FSC requirements updated to enforce decision to reject FSC material from Russia and Belarus

Updates to FSC’s Controlled Wood Framework
Controlled wood (CW) requirements explicitly require an assessment of whether a country’s forest sector is associated with armed violent conflict as listed in Indicator 2.1 of CW category 2 of FSC-PRO-002a:

“2.1. The forest sector is not associated with violent armed conflict, including that which threatens national or regional security and/or is linked to military control.“

FSC concluded that a strong association between the forest sector and government exists in Russia and Belarus. Combined with their government’s military action, ‘specified risk’ had to be concluded. FSC further concluded that this risk cannot be mitigated by any other control measure except to altogether avoid source material from these areas. To implement this credibly in the FSC system, shorter timelines were required in addition to providing a mandate for FSC International to make changes to such risk assessments and control measures directly. As a result, the following changes have now been made to the CW framework:

  1. FSC-ADV-60-002-01 Stipulation of Controlled Wood Risk Designations by FSC International in case of Emergency Situations: allowing FSC International to amend FSC risk assessments, both National Risk Assessments (NRAs) and Centralized National Risk Assessments (CNRAs), and to introduce mandatory control measures in CNRAs.
  2. PSU-PRO-10-002 V2-0 The Development and Approval of FSC Centralized National Risk Assessments: a revised procedure for the development of CNRAs to reflect the possibility for the CNRA to provide mandatory control measures.

Using changes to the above normative instruments, the following have been revised:
FSC-NRA-RU V3-0 FSC National Risk Assessment for Russian Federation: a revised NRA for Russia,
FSC-CNRA-BY V2-0 FSC Centralized National Risk Assessment for Belarus: a revised CNRA for Belarus. We have additionally revised the risk designation for indicator 2.2 due to the risk of ILO violations, as there are evidenced instances of such violations which, in combination with the inability to safely assess such instances, has resulted in ASI excluding Belarus from its assurance services.

  1. FSC-ADV-40-005-25 Adapting new Due Diligence Systems to Urgently Revised FSC Risk Assessments: to make sure that FSC risk assessments revised as per the above are used in a reasonably short timeframe to address the urgency of the respective risks (30 days instead of 6 months). In addition, we clarified that the provisions for mandatory control measures also include CNRAs. ​​​​​​​
  2. To ensure consistency between certification and accreditation requirements, we then issued an interpretation to FSC-STD-20-011, to clarify that when the NRA is mentioned in relation to control measures, it also includes CNRAs.

The above changes mean that within 30 days (by 8 April 2022) organizations shall cease to source controlled material from Russia and Belarus.

We believe that this timeframe is short enough to address the urgency of the situation and reduce the risk of forests being over-exploited to secure enough controlled material at the supplier’s premises, while giving enough time for companies to adapt their due diligence systems.

Addressing risks to FSC system
Finally, we have introduced one generic advice note to address system-wide risks:

  1. FSC-ADV-20-001-12 Consequences of Uncontrollable or Non-auditable Risks impacting the Forest Sector at large (NEW): requires certification bodies (CBs) to suspend or withdraw certificates in the event of emerging extraordinary risks beyond the control of the individual organization – identified either through CW risk assessments or otherwise. The advice note further regulates which types of certificates are subject to the highest risks and therefore shall be suspended or withdrawn.

In the case of Russia and Belarus, with the introduction of this Advice Note, within 30 days (by 8 April 2022) all certificates, except for FM (with no trading of certified products), will have to be suspended for the time being.

However, in Belarus case, both ASI as well as FSC have identified uncontrollable risks related to upholding and assessing certain FSC social requirements which are based on ILO core conventions. ASI has therefore decided to terminate its FSC oversight activities in Belarus. As a consequence, FSC certificates will not only have to be suspended as governed by the overall decision of FSC for Russia and Belarus, but will have to be withdrawn.

We expect more changes, such as waving the AAF fee for suspended certificates in Russia and will update stakeholders accordingly. We encourage stakeholders to review the published FAQs about the recent changes which can be found below. For further questions and inquiries into these changes, please contact the Performance and Standards Unit at psu@fsc.org.

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