Tuesday, 02 April 2013
Advice Notes Updated to Align with Global Timber Legality Legislation
April 2, 2013
On February 28, 2013, FSC published a round of updates with new or revised advice notes to the Directive on Chain of Custody certification (FSC-DIR-40-004), the Directive on Forest Management Evaluations (FSC-DIR-20-007), and the Directive on Controlled Wood (FSC-DIR-40-005). The updates are designed to align FSC with Timber Legality Legislation around the world, including the Lacey Act in the US. The following provides a brief overview of the key changes:
Chain of Custody Directive Updates
- Advice-40-004-08: Advice note on non-conforming product (Revised): This Advice Note was revised to specify that Small CoC enterprises do not need to have procedures in writing. Small CoC enterprises are defined as those organizations with either no more than 15 employees (full time equivalent), or no more than 25 employees (full time equivalent) and a maximum total annual turnover of $1,000,000.
- Advice-40-004-09: Advice note on minor components (Revised): This Advice Note has been revised to address all applicable timber legality legislation, eliminating the previous emphasis on the EUTR and fully harmonizing with existing timber legality legislation in the EU, US and Australia.As of March 1, 2013, companies in the US, and those companies importing into the US, shall no longer use uncontrolled and uncertified minor components in all products with FSC claims. Before this revision, the date for phase-out of minor components in the US was originally January 1, 2013; however, there was significant confusion among stakeholders around the interpretation and applicability of the advice note.Theglobal timeline for the complete phase out of products containing minorcomponents throughout the entire FSC system has been shortened, but alsofurther differentiated concerning production of products containing minorcomponents and sale of stocks. Please pay attention to this change in thetimelines because it affects not only the companies in countries where timberlegality legislation exist, but all certificate holders using minor components.
- ADVICE-40-004-10: Advice note on access to information required bytimber legality legislation (Revised): TheAdvice Note was revised to allow customers to also request information fromtheir suppliers concerning proof of compliance with trade and customs laws,where this information is required by timber legality legislation.
- ADVICE-40-004-11: Advice note on trade and customslaws (New): A new Advice Note was approved to ensureharmonization of FSC CoC requirements with existing timber legality legislationconcerning trade and customs laws.
Forest Management Evaluation Directive Updates and Controlled Wood Directive Updates
- Advice-20-007-17: Applicable National and Local Laws and Regulations and
- Advice-40-005-19: Applicable National and Local Laws and Regulations for Controlled Wood Company Risk Assessment: These Advice Notes clarify the scope of legality themes associated with Forest Management and Controlled Wood in order to align with the Lacey Act and other timber legality legislation. The Advice Note related to Controlled Wood applies only to Annex 3 processes associated with company controlled wood verification programs.
If you have questions relating to these updates, please contact Lori Knosalla, FSC US Chain of Custody Manager at l.knosalla at us.fsc point org.