FSC US Controlled Wood National Risk Assessment (US NRA)

In June 2018, FSC US submitted a final draft FSC US Controlled Wood National Risk Assessment (US NRA) for the conterminous United States to FSC International. FSC International is responsible for the final review and approval process. Since that time, FSC US has been working to address concerns and questions raised by FSC International regarding our submission.

In early-December, FSC US received conditional approval of the US NRA, and on January 24, 2019, we submitted a revised final draft and additional supplementary materials to FSC International that we believe will address all remaining conditions for approval.

The most significant changes in the revised final draft (compared with the draft submitted in June 2018) are to the Control Measures for Categories 3 and 4.
(These changes were approved by the FSC US Board in December 2018):

  • Removal of the Category 3 and Category 4 Control Measures whereby a company demonstrates that it is avoiding materials that come from places where HCVs were threatened by forest management activities or from places where the materials resulted from a forest conversion. As previously drafted, this Control Measure would have made it difficult for a company to take advantage of Clause 4.13 in the Controlled Wood Standard, which allows development of alternative Control Measures, as long as they are more effective than those in the NRA and meet additional conditions.
  • Removal of the Category 4 exception for very small companies – FSC International will not approve any exceptions.
  • Addition of a Category 4 Control Measure that addresses forest materials from limited and legal sources of conversion (e.g., conversion that results in conservation benefits, publicly approved changes in zoning in urban areas, etc.) and does not come from sources where the conversion threatens High Conservation Values. This revised Control Measure addresses one of the most prominent topics during US NRA development process.

There are no changes to the Category 3 and Category 4 Control Measures associated with the Controlled Wood Regional Meetings and implementation of resulting mitigation options.

Additional changes in the revised final draft include:

  • A number of formatting changes
  • Additional language to clearly indicate what content is normative and what is not
  • Updated information regarding NRA Working Group membership
  • Clarifications, additional sources of information and/or expanded content for the risk assessments associated with some risk topics, but NO CHANGES TO RISK DESIGNATIONS
  • Small refinements to the specified risk areas of limited HCVs to improve consistency between specified risk areas (e.g., excluding areas that are permanently protected for all HCV 3 specified risk areas, not just some)

Revised Final Draft Risk Designations:
Category 1 - Illegally harvested wood: Low Risk
Category 2 - Wood harvested in violation of traditional and human rights: Low Risk
Category 3 - Wood from forests in which high conservation values are threatened by management activities: Specified Risk in portions of the Pacific Coast, Rocky Mountain, Mississippi Alluvial Valley, Appalachian and Southeast Regions
Category 4 - Wood from forests being converted to plantations or non-forest use: Specified Risk for specific counties within the Pacific Coast and Southeast Regions
Category 5 - Wood from forests in which genetically modified trees are planted: Low Risk


  • The following revised final draft document has been submitted to FSC International, but has not yet been approved
  • The 6-month time period for certificate holders to incorporate the US NRA into their due diligence system has not yet begun
  • Certificate holders that source from the conterminous United States are not yet required to use the US NRA. However, certificate holders may adapt their due diligence system to use this revised final draft if they wish, following Clause 3.1.1.b of the Controlled Wood standard (FSC-STD-40-005 V3-1)

Revised Final Draft Documents Available:
1. FSC US Controlled Wood Risk Assessment - the full US NRA is available as a single pdf document which includes the required risk assessment template, along with a number of annexes that provide supplementary information. For Categories 2, 3, and 4, we recommend focusing on the annexes associated with those sections instead of the main template document. These annexes provide additional guidance, context, and details that informed the risk designations and do so in an easier to read format. Additional materials that may assist your review include:

2. Revised Consultation Report from the second public consultation

3. Static maps of areas with specified risk - all maps are in a single pdf document. A spatial data layer is also available. To request this data, please email j.anderson at us.fsc point org. A static map of all HCV 1 Critical Biodiversity Areas is also available. This map includes both those with low risk and with specified risk.

More details regarding the expansion of the US NRA to include Alaska and Hawaii will be available in the coming months.

Please contact FSC US with any questions you have about the FSC US Controlled Wood National Risk Assessment.