Chain of Custody Standard Public Consultation

Round 3

The third draft of the revised Chain of Custody standard (FSC-STD-40-004) is open for public consultation from June 15, 2016, to August 31, 2016.

Watch a webinar from FSC US about this third draft of the revised standard to learn more. The webinar provides an overview of the revision process, the proposed changes in the third draft, and instructions on how to comment on the draft.

The following are some of the main proposed updates in the Chain of Custody standard revision:

Transaction Verification
New transaction verification requirements are proposed that would allow certification bodies to verify FSC transactions between certificate holders. It is suggested that certificate holders would go through a risk assessment that will classify them as being part of either high-risk or low-risk supply chains. Those with a high-risk classification will be required to use the FSC Online Claims Platform (OCP), but for the majority of certificate holders, who would be classified as low-risk, the use of the OCP would be optional – although still recommended.

The introduction of transaction verification requirements in the FSC Chain of Custody standard will also result in changes for certification bodies. Therefore, FSC is proposing that four new clauses are added to the FSC Standard for Chain of Custody Evaluations (FSC-STD-20-011 V4-0). These four new clauses are included in the draft Chain of Custody standard so certificate holders and certification bodies can review the proposed transaction verification requirements for both standards at the same time. The clauses from FSC-STD-20-011 are only included in the draft Chain of Custody standard now to assist stakeholders during the consultation and will be removed prior to final approval.

Cross-site Credit and Percentage Accounting
The revision includes the proposal for COC certificate holders to implement cross-site credit accounts and percentage calculations (new). In 2011 and 2012, FSC conducted a pilot project to explore how cross-site credit accounting could be applied by certificate holders. FSC received positive feedback from certificate holders involved in the pilot, and the FSC Board of Directors would now like to seek stakeholder input on the proposal to include cross-site control for both the credit and percentage system in the revised Chain of Custody standard. Visit the FSC International website for more information.

Reduction to labeling threshold for FSC Recycled label
Under the current rules, FSC Recycled products that do not reach the 85% threshold can still be labelled as FSC Mix, if the product has more than 70% of certified content. A reduced labeling threshold of 70% for FSC Recycled wood products would enable more companies that produce products with exclusively reclaimed content to apply the FSC Recycled label on their products and would reduce confusion regarding the gap between 70-84%, where only an FSC Mix label is currently applicable.

Clarification of credit system requirements
To ensure the credit system is applied equitably across the entire FSC system, the membership passed Motion 46 at the 2011 General Assembly which asked FSC to clarify the requirements within the credit system. Therefore, refined credit system requirements have been introduced, including clarifying credit accounting for assembled products, and an extension of the credit period from 12 to 24 months.

Incorporation of advice notes and standard interpretations
In an effort to streamline and reduce the number of documents stakeholders must consider, the revision process has also included a consolidation of advice notes and other standard interpretations.


Stakeholder participation and feedback is essential to the revision process, and all stakeholders are encouraged to provide their comments on the revised requirements for both the Chain of Custody Standard and the Standard for Chain of Custody Evaluations. This third revision contains changes based upon the feedback from stakeholders during the first and second round of consultations. Following this third consultation, the standard will be further refined based on the comments and feedback received.

For this third round of consultation, FSC is using a new web-based consultation platform to help stakeholders with their review of the standard and to collect comments. Access the consultation platform.

Please take note of the following before using the consultation platform:

  • While you can save, pause, and continue your review at any time, you will need to use the same device (computer/tablet) to do so.
  • Once you register for access to the consultation platform, you will receive an email with a link to access the survey. Keep this email and link easily accessible to ensure you can continue working on your comments.
  • Each comment must specify the exact reference to the standard to which the comment relates (e.g. clause number, page, section). Comments submitted without a reference will be discounted by FSC.


FSC US hosted a webinar on June 29, which included an introduction to the revised standard, the proposed changes in the third draft, and a walkthrough of the new consultation platform.

Watch the recorded webinar.

Thank you for your participation and if you have questions about the revised Chain of Custody Standard, please contact Lori Knosalla, FSC US Policy and Standards Manager: Chain of Custody (