Guidance on Controlled Wood Implementation

Updated 4th August 2015: Guidance Document : Controlled Wood implementation for companies using FSC-STD-40-005 V2-1 Standard for company evaluation of FSC Controlled Wood.

This guidance document provides an overview of the aspects that were raised in motion 24 that was passed during the past FSC General Assembly in South Africa and later advice that FSC International has produced to support the implementation of the motion.

It finally provides interpretation and guidance to support the implementation of the motion in Australia.

Issues addressed in this guidance document:
1. Use of the FSC Australia Risk Assessment Matrix and implementation of Annex 3 of FSC-STD-40-005 Version 2-1 Controlled Wood verification program.

FSC ADVICE-40-005-09 Use of guidance and risk designations developed by FSC accredited National Initiatives

1. Risk designations for a specific country/ region conducted by FSC accredited National Initiatives and approved by FSC IC shall be considered conclusive and shall be used by any company sourcing non-certified forest-based material under a controlled wood verification program from that specific country/ region.

2. Companies will have a period of up to12 months after the approval date to align their controlled wood verification programs to the approved risk designation by a National Initiative. Certification bodies shall be responsible for informing their certificate holders of newly approved risk designations.

3. FSC-STD-40-005 V2-1 Clause 13.3 also requires that any formal guidance (different from risk designations) produced by an FSC accredited National Initiative shall be used by the company. Guidance may include details on relevant stakeholders, areas of high conservation values or consultation procedures. Ignorance of guidance is considered as a noncompliance.

Implementation in Australia
FSC Australia has developed a Risk Assessment Matrix for all bioregions in Australia which has been approved by FSC International. The use of the Australian Risk Assessment Matrix is mandatory for all companies sourcing from suppliers within Australian bioregions.

FSC Australia is developing a guidance document on the implementation of Annex 3 of FSC-STD-40-005 which shall be used by ALL companies sourcing from ‘unspecified risk’ bioregions in Australia.

ALL companies sourcing from ‘unspecified risk’ bioregions in Australia shall implement a field verification program in accordance to Annex 3 of FSC-STD-40-005 and the guidance document that FSC Australia is developing. The FSC Australia guidance document will be effective upon approval. It is anticipated that all companies sourcing from suppliers within Australian bioregions shall be in compliance to this guidance document from January 2011.

2. Operations with substantial complaints regarding Controlled Wood and implementation of FSC-STD-30-010 Controlled Wood standard for Forest Management enterprises

Motion 24:
The company verification program may not be used when there are multiple and significant complaints made to FSC-IC regarding an FMU operation in areas of unspecified risk. Instead, the FMU must be independently certified according to FSC-STD-30-010.

The motion requires FSC IC to make the decision to request an independent certification process against FSC-STD-30-010 when multiple and significant complaints regarding FM suppliers risks the credibility of the company verification program according to FSC-STD-40-005. FSC Australia considers that independent certification against FSC-STD-30-010 provides a higher grade of transparency and credibility as the FM operation takes full responsibility of the practices at the FMU level and the maintenance of the certificate.

Where FSC Australia is in receipt of multiple and/or significant complaints it will forward this information to FSC IC and the relevant Certification Body (or Certification Bodies) in the context of Motion 24.

3. High Conservation value forests in the Controlled Wood standard – Special focus on stakeholder consultation

Motion 24:
Where there is unspecified risk and where these areas have not been determined at the Annex 2 level by the National Initiative, FSC must ensure the implementation of field verification audits of HCVF areas are equally rigorous as for a full certification audit. A guidance note from FSC IC will be prepared for Certification Bodies.

FSC advice:
ADVICE-40-005-14 How can low risk be confirmed for Category ‘C’ of FSC-STD-40-005 V2-1 Clause 1.1?

1.Compliance with Indicator 3.1 may be demonstrated as follows:

a) The district of origin of the timber is not located in any of the mapped areas of high conservation values (as listed in 3.1) in a certain country, or

b) There are no ecoregionally significant high conservation values in the district of origin according to independent verifiable information at the district/ FMU level (NGO reports, environmental impact assessments, etc).

2. Compliance with Indicator 3.2 shall be demonstrated as follows:

a) A strong system of protection of high conservation values is in place. The definition of strong shall be based on the effectiveness of law enforcement in the country. This can be demonstrated through a high rating (? 75%) in the World Bank "rule of law" index (, and

b) Significant support by relevant national / regional stakeholders from the assessed district, or

c) The company has agreed to an approach of HCVF protection at the forest management unit level with national / regional environmental stakeholders from the assessed district.

3. Compliance with Indicator 3.2 cannot be demonstrated if there is substantial objection from relevant national / regional stakeholders against a ‘low risk’ designation for the HCVF category

Implementation in Australia:
Stakeholder consultation is a critical step on identifying the risks of threats to HCVs. Stakeholder consultation shall also happen at the FMU level for the implementation of Annex 3 of FSC-STD-40-005

FSC Australia has determined that HCVs are present in all bio-regions in Australia, hence 3.1 indicates unspecified risk.

Current legislation, programs and tools such as the Comprehensive, Adequate and Representative (CAR) reserve system based on the JANIS criteria and the Regional Forest Agreements (RFAs) have not passed the test of wide stakeholder acceptance as 'strong system of protection'. Evidence still exists that HCV are still being impacted across Australia. Therefore, risk remains unspecified at the Annex 2 level for indicator 3.2.

FSC Australia advises that no ‘low’ risk designation for HCVs in any Australian bio-region can be determined with the absence of broad relevant stakeholders support.

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