FSC Chain of Custody: into the realm of fantasy

The FSC is set to continue on its seemingly inexorable slide into becoming a ‘self-certification’ system with new changes to the Chain of Custody procedures. As announced in the most recent FSC Newsletter (see below), the FSC is currently piloting what are called ‘multi-site’ procedures, in which the FSC’s accredited certifiers would not actually check all the relevent company facilities in order to issue a Chain of Custody certificate.

This will add a further layer of discredit to what is already an opaque, muddled and highly doubtful system. FSC’s Chain of Custody process does not require checking or labelling all the way through to the end-user or retailer, nor does it provide information on the actual FSC-certified source of the products which are in the ‘chain’. Thus it is completely impossible for the end consumer or members of the supply chain to know where a given product originates.

Unlike forest management certificates, certifiers are not obliged to provide publicly available reports of the Chain of Custody certificates – so there is no way to check that assessments of the various companies in the supply chain have been carried out rigorously. However, previous reports of FSC Secretariat’s regular checks on the accredited certifiers have revealed that the certifiers have overlooked irregularities – some of them major – in the Chain of Custody procedures of some of the companies to which they had issued certificates.

Furthermore, an internal FSC report obtained by FSC-Watch reveals that, over the years, around 2,000 Chain of Custody certificates had been suspended or cancelled (the reasons for this are not known or stated, but probably including that the forest from which the product originated lost its forest management certificate, or closure of the company, and fraud). It seems highly doubtful that the FSC has managed to ensure that all the products passing through these thousands of de-certified chains of custody have, in fact, been ‘de-labelled’ as having a Chain of Custody certificate. Because this information about cancelled certificates is not in the public domain, members of the private sector who genuinely want to encourage better forest management by purchasing or specifying FSC products are put in the difficult position of not knowing whether a given company is genuinely still Chain of Custody-certified or not.

The new FSC system now being piloted will allow companies that appear to have similar procedures across several sites not to have all of them inspected as being chain of custody ‘secure’. This will clearly increase the scope for fraud in a system in which there are already doubts about the willingness or ability of the certifiers to conduct the necessary detailed ‘forensics’ to detect abuse of the system. As with the so-called ‘Controlled Wood Standard’, it will increase the likelihood that wood from non-certified (and possibly illegal) sources enters into the FSC-certified supply chain.

As with other FSC policies, such as that concerning ‘mixed-sources labelling’, this new procedure “has been developed to facilitate certification for larger companies” – who will no doubt be pleased that they can now, in effect, partially certify themselves. But it serves once again to undermine the credibility of the FSC.


The first two FSC Chain of Custody (CoC) certificates resulting from a pilot test of the new draft Multi-site Chain of Custody certification standard have been issued.

Certified companies Danzer Group and SAPPI Fine Paper Europe can now market their products with the FSC trademark consistently throughout their operations on an international scale. FSC Multi-site CoC certification has been developed to facilitate certification for larger companies that have a number of production facilities, warehouses or sales agencies, at which fundamentally the same functions, methods or procedures are carried out.

FSC Newsletter, March 30th, 2007


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