Addressing misconceptions about FSC’s certification system

The Forest Stewardship Council (FSC) is committed to maintaining the highest standard of responsible forest management, ensuring that all timber entering FSC-certified supply chains complies with legal and ethical requirements. We recognize the ongoing concerns surrounding illegal timber trade, particularly from sanctioned countries such as Russia, and the need for transparency in global supply chains. All certification systems carry inherent risks of misuse and illegal trade. The complexity of global supply chains - whether in timber, agriculture, or textiles - can expose them to risks such as false claims or illegal trade. 

Unfortunately, misconceptions regarding FSC certification and its processes continue to appear in some reports and public discussions, leading to misinterpretations of the system’s integrity. As such, it is important to take this opportunity to address these issues and provide a clearer understanding of the robust measures FSC has implemented to prevent illegal timber from entering certified supply chains. 

 Clarifying key misconceptions 

It is important to differentiate between two distinct issues: false claims about certified products and the trade of illegal timber outside the scope of FSC certification.   

• False claims occur when a certificate holder unintentionally or deliberately represents a product as FSC-certified when it is not. False claims can taint entire supply chains and result in the immediate suspension or termination of a certificate; a decision made solely by the certification body. Additionally, FSC may block companies by revoking their trademark licenses and preventing re-certification until corrective measures are completed. 
• However, the sale of illegal timber outside the scope of FSC certification is beyond the authority of certification bodies, as they do not have the mandate to address transactions that fall outside the certified scope.
• If there is evidence that a company may be violating the FSC Policy for Association – such as sourcing wood from Russia outside the scope of certification – FSC may initiate a Policy for Association investigation. 

Addressing risks in Eurasian timber supply chains 

FSC is aware of specific risks regarding the potential illegal entry of Russian birch into certified supply chains through countries in the Eurasian region such as China, Turkey, and Kazakhstan. In response to this, FSC launched the Eurasia integrity workplan to address this risk through multiple avenues: 

• Transaction verification (TV) loops: FSC and Assurance Services International (ASI) launched TV loops focusing on birch wood products, including both wood panels and plywood. Over 800 certificate holders are participating in these investigations across 30 countries, with a targeted focus on Eurasian nations. The Eurasia birch wood panel TV loop (launched in 2024) and the birch plywood TV loop (launched by ASI in 2023), complement each other. Preliminary results from the birch plywood TV loop were published last year, while those from the birch wood panel TV loop will be shared soon.
• Wood sample testing: To complement the TV loop, Wood samples are being collected from certain certificate holders for testing to verify timber origin from the claimed sources.
• High-risk cluster investigations: After analyzing trading patterns within FSC-certified birch supply chains, ASI identifies high-risk clusters and conducts deeper investigations. If any certificate holder is found to falsely and deliberately making FSC claims on non-certified wood, FSC takes immediate action by blocking the certificate holders from the FSC system and addressing any gaps identified in its normative framework. In Kazakhstan, ASI's investigations into the illegal sale of Russian wood using false FSC claims have led to significant outcomes. These included on-site assessments, and transaction verifications, following which two certificate holders voluntarily terminated their FSC certification. Additionally, another company had its certification revoked due to non-cooperation.
• Calibration workshops for certification bodies are also being organized by FSC to make sure there is a common level of understanding of the integrity challenges and to improve the quality of audits. 

 Rigorous integrity measures to mitigate such risks 

FSC has robust, built-in mechanisms to proactively identify and prevent risks related to illegal timber trade. Accredited certification bodies play a crucial role in managing the certification process and are responsible for conducting thorough annual audits of certificate holders to ensure conformity with FSC standards. 

In addition to FSC standards, we have developed a range of mechanisms designed to prevent illegally harvested timber from entering certified supply chains. These include:  

• Technology-based tools: FSC is adopting advanced digital record-keeping and traceability systems to enhance transparency within certified supply chains. These tools ensure greater accountability and help verify the origin of timber.
• Supply chain monitoring and investigation: FSC works with ASI to conduct rigorous assessments and investigations to detect discrepancies in the volumes of certified traded through supply chains. ASI, along with the certification bodies, also carries out various types of investigations and assessments, including unannounced visits to certificate holders, to address allegations of wrongdoing.
• Measures for high-risk species: Based on ASI’s findings from various TV loops and investigations, FSC has introduced special evaluation requirements for auditing supply chains of high-risk species such as mango, Dalbergia, and Paulownia. These additional measures ensure more stringent checks on species vulnerable to illegal trade and misuse of certification.
• FSC’s Policy for Association: The Policy for Association allows FSC to sever ties with certified companies involved in unacceptable activities such as deforestation, illegal logging, or human rights violations. For example, in the case of WOB Timber, FSC launched a case based on a German court ruling against WOB Timber for illegally trading teak from Myanmar. FSC’s board of directors decided to set conditions for maintaining association with WOB Timber– including a compliance audit – that need to be fulfilled, otherwise a disassociation would be the consequence.  

 Moving forward 

FSC remains committed to upholding the highest levels of integrity of forest certification. Several key actions are in progress in relation to these efforts.  
The implementation of the Eurasia integrity workplan is ongoing, with further updates expected on its various components, including transaction verification (TV) loops and calibration workshops.   

Additionally, proposed revisions to FSC’s main certification body standard (FSC-STD-20-001) include normative changes aimed at enhancing oversight of certificate holders—particularly within high-risk supply chains. Following a consultation process, the revised standard is now in its final stage of preparation. 

ASI has also strengthened its normative requirements regarding unannounced on-site visits and plans to conduct additional unannounced assessments in 2025. 

We encourage all stakeholders to report any evidence of illegal timber trade by submitting a complaint to FSC, reporting an incident to ASI or – if the illegal trade is taking place outside the scope of certification – by submitting a Policy for Association complaint.