Chain of custody + labelling
Sustainable forest management (SFM) certification has been a platform for the Canadian forest products industry to demonstrate their commitment and action to promoting SFM. While over the last 5 years the focus has been primarily on SFM certification, there is now enough certified forest area to pay closer attention to how the products derived from these forests are brought to market. Indeed the whole subject of product claims, which are integral to achieving recognition for the industry's SFM certification success, has become a renewed focus for many of the international organizations in 2004, such as FSC and PEFC. Most SFM certification approaches rely on chain-of-custody certification as the basis for product claims and labels.
It is important to understand how product claims fit into the sustainable forest management certification programs, and essentially they all can break down into four components as described below. While there are differences in the way the various certification programs function, they all tend to deal with the following four areas:
- SFM Standard—voluntary standard that sets out the sustainable forest management requirements.
- SFM Certification—the audit process that establishes whether the requirements in the standard have been met. The audit is conducted by a qualified 3rd party certifier/registrar.
- Accreditation—a mechanism to ensure the certifier/registrar is competent and can produce credible, and consistent results.
- Product Claims
labelling—Rules for labelling products as coming from a certified forest are stipulated by standards organizations and need to be followed to make any claims about a product. Normally these include the requirement for having a Chain of Custody (explained below), as well as the minimum % of certified content needed before a label can be put on a product.
Chain of Custody—This is the mechanism to track wood from certified forests and other sources, through each stage in the production chain, so that claims about characteristics of that product (such as its certified or recycled content) can be supported.
Chain of Custody
Chain of custody is essentially a wood flow accounting process or segregation method that need not be complicated when the sources of supply are well understood. Despite the different agencies and minor differences in approach behind the CSA, FSC, SFI, and PEFC CoC standards, and generic CoC standards such as the PricewaterhouseCoopers CoC, for the most part these CoC standards are wood tracking standards that align nicely with one another. The standards are similar in that they all incorporate a percentage based option to track certified wood flows as opposed to strict product segregation as was originally the case. All the standards also allow for the volume-credit option which allows the user to target its %-certified-content input towards specific outputs. For example, 40% certified content in, can now be sold as 100% certified content on 40% of the output (as opposed to the average percentage method option which under the same scenario would allow for the sale of 100% of the output as 40% certified content).
In addition, while CoC standards were originally developed to track certified content, they are now capable of tracking recycled content (and in some instances communicate that in the label), and have also evolved to provide some assurances around the portion of the product that is not certified. The matrix highlights the fundamental similarities in the approaches taken to tracking wood flows as well as pointing out the value-laden requirements found in some of the CoC standards or supporting program documents. For example, while all of the CoC standards and/or their associated program documents, do not knowingly allow illegally harvested fibre in the certified product, they all have additional requirements in terms of unacceptable sources of supply in the certified product be it from genetically-modified trees, high conservation value forests under threat of forest management, or fibre from areas of civil unrest. Some of these important nuances are explored in the table below.
It is important to note that the PwC-ICoC:2005 Standard was used in the matrix as an example of generic CoC standards available to organizations tracking multiple wood flows derived from a variety of certified forests, be it CSA, SFI, FSC, or PEFC certified wood flows. However, there are other agencies that offer similar services, including but not limited to: KPMG, SCS, and BM Trada. Likewise, there are certification bodies who are accredited to conduct accredited certification to both FSC and PEFC CoC standards, such as SGS and BVQI.
Chain of Custody (CoC) Summary Matrix
| Issue | CSA CoC is the PEFC CoC (PEFC CoC Annex 4) | SFI CoC, Annex 2 (based on PEFC CoC Annex 4) | FSC CoC, FSC-STD-40-004 | PwC-ICoC: 2005 |
| Terms and Definitions covering CoC, certified content & other terms integral to understanding the basic requirements of the Standard |  |
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| Scope that covers tracking wood flows through the harvesting, transporting, handling, or processing of forest based products at any stage in production from the forest through to a final consumer. | |
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Implied |
| Minimum management system requirements including documentation | |
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| Origin of Certified Content to be Identified through supplier information, appropriate documentation | |
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Implied |
| Options to Tracking Wood Flows: | ||||
| Product Separation (certified raw material remains clearly identifiable throughout the whole production/trading/storage process) | |
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Implied | Implied |
| Threshold / Average Percentage (% in = % out) If 40% certified content goes in then 100% of output is considered 40% certified | |
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| Volume Credit (allocating certified content to specific products) If 40% certified content goes in, then a targeted 40% of the output is considered 100% certified. | |
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| Acceptable Sources of Content Allowed in the Certified Product but not necessarily for the certified content calculation includes: | ||||
| Certified content derived and tracked from a certified forest | |
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| Pre Consumer Recovered/Recycled/Reclaimed (wood and/or wood fibre reclaimed from a product, by-product or co-product during manufacturing operations). | treated as other non-certified content and is used to calculate % not certified in the product; cannot be used for calculations regarding PEFC recycled content label or claims. | treated as neutral and is not included when calculating % certified content. SFI does not have % recycled label/claims, although CoC allows for tracking to meet customer needs | % is calculated for FSC label and claims related to other reclaimed. | allows for flexibility to meet customer needs in terms of reporting as a stand-alone item or grouped with post-consumer recycled. |
| Post Consumer Recovered/Recycled/Reclaimed (wood and/or wood fibre reclaimed from a product after it has been used for its intended end use purpose) | treated as neutral and is not included when calculating % certified content, unless using PEFC recycled content label, in which case % post-consumer recycled is calculated | Same as above; SFI does not differentiate between pre and post consumer recycled - both considered recycled. | % is calculated for FSC label and claims related to post-consumer reclaimed | allows for flexibility to meet customer needs in terms of reporting as a stand-alone item or grouped with pre-consumer recycled. |
| Other non-certified content provided it does not include categories of content that are identified as unacceptable /controversial/ uncontrolled sources by the Standard. (Refer to rows below) | |
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| Categories of Content NOT Allowed in the Certified Product UNLESS derived from a certified forest: | Does not allow fibre from areas that have been classified by CITES threatened and endangered species, unless all regulations defined by CITES and supporting laws have been followed. | Same as PEFC,plus SFI has a variety of additional procurement requirements under Performance Measures 8.5 and 8.6 ( SFI 2005-2009 Standard) to ensure procured wood outside N.America is risk assessed and, not procured, as appropriate. | Unless from a certified forest, the Standard does not allow fibre from areas with high conservation values which are threatened by forest mgmt activities, | Unless from a certified forest, the Standard does not allow fibre from area of exceptional risk, or from GM trees, |
| Categories of Content NOT Allowed/Accepted in the Certified Product, and controlled by the company to exclude: | Controversial sources: illegal or unauthorized harvesting. (Examples include harvesting in areas protected by law as well as areas officially published by government authorities as planned to become strictly protected by law, without the govt/authority giving permission to do so.) | Controversial sources: illegal logging. (Theft of timber or logs and cutting in parks, reserves, or other similar areas where otherwise precluded by law.) | 1. Forest areas where traditional or civil rights are violated 2. Uncertified forests with threatened High Conservation Values 3. Genetically modified (GM) trees 4. Forest areas which have been illegally harvested 5. Natural forests cleared for plantation or other use |
Illegal sources: Shipments rec'd from organizations that do not have the legal rights to harvest, transport or sell wood fire, or fibre on which royalties, stumpage or taxes have not been paid. |
| Certification Body Qualifications: | ||||
| Requires Independent 3rd Party Audit | |
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| Certification body must be accredited by a national accreditation body that is a member of the International Accreditation Forum (IAF) | |
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No. FSC International accredits FSC certification bodies. | Not specified, although PwC is accredited by an IAF member. |
While all chain of custody products essentially focus on tracking wood from known sources through to the end user or retailer, there are some differences in each tracking method used. These differences are best understood by reading the relevant standard-specific documentation provided below.
- SFI CoC Requirements. Note: These are new CoC requirements for the SFI Program just introduced in late 2005 and early 2006.
- FSC CoC Requirements. Note: This is the key standard related to CoC for the FSC Program. For further details go to the FSC web-site.
- PEFC CoC Requirements. Note: PEFC Annex 4 sets out international CoC requirements used by many of the certification programs that it has endorsed.
Product Labelling Trends
While CoC tracks the wood flow to determine the percent certified content and other attributes of the product that may be of interest to the buyer such as recycled content, product labels are the next optional step to communicate the 3rd party verified information. The amount of certified content required to carry a label varies across the labels explored in the matrix below as does the transparency of the certified content.
The CSA and PEFC labels have traditionally required a minimum of 70% certified content prior to label use. While this is still the case with CSA, the PEFC in 2005 has just proposed a new labelling option based on tracking recycled content in the chain-of-custody. With this new option, a minimum of 70% certified and recycled content (combined) must be achieved when the PEFC recycled content label is being used. PEFC requires that the % recycled content is demonstrated on the label inside the mobius loop. For those qualified PEFC Label Users not interested in making recycled content claims, the original 70% minimum certified content requirement remains an option.
Just as the FSC has adjusted its approach to CoC, the same holds true with its product labels. FSC International still provides for a 100% certified content label (FSC Pure Label), and now provides for a 100% recycled content label (FSC Recycled Label) - in both instances the % certified / % recycled are clearly communicated on the label. However, a new category of FSC Mixed Labels allows for certified and recycled content to be mixed for a label, with a 70% minimum combined content (and a minimum of 10% FSC certified) however neither the % certified, nor the % recycled is required to be communicated on the label. Also in the FSC Mixed Label category, there is an option to include (uncertified) controlled wood along with FSC certified/recycled content.
The SFI labels are labels are supported by clear claims that qualify what is being communicated. In the case of SFI certified content labels, the actual % of certified content in the product is also made transparent, in the case of SFI fibre Sourcing Labels, the claim makes it clear that fibre sourcing requirements have been met, and there are no claims to certified content.
There is no label option associated with a PwC CoC certification. The purpose of the PwC CoC certification is to provide buyers with an assurance of an independently audited chain-of-custody tracking system and associated requirements regardless of the certified content being tracked (CSA, SFI, FSC, PEFC). The PwC CoC certification can not result in forest certification scheme-specific claims to CoC certification and or labelling requirements based on certification to PwC-ICoC:2005.
While CSA, FSC, SFI and PEFC have a variety of product labels available for use, it is the exception, rather than the rule, that these labels get used to identify products from certified forests. This can be attributed to a variety of factors including:
- the added expense of label use;
- many buyers of forest products are satisfied with the assurances provided by the SFM certification and the corresponding CoC audit;
- the demand for certified forest products does not come from consumers, who seek out specific labels in their retail outlets, but rather by large buyers who can secure assurances of certified content, without a label through tools such as supplier information and chain-of-custody certificates.
- many buyers do not want certification labels competing with their own brand labels;
However, labels still do get applied in certain niche markets or where the buyer demand is communicated. In addition, designers and architects have expressed interest in having labels on products in the marketplace, so that the SFM certified wood that they specify for use can be easily found by builders. This is likely also an emerging issue given the growth of green building programs, and because there is not a centralized resource available from which to source certified wood. However, it is not certain whether the various SFM labels shown in the matrix below will be picked up in the marketplace to a significant extent. If label use does increase, it will serve to make consumers, and not just customers, aware of forest certification.
Product labelling & Claims Summary Matrix
| Description of Label: CSA Certified Content Labels |
Label Options: |
Associated Label Claims & Minimum % Certified |
| Description of Label: SFI Certified Content Labels associated with SFI Chain-of-Custody Certification (SFI Annex 2) & Rules for Use of SFI Program Marks |
Label Options: |
Associated Label Claims & Minimum % Certified For SFI % Content Labels the claim is transparent as follows: |
| Description of Label: SFI fibre Sourcing Labels associated with SFI fibre Sourcing Certification & Rules for Use of SFI Program Marks |
Label Options: |
Associated Label Claims & Minimum % Certified |
| Description of Label: PEFC Certified Content Labels associated with PEFC CoC Certification, Annex 4 & PEFC Logo Use Requirements, Annex 6. |
Label Options: |
Associated Label Claims & Minimum % Certified For PEFC minimum 70% Certified Content Labels the claim is: Promoting sustainable forest management - For more info: www.pefc.org Note: Although 70% certified content is required to use this PEFC claim, the % certified content is not communicated on the label. |
| Description of Label: PEFC Certified & Recycled Content Labels associated with PEFC Annex 4 CoC Certification & PEFC Label Use Requirements |
Label Options: |
Associated Label Claims & Minimum % Certified |
| Description of Label: FSC Certified Content Label (FSC-Pure Label) |
Label Options: |
Associated Label Claims & Minimum % Certified |
| Description of Label: FSC Mixed Content Labels (FSC-Mixed Label) |
Label Options: |
Associated Label Claims & Minimum % Certified When recycled content is added to the mix of FSC certified content (whether controlled wood is used or not): the product must have at least 10% FSC certified content, as well as a combined total of 70% FSC certified and recycled content. The remainder can be controlled wood. Note: The % certified content is not communicated on the label, and communicating % recycled content is optional. A claim is on the label. |
| Description of Label: FSC Recycled Content Label (FSC-Recycled Label) |
Label Options: |
Associated Label Claims & Minimum % Certified |
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