Tuesday, 02 March 2004
FSC International Reviews Percentage-Based Claims Policy

FSC International Center (FSC-IC) has been engaged in the process of reviewing the percentage-based claims policy since June 2001. FSC-IC has posted information regarding this review process at www.fscoax.org/coc. The following is an overview of the existing policy, why it has been reviewed, and explanations and status of the proposed changes.

WHAT IS THE EXISTING PERCENTAGE-BASED CLAIMS (PBC) POLICY?

The existing FSC PBC policy governs requirements and definitions relating to chain-of-custody and on-product use of the FSC logo for products that contain less than 100% FSC fiber. The policy was designed to:

• Allow for public recognition of products containing a "significant" amount of FSC endorsed raw materials;
• Reduce barriers facing industries which rely on a large number of suppliers not all certified; and
• Reduce the perceived disadvantages faced by small forest properties supplying the same markets as larger integrated forest enterprises.

WHY IS IT UNDER REVIEW?

At their May, 2002 meeting, the FSC International Board of Directors authorized the Secretariat to develop new FSC standards for chain-of-custody (COC) and labeling. They were to consider changes to the labeling and COC standards, specifically the percentage-based claims policy that would:-Reduce the economic and logistical barriers facing industries supplying FSC-certified products;

• Improve the flow of certified products through the supply chain;
• Increase the flexibility of on product statements;
• Extend market presence for FSC labeled products;
• Incorporate recycled content to a greater extent in FSC products; and
• Strengthen the credibility and value of the FSC logo.

From a technical perspective, it was expected that the changes would also:

• Create additional controls over the non-certified portion of wood included in an FSC labeled product;
• Revise definitions of grades, qualities and types of recycled, reclaimed/rediscovered and non-wood material; an 
• Revise requirements for the measurement of product content.

WHAT ARE THE PROPOSED CHANGES FROM FSC INTERNATIONAL?

FSC-IC reviewed the PBC policy using the three major industry sectors that are the basis of the existing policy:

• solid wood / sawn wood products,
• chip and fiber products, and
• assembled products.

SAWN WOOD PRODUCTS

In the review of the chain-of-custody process and implementation it was realized that sawmills, especially large integrated sawmills, represent a significant blockage in the supply of labeled products. Under the existing percentage-based claims policy, 100 percent of the wood coming out of a certified product line can be labeled as X% FSC certified, where X is the amount of FSC-certified wood going into the mill. Thus, a mill producing baseball bats where 70 percent of their wood supply was FSC-certified could label all the baseball bats produced with a 70 percent claim label. Many mills complained that rules and processes for enforcing this policy resulted in little use of the FSC label. Others held that the rule was confusing to customers. Under the new proposed policy, the saw mill can label X percent of their output as being 100 percent certified, where X equals the amount of FSC fiber coming into the mill.

Thus, If 70 percent of the mill’s input is certified, 70% of the mills products can carry a FSC label. Under the current version of the new proposal, there is a 10% minimum required in order for a mill to use the label.

CHIP AND FIBER PRODUCTS

Under the existing standards, all chip and fiber products are required to have a minimum FSC-fiber content of 17.5 percent in order to carry an FSC label. The balance of the wood content has to come from non-controversial sources. In addition, under the old policy post-consumer recycled content is classified as a "Neutral Fiber" and does not contribute to the calculation of FSC content.

The new standards proposed for chip and fiber products make a number of important changes to the existing rules designed to broaden the application of the FSC label to these products and to recognize other "environmentally preferred" fiber sources. Specifically:

• The minimum "FSC verified fiber" in a chip and fiber product would be raised to 30%. Example: paper stock will now have a minimum 30% FSC-certified content (this is now defined as FSC certified virgin fiber or recycled content).
• Post-consumer recycled content could be substituted for FSC fiber as 0.5%. Example: to meet the 30% minimum a company could use 10% FSC virgin fiber and 40% post-consumer to fulfill the 30% minimum.
• Products containing up to 100% post-consumer fiber could be labeled as FSC-certified.
• Products containing a minimum of 60% post-consumer (with no FSC virgin content) could be labeled FSC certified. Example: A Georgia-Pacific chip board product containing 40% International Paper pulp and zero FSC content could receive an FSC label as long as the other 60% is post-consumer recycled.

ASSEMBLED PRODUCTS

The new assembled products standard differs from the old standard in these main points:

a) Clearer controls over the non-certified proportion of wood included in FSC-labeled products including additional requirements for excluding wood from illegal sources, uncertified High Conservation Value Forests and Genetically Modified Trees;

b) An option for making on-product claims for assembled wood products on the basis of an "FSC credit" accounting system or a threshold system;

c) Consistent definitions of grades, qualities and types of reclaimed wood; new requirements for on-product labeling of reclaimed wood.

This standard outlines the requirements for labeling using either FSC "Green", "Brown" or "Recycled" on-product labels. It offers manufacturers the option of implementing an FSC credit or threshold system for labeling products carrying the FSC "Brown" label.

The threshold system outlined in this standard has been based on current FSC requirements for labeling assembled products (FSC Percentage Based Claims Policy, May 2000). The FSC threshold system requires a monthly minimum level of FSC content to be maintained in order to label product with the FSC trademarks.

The FSC credit system links FSC labeled product to the volume of FSC material entering the production process but does not require separation of FSC from controlled wood or the maintenance of monthly minimum averages.

CONTROVERSIAL SOURCES

The existing PBC policy includes the requirement that all non-FSC wood in an FSC labeled product come from non-controversial sources. This requirement is, however, unclear. Under the new proposed policy, the "controversial sources" language is strengthened to create a stronger policy.

The new proposed rules require that all wood going into FSC labeled products and product lines must be verified as coming from non-controversial sources. "Controversial sources" is defined as:

• Harvested from areas of social conflict;
• Harvested from uncertified High Conservation Value Forests or harvested from Endangered Forests;
• Harvested from genetically modified trees;
• Harvested illegally.

This controversial sources policy applies to all three percentage-based claims strategies.

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