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Monday, 18 September 2017
Updates to Chain of Custody Directive and Interpretations

September 18, 2017

On September 8, 2017, FSC published a new and updated Chain of Custody Directive (FSC-DIR-40-004) and interpretations. The updated documents are available for download below as well as the updated documents in track changes form.

The following provides a brief summary of the changes to the documents:

FSC Directive on Chain of Custody Certification –
5 amended advice notes – all amendments are minor and intended for updates to effective dates and FSC terminology.
3 new advice notes:

  • Advice-40-004-14 Supply Chain Integrity – presents requirements for all certificate holders during the transition period between V2-1 and V3-0 to ensure that certificate holders support transaction verification and fiber testing activities by their certification bodies.
  • Advice-40-004-15 Neutral materials that cannot be distinguished from FSC certified ingredients – creates a new requirement for products produced with FSC certified inputs and neutral materials. When the neutral materials cannot be distinguished from the FSC inputs, and may be misinterpreted as being FSC-certified (e.g. agricultural fibers, synthetic rubber), the organization shall only label and claim the products as FSC Mix and the FSC ingredients are identified via the label or additional statements.
  • Advice-40-004-16 Disassociated organizations operating as outsourcing contractors – provides a delay in the implementation of clause 12.4.e) of the standard. FSC is further evaluating impacts and relevance before taking a final decision on the requirement.

    12.4 The organization shall establish an outsourcing agreement with each non-FSC-certified contractor, specifying at minimum that the contractor shall:

    e) notify the organization within the period of 10 business days if the contractor is included in the list of organizations that are disassociated from FSC, in accordance with the FSC-POL-01-004, and therefore subsequently ineligible to provide outsourcing services to FSC-certified organizations.

FSC Interpretations on Chain of Custody
6 new interpretations:

  • INT-STD-40-004-32 (p. 26) – Sale of FSC Controlled Wood to FSC Project Certification (FSC-STD-40-006) applicants is allowed.
  • INT-STD-40-004-33 (p. 26) – Organizations working with FSC certified contractors do not need to provide the contractors with documented procedures.
  • INT-STD-40-004-34 (p. 26) – Clarification on the term “common operational procedures” for multi-site certification.
  • INT-STD-40-004-35 (p. 27) – Organizations that are informed of non-conforming products from their suppliers will need to apply requirements in clause 1.6.
  • INT-STD-40-004-36 (p. 27) – Further explanation of the Note in the product group section about equivalent input materials and credit accounts for reclaimed and virgin inputs.
  • INT-STD-40-007-03 (p. 29) – Organizations cannot include manufacturers in their supplier audit program.

FSC Interpretations on Normative Framework
1 new interpretation

  • INT-STD-20-001-22 (p.16) – Certification bodies can access non-FSC related records to assess conformity to certification requirements.

For questions about Chain of Custody and the above updates, please contact Lori Knosalla at