Technical Updates

Thursday, 18 April 2019
FSC US Controlled Wood National Risk Assessment Approved

April 18, 2019

After seven years in development, reviews, consultations and interim approvals, FSC International approved and published a Controlled Wood Risk Assessment for the conterminous United States (i.e., the ‘Lower 48’ states) on April 5, 2019.

Globally, National Risk Assessments assess risks associated with the undesirable forestry activities, including illegal harvest, forest management that violates workers or indigenous peoples’ rights or threatens high conservation values, conversion of forest to non-forest uses, and use of genetically-modified trees. In the United States, the primary risks identified are forest conversion and threats to high conservation values; the FSC US National Risk Assessment (US NRA) defines landscapes in which these risks exist.

The US NRA requires that if a company wishes to use non-certified materials from landscapes with unspecified risk for one of the undesirable activities above, the company must implement mitigation activities that over time will help to reduce the identified risks within these landscapes.

The US NRA is a key component of the FSC Controlled Wood system, which underpins FSC Mix claims and allows companies to mix certified and non-certified materials, under specific conditions. This decision by the FSC membership led to significant growth in the FSC system. By allowing mixing, FSC opened the door to many more manufacturing companies especially in the paper and packaging sectors – and because all of these companies must purchase certified wood, it has helped to drive greater demand for FSC certified materials, and therefore FSC certified forests.

But FSC does not allow companies to use just any non-certified materials for mixing. Companies must identify if and where there’s a risk of receiving materials that are the result of undesirable forestry practices, and then either work to avoid these materials or mitigate the identified risks. When a company has gone through this process, the non-certified materials are considered to be ‘controlled’ and are called Controlled Wood.

To identify risks, FSC requires companies to use a risk assessment developed by FSC or its partners as the company’s primary source of information. In the United States, the greatest challenge was not necessarily defining where risk occurs, but in finding a feasible approach for companies to effectively mitigate (i.e. reduce) the risks identified.

The core challenge is that most US companies do not have, and cannot acquire, information about the specific origins of some of the non-certified materials they use. There are numerous reasons for this, including complicated supply chains and antitrust laws in the United States that prevent companies from sharing information (like material origin) with each other. So, if companies don’t know the specific origins of their materials, how can they know if the materials came from places where undesirable activities are occurring and how could they possibly mitigate any associated risks? This is precisely why FSC US decided to develop its risk assessment using a landscape approach.

In 2018, many companies, experts, environmental organizations and other interested individuals joined FSC US for webinars, interacted through an online platform and participated in three regional meetings to collaboratively identify mitigation activities that are likely to be effective in reducing risk and that could feasibly be implemented by the companies required to do so.

Many different mitigation activities were identified, but most were focused on trying to influence the behaviors of forest landowners within the identified landscapes. They include outreach and education approaches, creating change through partnerships with conservation organizations, incentivizing private landowners to manage their forests responsibly, influencing planning or implementation of conservation and land-use plans, and others.

FSC believes that the efforts by companies to mitigate risk will create measurable change in the level of risk within these landscapes. FSC US will be responsible for monitoring and evaluation to verify the effectiveness the mitigation.

While there are Controlled Wood National Risk Assessments being developed all over the world, ours is unique in its landscape-scale, longer-term approach to risk identification and mitigation. It is unique in that the focus is not simply on avoiding places where undesirable activities are occurring, but instead working together through partnerships that include both industry and conservation organizations to create on-the-ground change.

This is what FSC is all about: encouraging organizations and people with different perspectives to work together to promote responsible forest management. With our newly approved US National Risk Assessment we will be living our mission – not just driving more demand for certified forests, but also encouraging positive change in the management of non-certified forests.

More: Controlled Wood/ FM