FSC members include some of the world’s leading environment groups, social organizations, businesses as well as forest owners and managers, processing companies, campaigners, and individuals. FSC played an active part in the first EUTR review process and is in close contact with the European Commission and the EUTR/FLEGT Committee of EU Member States.
Actors practicing due diligence can use FSC certification as a key element of risk assessment and mitigation. All components of FSC certification – and the FSC standards – align with the EUTR. FSC has produced guidance materials on EU Timber Regulation.
In 2019, NEPCon assessed how the FSC forest certification system meets fundamental aspects of legality requirements for timber, as well as how the certification is set up to provide quality assurance and transparency, enabling the system to provide a meaningful indication of legality in relation to EUTR. NEPCon concluded: “FSC certification provides robust assurance for the responsible origin of timber products”. It can be concluded that the FSC system covers most of the requirements evaluated, but without FLEGT or CITES license a due diligence is still needed.
NEPCon continues, “the most important gap in the FSC system are found in the lack of a system to validate volumes of material with an FSC claim transferred from seller to purchaser and ensure that mixing of non-certified material does not take place in the supply chain”. Therefore, an FSC Chain of Custody certificate is not considered sufficient to mitigate the risk of mixing in the supply chain. This risk needs to be evaluated and addressed as a part of the due diligence system. One way to address this risk is to request that suppliers use the Online Claims Platform (voluntary internet-based volume transaction platform).
Secondly, the FSC CoC standard currently does not include evaluation of the legality of trade and transport activities that is considered to meet the EUTR definition of legality. To address this second gap, buyers of FSC-certified material should conduct a risk assessment of their supply chains for the risk of mixing of certified material and material from noncontroversial sources with material that has not been subject to FSC requirements, which could have been harvested illegally.