Despite best efforts by the trade and certification schemes, the European Commission is not giving certified material a ‘green light’ under the EU Timber Regulation (EUTR). The basis of compliance for companies which first place timber on the EU market is a due diligence system, which ensures exclusion of illegally harvested material. But given these parameters, FSC has sought to make its certification model a complete platform for due diligence systems, especially for companies involved in ‘first placing’.

The EUTR’s Implementing Act requires that, before certification schemes can be used in due diligence risk assessment and risk mitigation, they must meet four criteria. These are listed below, along with what FSC has done to meet the requirements. They must:

  • Have a publicly available system of requirements, including those of the regulation. FSC will comply in all respects now that its national, regional, generic and controlled wood standards have been directed to include custom and trade laws within their regulatory scope.
  • Ensure third-party checks, including field visits, are made at regular intervals of no longer than 12 months. Such checks are standard within FSC’s certification rules for both forest management and chain of custody. Technically, there’s an exception in group schemes, operated for small and/or low intensively managed forests and woodlands. Under these the inspection period may be greater than 12 months. However, FSC believes this is acceptable under the EUTR because each woodland on its own poses only negligible risk.
  • Include traceability of timber or timber products before they are placed on the EU market. There is already a level of traceability built into the FSC system covering suppliers, receivers and quantities. However, to satisfy the EUTR, FSC has issued an advice note requiring certified suppliers to provide on request the common name of the timber species used in products and country/region of harvest. This must be passed upstream until the information can be obtained. Longer term, FSC is aiming for timely traceability throughout the supply chain via an online transaction recording mechanism.
  • Include controls to exclude unknown or illegally harvested products from the supply chain. FSC already seeks to exclude illegally harvested timber from the chain of custody by requiring separation of certified and uncertified products. The exception of ‘minor components’ has now been withdrawn.

FSC has never set out to provide an entire due diligence system, but our aim is to demonstrate that consideration of FSC-certified material in the due diligence equation can be made in confidence, knowing that our rules have been extended to meet all EUTR Implementing Act requirements. So we trust that FSC-certified products carry a much lower risk under the terms of the Regulation than non-certified or material covered by less