Certificates in Ukraine conflict areas suspended

Bogomaz Conservation Photography / WWF Ukraine
A young coniferous forest
Bogomaz Conservation Photography / WWF Ukraine
April 4, 2022

The Forest Stewardship Council (FSC) will require suspension of its certificates in armed conflict areas of Ukraine, and will allow streamlined auditing processes on certificates in areas not affected by conflict.

FSC remains determined to continue to support Ukrainian certificate holders as far as possible, and therefore will allow certification bodies – the independent auditors of FSC certificate holders – to continue their work in areas not affected by war, for example through remote audits and extending the time between audits to over a year, if required.   

At the same time, FSC must continue to protect the integrity of the FSC system. In the invaded regions of Ukraine, government legislation cannot be enforced, and it is not safe for the auditors to carry out their work. These factors dramatically increase the risks of forests not being managed according to FSC’s standards, and therefore FSC has no choice but to require the suspension of the relevant certificates. The suspension will be effective on 4 May 2022 (30 days from today).

FSC has worked closely with colleagues based in Ukraine to provide as clear as possible guidance on where the armed conflict zones are. This is not a simple activity, considering the unpredictability of war, and FSC requests certification bodies, certificate holders and other stakeholders to make this assessment to the best of their ability. For this purpose, FSC has identified three categories of information sources regarding the location of conflict zones:

  1. Public sources***
  2. The Ukraine State Forest Resources Agency (for state-owned forests)
  3. Directly from local authorities within Ukraine.

Certificate holders importing FSC material from Ukraine are required to amend their supply chain due diligence to avoid sourcing from zones of armed conflict.

Collection of Policy Responses to Situation in Ukraine

To support certificate holders in Ukraine to maintain their certification, FSC has published a set of derogations and interpretations. They are applicable in circumstances in which an on-site audit is not possible or viable due to the organization being located in or requiring travel through a region with a demonstrated security risk for the life or health of auditors. The collection of derogations include measures such as options to postpone audits and allowing remote audits for low-risk scenarios or hybrid audits, depending on the risk assessment conducted by certification bodies. The collection can be found here.

Controlled wood national risk assessment for Ukraine revised

FSC has revised the controlled wood national risk assessment for Ukraine.

Two key risks were identified in relation to the invasion and connected to the zones with armed conflict:

a. illegality due to the lack of enforcement of Ukrainian legislation, and

b. conflict timber, due to the Russian army able to use any forest resources for their own purposes.

These risks were considered as infeasible to mitigate and hence, the controlled material cannot originate from these conflict zones.


*** *Sources include, but are not limited to:

State Forest Resources Agency of Ukraine - https://forest.gov.ua/

The State Emergency Service of Ukraine - https://dsns.gov.ua/

Ministry of Defenсe of Ukraine - https://www.mil.gov.ua/

Ministry of environment protection and natural resources of Ukraine - https://mepr.gov.ua/

State Bureau of Investigation - https://dbr.gov.ua/

The Security Service of Ukraine - https://ssu.gov.ua/

The Armed Forces of Ukraine - https://www.zsu.gov.ua/

Liveuamap - https://liveuamap.com/

National police - https://www.npu.gov.ua/

State Border Guard Service of Ukraine - https://dpsu.gov.ua