifiée ou des audits de suivi afin de 
s’assurer  que les non- 
conformités identifiées ont été traitées et résolues dans le délai fixé.  

Les audits de surveillance permettent de contrôler : 
• La conformité de l’entité telle qu'évaluée lors de l'audit initial ;
• La mise en œuvre des actions correctives mineures et des éventuelles 
observations ;
• L'usage correct de la marque OLB par l’organisme certifié. 

Après chaque audit de surveillance, le résumé public sera mis à jour avec les 
nouvelles observations et éléments identifiés lors de l’audit. Ce résumé sera 
transmis à l’entreprise pour commentaires durant deux semaines. Le rapport 
sera publié une fois que celui -ci aura  
été validé par l’entreprise.  

Si Bureau Veritas Certification identifie des non-conformités significatives 
conduisant à une ou plusieurs demandes d’action corrective durant la période 
de validité du certificat (maximum de 5 ans), il est donné à l’entreprise un délai 
déterminé par l’équipe d’audit Bureau Veritas (3 mois maximum) pour mettre en 
œuvre les actions correctives. A la fin de cette période, un audit complémentaire 

1008 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

est réalisé (vérification documentaire ou évaluation  
sur  le terrain). Selon le résultat de cette nouvelle évaluation, le certificat est 
maintenu ou suspendu pour une période de temps qui permettra à l'entreprise 
de corriger la(les) non-conformité(s) identifiée(s) et d'atteindre la conformité.  
Chaque année, l'organisme certifié fournit à Bureau Veritas Certification la liste 
des produits exploités et vendus issus de "forêts certifiées". L'organisme précise 
l'essence, la nature, la quantité ainsi que les coordonnées des clients de ses 
produits. Ces informations  
permettent de suivre les produits FSC après transfert de propriété. 

C.4 Certification process

C.4.1

Compl
iance 
evalua
tion 

C.4.1.1 The
Scheme shall
include
requirements that
ensure that the
Certification
Bodies applies a
clear basis for:
i) establishing
conformance;
ii) raising
corrective actions 
for non-
compliance, and;
iii) certification 
decision making. 

GP01 OLB EF 

6 - Non conformités et Actions correctives  

Findings 

Scheme info 

Covered 

6.1 - Non conformités  
Les écarts rencontrés au cours de l’audit sont notifiés par le responsable d’audit 
au représentant du candidat. L’Entreprise peut apporter des éléments 
complémentaires pour démontrer la conformité aux exigences, si ces éléments 
sont disponibles.  

Les non-conformités ainsi formalisées doivent répondent aux 3 critères suivants 
:  
• Être objectives et motivées par le non respect d’une exigence de la norme ou
d’une disposition prévue par l’entreprise,
• Être fondées sur des preuves factuelles et en aucun cas sur des 
présomptions,
• Etre comprises et acceptées par l’entreprise.
Selon leur importance, les non-conformités apparaissent sous la forme de
demandes d'actions correctives mineures ou de demandes d'actions correctives 
majeures.

6.2 - Actions correctives  
Il existe deux niveaux d'action corrective : 



Demandes d'actions correctives mineures (DAC mineures) : l'entité peut
être certifiée mais elle doit se mettre en conformité avec les exigences en
question dans l'année qui suit l'audit initial et au plus tard avant le premier 
audit de surveillance ;

The OLB scheme has defined a set of clear indicators 
to establish conformance. At the forest management 
level, a list of applicable legality documentation is also 
checked and adapted for each country.  

Auditors may raise two levels of corrective actions 
(applicable to both FM and COC):  

• Minor corrective action requests (Minor CAR): the
entity can be certified but it must comply with the
requirements in question within one year of the initial
audit and at the latest before the first surveillance
audit. ;

• Major corrective action requests (major CARs): the
entity cannot be certified until major non-conformities 
have been corrected. An additional audit specific to
major non-conformities and their corrective actions 
implemented will take place before any certification
decision. If a major non-compliance is detected during
a surveillance audit, the Company must demonstrate
that this non-compliance has been resolved within a
relatively short period (maximum of three months).

1009 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 



Demandes d'actions correctives majeures (DAC majeures) : l'entité ne peut
pas être certifiée tant que les non-conformités majeures n’ont pas été
corrigées. Un audit complémentaire spécifique aux non-conformités 
majeures et leurs actions correctives mises en œuvre aura lieu avant toute 
décision de certification. Si une non-conformité majeure est détectée
durant un audit de surveillance, l’Entreprise doit démontrer que cette non-
conformité a été résolue dans un délai relativement court (maximum de
trois mois).

Observations can also be issued. 

The certification decision is taken by the Head of the 
Forest-Timber Department on the basis of the 
elements contained in the final audit report and after 
having received proof that all major non-conformities 
have been closed and that the company is in in 
accordance with the requirements of the standard. 

Des  Observations peuvent également être émises 

Justification 

7 - Certification  

Based on the above, this indicator is covered. 

7.1 - Décision de certification  
La décision de certification est prise par le Responsable du Département Forêt -
Bois sur  la base des éléments contenus dans le rapport final d’audit et aprè s 
avoir reçu les preuves que toutes les non-conformités majeurs ont été fermées 
et que l’entreprise est en en conformité avec les exigences du référentiel. 

(Similar description for COC can be found in sections 12 and 13 of GP01 OLB 
EF). 

C.4.1.2 The
Scheme
requirements for 
establishing
conformance
should enable 
comparison with
the definition of
negligible and
non-negligible risk 
as outlined in the
EUTR and
associated guides.

PL-CAM-CER-002 rev1.3.,  

12.NON CONFORMITES ET ACTIONS CORRECTIVES

Findings 

Scheme info 

Partially 
Covered 

12.1. NON CONFORMITE 

Les écarts rencontrés au cours de l'audit sont notifiés par le responsable d'audit 
au représentant du candidat. L'entreprise peut apporter des éléments 
complémentaires pour démontrer la conformité aux exigences, si ces éléments 
sont disponibles.  
Les non-conformités ainsi formalisées doivent répondent aux 3 critères suivants 
:  

- Être objectives et motivées par le non-respect d'une exigence de la norme ou
d'une disposition prévue par l'entreprise,
- Être fondées sur des preuves factuelles et en aucun cas sur des 
présomptions,
- Être comprises et acceptées par l'entreprise.
Selon leur importance, les non-conformités apparaissent sous la forme de

The OLB systems is performance based, and all 
inputs must be verified against all the standard 
indicators.  

Each time an indicator is not met (in any of the 
standards, including the Supplier Evaluation Program, 
for which all inputs go through the full checklist – not 
risk  based), a non-conformity (major or minor) is 
raised, and a corrective action must be implemented. 

In justified cases, the OLB certificate may be 
suspended.  

However, requirements for non-conformities are 
structured in a way that there is a potential risk that a 

1010 

ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

non-conformity may represent an infringement of 
legislation and that, as a result, illegal wood may enter 
the EU market without mitigation measures to prevent 
this from occurring for a period of up to 3 or 12 months. 

Justification 

Based on the above, this indicator is partially covered. 

demandes d'actions correctives mineures ou de demandes d'actions correctives 
majeures. 

12.2. ACTIONS CORRECTIVES  

Il existe deux niveaux d'action corrective : 

- Demandes d'actions correctives mineures (DAC mineures) : l'entité peut être
certifiée mais elle doit se mettre en conformité avec les exigences en question
dans l'année qui suit l 'audit initial et au plus tard avant le premier audit de
surveillance

- Demandes d'actions correctives majeures (DAC majeures) : l'entité ne peut
pas être certifiée tant que les non-conformités majeures n'ont pas été corrigées.
Un audit complémentaire spécifique aux non-conformités majeures et leurs 
actions correctives mises en œuvre aura lieu avant toute décision de
certification. 

Si une non-conformité majeure est détectée durant un audit de surveillance, 
l'Entreprise doit démontrer que cette non-conformité a été résolue dans un délai 
relativement court (maximum de trois mois).  

Des  Observations peuvent également être émises :  
Observations: commentaires concernant soit des dysfonctionnements ou des 
risques non traités par le référentiel, soit une adéquation imparfaite entre la 
gestion constatée sur le terrain et les exigences du référentiel OLB. L'entité peut 
être certifiée mais elle doit améliorer les points identifiés.  

L'entreprise peut proposer un plan d'actions, si elle le souhaite, et le transmettre 
au Responsable d'Audit ou le Responsable Technique de Bureau Veritas afin 
d'être validé avant sa mise en œuvre.  

Néanmoins, l'entreprise peut engager des actions correcti ves pour solutionner 
les non-conformités dès lors que les rapports de non-conformité ont été signés.  

L'original des rapports de non-conformité doit être complété par l'entreprise 
avec une description de l'action corrective mise en œuvre et retourné au 
Responsable d'Audit. Les actions mises en œuvre seront évaluées et validées 
durant le prochain audit de surveillance ou complémentaire par le Responsable 
d'Audit et le Responsable Technique de Bureau Veritas. 

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PL-CAM-CER-014 V2.4_GP01 OLB CoC 13.1,  

12. NON-CONFORMITIES AND CORRECTIVE ACTIONS

12.1. NON-CONFORMITIES  
The non-conformities identified during the audit are presented and commented 
to the applicant by the Lead Auditor. The company can then provide additional 
information required to demonstrate conformity, if available. The non-
conformities shall always meet the 3 following criteria:  

- Be objective and motivated by failure to meet a specific standard requirement.
- Be based on facts and documented evidence.
- Be understood and accepted by the Applicant.
According to their importance, non-conformities can be raised as minor 
corrective actions requests or major corrective actions requests.

12.2. CORRECTIVE ACTIONS There are two types of corrective action:  

- Minor corrective actions requests (minor CAR): the entity can be certified but it 
must demonstrate conformity with the standard's requirements within 12 months 
following the initial audit and at the latest before the following surveillance audit;
- Major corrective actions requests (major CAR): the entity cannot be certified as 
long as the major nonconformity has not been corrected. A complementary audit
focused on an evaluation of the major non-conformity and corrective actions 
implemented shall take place before any certification decision.

If a major nonconformity is detected during a surveillance audit, the applicant 
entity shall demonstrate that the nonconformity has been addressed within a 
relatively short time frame (maximum of three months).  

Recommendations can also be presented: 

- Recommendations: remarks concerning either dysfunctions, or a threat which
is not dealt with by the standard, or potential improvements detected by the
auditors, but for an element which, however, meets the standard requirements.
The entity can be certified but it has to take into consideration the weakness 
highlighted.

The entity can propose a corrective action plan, if it wishes to do so, and send it 
to Bureau Veritas' auditors and Technical manager so as to have it approved 

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ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

before implementation. Nonetheless, the Applicant can also start implementing 
corrective actions to solve the nonconformities as soon as the non -conformity 
reports have been signed. 

The original nonconformity reports must be filled in by the Company with a 
description of the corrective action implemented and returned to the Lead 
Auditor. The actions taken will be assessed and validated during the following 
surveillance/complementary audit by the auditors and the Bureau Veritas 
Certification Technical manager. 

GP01 OLB EF  1.2 version 

11 - Suspension et retrait du certificat 

Le Responsable Technique OLB de Bureau Veritas Certification ou le Comité de 
certification prend la décision de suspendre ou retirer un certificat si une(des) 
non-conformité(s) ont été identifiée(s) et qu’elle(s) n’a(ont) pas été traitée(s) 
dans le délai requis :  

• Si la non-conformité est due à une action involontaire, elle justifie un maintien
conditionnel du certificat. Le certificat est maintenu sous réserve de la
réalisation de la ou des actions correctives dans un délai défini.
• Si la non-conformité est due à une action délibérée de l’entreprise, elle justifie,
selon la gravité des faits, une suspension temporaire ou un retrait définitif et
immédiat du certificat.
En cas de non-respect grave et indiscutable des exigences du référentiel OLB
ou des conditions d'usage du label OLB, Bureau Veritas Certification s’autorise
à suspendre le certificat temporairement.

Dans le cas d’une suspension, l’entreprise certifiée a un délai d’une semaine 
pour faire appel à cette décision et fournir des informations complémentaires ou 
des clarifications si nécessaires.  
Afin de lever la suspension, un audit complémentaire (par une  vérification 
documentaire ou une évaluation de terrain) doit être réalisée afin de vérifier la 
mise en œuvre des actions correctives pour traiter les non -conformités 
identifiées.  

3.2.2 

C.4.1.3 The
Scheme shall
include

Réf: RF03 OLB CdC v3.6 

Findings 

1.1.7 - 

L’entreprise s’assure  que toute transaction commerciale (achat et 

Not 
Covered 

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vente) de bois se fasse  en conformité avec les lois et règlementations 
nationales et internationales applicables, y compris celles relatives au transport 
et à la commercialisation des  bois. 
1.4.5 
s’assure  et démontre que ceux-ci ne proviennent pas de sources i llégales. 

- En cas d’approvisionnement en bois non certifiés, l’entreprise 

Méthode d’évaluation : mise en place d’une diligence raisonnée voir ANNEXE 1  

requirements that 
ensure that the 
above 
requirements are 
in line with the 
requirements of 
the EUTR to 
prohibit illegal 
material or 
material with a 
non-negligible risk 
category being 
placed on the EU 
market. 

Scheme info 

This indicator only applies to COC companies, which 
shall “ensure that any commercial transaction 
(purchase and sale) of timber is carried out in 
accordance with applicable national and international 
laws and regulations, including those relating to the 
transport and marketing of timber”. 

The concepts of “negligible” and “non-negligible” risks 
are not used in the standard, which is performance 
based and not risk-based. Like other performance-
based certification systems, it may occur that a 
company has placed products in the EU market with 
non-conformities (in which case a corrective action is 
required to maintain certification). 

The criteria and indicators evaluated during the 
performance-based evaluation at the forest 
management level are comprehensive and aligned 
with the EUTR requirements.  

At the COC level, the standard has also been 
developed to align with the EUTR requirements, and 
therefore, when correctly implemented, OLB COC 
companies sourcing solely from OLB forests may 
qualify these inputs as “negligible risk”.  

OLB COC certificate holders using the credit system 
may mix OLB certified and non OLB inputs, provided 
that the non-OLB inputs either:   

-

-

Are certified against an approved scheme, 
FSC, PEFC endorsed schemes, BV DDS or 
LegalSource. No further checks are made
to these inputs, and all claims (including
Mix) are accepted. To conclude if these
sources  are considered negligible risk…
Comply with the requirements in Annex 1 of
the COC std (“Supplier Evaluation
Program”). In this case, the robustness of

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the legality evaluation will be impacted by 
the competence of the certificate holder’s 
assessors.  During the annual surveillance 
audits, the OLB auditor checks the quality 
of the Supplier Evaluation Program 
implemented by the certificate holder, which 
mitigates potential risks.  

Also,  requirements for non-conformities are structured in 
a way that there is a potential risk that a non-conformity 
may represent an infringement of legislation and that, as 
a result, illegal wood may enter the EU market without 
mitigation measures to prevent this from occurring for a 
period of up to 3 or 12 months. 

Justification 

Base don the above, this indicator is not covered. 

C.4.1.4 the
Scheme shall
include
requirements that
ensure that the
decision process 
to certify
organisations, or 
maintain
certification of
CHs,  is free from
conflict of interest
and includes 
checks  and
balances.

GP01 OLB EF  1.2 version 

7.1 - Décision de certification  
La décision de certification est prise par le Responsable du Département Forêt -
Bois sur  la base des éléments contenus dans le rapport final d’audit et après 
avoir reçu les preuves que toutes les non-conformités majeurs ont été fermées 
et que l’entreprise est en en conformité avec les exigences du référentiel.  

Le Comité de Bureau Veritas Certification se réuni une fois par an et tous les 
dossiers  de certification OLB sont présentés pour évaluation et commentaires 
afin d’améliorer la performance de Bureau Veritas.   
Le Comité de certification est composé de personnes de référence dans toutes 
les composantes relatives à la certification et la gestion forestière responsable 
(ONG environnementales et sociales, associations, entreprise, etc.). Le rôle du 
Comité est de s’assurer  de la performance, de l’intégrité et de la crédibilité du 
système du Département Forêt-Bois de Bureau Veritas Certification. 

11 - Suspension et retrait du certificat 

Le Responsable Technique OLB de Bureau Veritas Certification ou le Comité de 
certification prend la décision de suspendre ou retirer un certificat si une(des) 

Findings 

Scheme info 

Covered 

The scheme owner (Bureau Veritas) includes a policy 
related to impartiality for all certification service that 
they are providing. In addition, PL-CAM-CER-002 
rev1.3., 9.1 and PL-CAM-CER-014 V2.4_GP01 OLB 
CoC 9.1 state that Bureau Veritas recruits only 
specialist that are independent. 

The Bureau Veritas Certification Committee meets 
once a year and all OLB certification files are 
presented for evaluation and comments in order to 
improve the performance of Bureau Veritas. 

The Certification Committee is made up of reference 
persons in all the components relating to certification 
and responsible forest management (environmental 
and social NGOs, associations, companies, etc.). The 
role of the Committee is to ensure the performance, 

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ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

integrity and credibility of the Forest-Wood 
Department system of Bureau Veritas Certification. 

The OLB certification procedures handbook (PL-
CAM-CER-015) 
explains in further detail how the members of the 
Certification Committee must be free from conflict of 
interest.  

Direct interviews/ discussions / Stakeholder input 

In reaction to the original conclusion ‘partially 
covered” and the justification “Part of this indicator is 
not met: the process to ensure that certification 
decisions from the Certification Committee are free 
from conflict of interest is not clear”, BV points out:  

Dans le manuel de procédures OLB la prévention des 
conflits d’intérêt  est présentée au  7.2.6. (Note: this 
manual had not been reviewed in previous draft 
versions of this assessment  report) 

Justification 

BV’s input has been taken into account and this 
indicator is covered.  

non-conformité(s) ont été identifiée(s) et qu’elle(s) n’a(ont) pas été traitée(s) 
dans le délai  
requis :  

• Si la non-conformité est due à une action involontaire, elle justifie un maintien
conditionnel du certificat. Le certificat est maintenu sous réserve de la
réalisation de la ou des actions correctives dans un délai défini.
• Si la non-conformité est due à une action délibérée de l’entreprise, elle justifie,
selon la gravité des faits, une suspension temporaire ou un retrait définitif et
immédiat du certificat.

En cas de non-respect grave et indiscutable des exigences du référentiel OLB 
ou des conditions d'usage du label OLB, Bureau Veritas Certification s’auto rise 
à suspendre le certificat temporairement.  

Dans le cas d’une suspension, l’entreprise certifiée a un délai d’une semaine 
pour faire appel à cette décision et fournir des informations complémentaires ou 
des clarifications si nécessaires.  
Afin de lever la suspension, un audit complémentaire (par une vérification 
documentaire ou une évaluation de terrain) doit être réalisée afin de vérifier la 
mise en œuvre des actions correctives pour traiter les non -conformités 
identifiées.  

PL-CAM-CER-015 

7.2.6 Responsable de la décision de certification 

[…] Le responsable de la décision de certification doit observer le principe 
d’impartialité. En effet :  

-

-

Aucun conflit d’intérêts, y compris financier ou autre intérêt
commercial, dans la prise de décision de certification
Spécifiquement, le responsable de la décision de certification ne doit
avoir participé à l’audit pour lequel il prend la décision de certification
ni en tant qu’auditeur principal, auditeur, observateur ni en tant 
qu’expert technique.

9.5.7. Impartialité du processus décisionnel 

Le comité d’impartialité examine les processus  d’audit, de certification et de 
prise de décision. Cela peut être réalisé par un membre externe (ou interne 
n’ayant pas pris part au processus  de certification), en vérifiant dans un 

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ANNEX 8 : SCHEME ASSESSMENT REPORT – OLB 

échantillon de fichiers de BV Douala Dpt CER-FOR les processus  et en 
présentant les résultats de leur évaluation à une réunion du comité 
d’impartialité.  

BV Douala Dpt CER-FOR doit :  

-
-

-

Inviter le ou les membres à effectuer l’examen
S’assurer  que la « déclaration de confidentialité et de conflit
d’intérêts » est signée
Fournir la liste complète des certification accordées dans la période 
considérée

Les membres sélectionnent des échantillons de cette liste et BV Douala Dpt 
CER-FOR donne accès à tous les enregistrements du processus d’audit, de 
certification et de prise de décision.  

Cette revue comprend :  

-

-

-

-

Les auditeurs/vérificateurs ont-ils été utilisés sans conflit d’intérêts 
avec le client ?

Existe-t-il d’autres éléments indiquant que Bureau Veritas fournit des 
services au client qui pourraient être en conflit avec les services de
certification ?
Y a-t-il eu des preuves de la décision prise par un membre de l’équipe 
d’audit ?
Y a-t-il eu d’autres indications selon lesquelles les processus  de
certification d’audit et de prise de décision n’ont pas été réalisés de
manière impartiale ?

Cet examen peut être effectué avant la réunion sur l’impartialité ou dans le 
cadre de la réunion sur l’impartialité, de sorte que les résultats de l’examen font 
partie de l’ordre du jour de la réunion. BV Douala Dpt CER-FOR doit répondre à 
toute question soulevée dans cette revue.  

1017 

About us 

Preferred by Nature (formerly NEPCon) is an international non-profit organisation working 
to support better land management and business practices that benefit people, nature and 
the  climate.  We  do  this  through  a  unique  combination  of  sustainability  certification 
services, projects supporting awareness raising, and capacity building. 

For more than 25 years, we have worked to develop practical solutions to drive positive 
impacts in production landscapes and supply chains in 100+ countries. We focus on land 
use,  primarily  through  forest,  agriculture  and climate impact commodities, and re lated 
sectors such as tourism and conservation. Learn more at www.preferredbynature.org  

Contact 

Christian Sloth  
Email:  csloth@preferredbynature.org  
Phone: +45 3158 7981 
Skype:  christiansloth 

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