FSC’s Eurasia Integrity Workplan: Progress update

In March 2024, FSC launched the Eurasia Integrity Workplan (EIW) to holistically address a range of integrity risks identified in FSC-certified supply chains across the Eurasian region. One year on, FSC is pleased to share the progress made through this multi-faceted initiative. 

A key priority has been to identify and mitigate the risk of Russian timber entering certified supply chains. Rather than focusing on a single issue or country, the EIW takes a systemic approach to strengthen the integrity of the FSC system in the Eurasian region and beyond. To support this, FSC is using a combination of transaction verification investigations, landscape analyses, and technology-based solutions to detect and respond to integrity risks identified in the Eurasian region, and to apply the tools developed on a global scale. 

The workplan also includes the development of updated normative provisions aimed at reinforcing the overall integrity of the FSC system. Alongside this, FSC has been working to enhance support for certification bodies, ensuring they are better equipped to evaluate certificate holders’ conformity with FSC standards and respond to emerging integrity risks. Finally, the EIW is driving systemic reforms designed to curb dubious practices among certificate holders and deter them from defrauding the FSC system.  

Through a combination of investigations, technological innovation, normative updates, and stakeholder collaboration, the EIW is laying the groundwork for a more resilient and robust certification ecosystem in the Eurasian region, and globally. 

Key actions and progress 

• Transaction Verification (TV) loops: The preliminary results of the two TV loops –on birch plywood and birch wood panels – have revealed certain integrity risks in these supply chains. Consequently, FSC’s assurance partner, Assurance Services International (ASI): 
  • Expanded the scope of the birch wood panels TV loop, to include an investigation into FSC-certified wood supply from Ukraine.  
  • Included certified traders/brokers in the certified birch wood panel supply chains within the TV loop’s scope.  
• Action against potential fraudulent activities: Through the ongoing TV loops, ASI and FSC are investigating certificate holders who are potentially making false FSC claims on their products. For some cases, FSC has collected clear and convincing evidence of certificate holders making false claims, based on which these certificate holders may be blocked from the FSC system.  
  • Since the launch of the EIW, over 179 certificate holders with veneer and plywood from birch in their certificate scope have been terminated or suspended by their certification bodies due to various violations of FSC requirements during the EIW (2022-2025). 
  • Through the interventions and transaction verification investigations two certificate holders have been blocked in the FSC system for making false FSC claims or other fraudulent behaviour, in Kazakhstan and Türkiye. FSC is currently processing an additional seven certificate holders that ASI has proposed for blocking.  
• Trademark infringements: FSC’s investigations led to the identification of over 3,200 listings in an e-commerce marketplace, including Alibaba, featuring products with unauthorised and unlawful use of FSC's trademarks. Moreover, some of these sellers were also exhibiting images of expired certificates along with their products. To address these trademark infringement cases, FSC requested the removal of these pages from the marketplace provider, demonstrating effective multistakeholder cooperation. 
• Risk of Russian timber entering FSC supply chains: Direct evidence of Russian wood entering FSC-certified birch supply chains, based on transaction data analysis and other investigations, has not been found. However, a majority of the certificate holders participating in the TV loops operate in countries that are not affected by sanctions against Russian timber. Hence they may purchase, produce and sell products made from Russian wood, as long as this is done via non-FSC certified supply chains. Furthermore, amongst 78 certificate holders evaluated during the Birch Plywood TV loop, two certificate holders deliberately obstructed the onsite ASI assessment process. This has resulted in the termination of their certificates by their certification bodies. 
• Technology-based solutions: In the past one year, ASI conducted 17 assessments of certification bodies and their certificate holders and collected wood samples from 11 sites located across China, Estonia, and Latvia. In collaboration with FSC’s partner, World Forest ID (WFID), these wood samples are being tested against WFID’s global reference library of endangered and threatened wood species. FSC Trace – a blockchain-based transaction traceability tool – is an integral component of the EIW. Once it is launched as a voluntary tool, FSC will proceed with implementing the Board of Directors’ decision to use it as a mandatory tool for traceability in high-risk supply chains, including in the context of FSC work in the Eurasia region. 
• Strengthening FSC’s normative framework: To address supply chain integrity risks, including the ones being investigated in the EIW, FSC has published an Advice Note (FSC-ADVICE-20-011-21) which prevents certificate holders in China with any of the following products in their certification scope, from waiving their audits for claiming ‘no FSC sales’: bamboo, solid wood, veneer or wood panels. In the context of the EIW, this will ensure that certificate holders with birch-based products in the country are audited annually. Additional auditing requirements for high-risk supply chains are included in the revised accreditation standard for certification bodies (FSC-STD-20-001 V5-0). FSC is now amending Advice Note (FSC-ADVICE-20-011-21) to enable FSC to publicly disclose information about all certificate holders who declare ‘no FSC sales’. This information will be available in FSC Search – a platform to check the certification details of all certificate holders. This will enable certificate holders in high-risk supply chains to strengthen their due diligence. FSC will announce the effective date of the Advice Note once the development process is completed. 
• ASI’s Code of Conduct: ASI will strengthen the oversight over auditors’ quality by developing a Code of Conduct, which is aligned with the new version of FSC’s standard governing accredited certification bodies (FSC-STD-20-001 V5-0). Non-conforming auditors will be suspended from performing their services. 
• Certification landscape analysis: FSC and ASI completed an in-depth review of the certification ecosystem in China. Findings highlight the involvement of consultants who provide support to certificate holders at various points in the certification journey. However, their actions in the certification are unregulated and can result in poor services and consequently in poor performance of certificate holders. Based on findings of ASI’s review, FSC organized two calibration workshops with certification bodies to share the results of the review and jointly identify ways to strengthen the certification landscape. In April 2025, ASI launched an independent investigation into audit quality and integrity in Türkiye, as a continuation of the evaluation done in China, with the objective of understanding how well FSC audits are addressing integrity risks. 

Monitoring and screening  

FSC and ASI have been actively responding to alerts and reports of fraudulent behaviour submitted by concerned stakeholders. These inputs have played a crucial role in shaping ongoing investigations and reinforcing the integrity of the certification system. FSC encourages all stakeholders to report any incidents of suspicious activities, along with evidence, so that these inputs may be taken into consideration in the ongoing investigative activities. 

To prevent high-risk companies from entering the FSC system, the FSC Check is being used to screen all new applicants for certification against a database of disassociated and blocked organizations. In case of any matches between an applicant and a blocked company or in case of any other identified potential risks FSC shares this information with the relevant certification body for their follow-up and oversight.  

Meanwhile, FSC and ASI are closely monitoring global developments in the wood and forestry markets, particularly in light of the upcoming European Union Deforestation Regulation, set to take effect in December 2025. This regulation may potentially affect FSC-certified supply chains, significantly. 

Looking ahead 

By the end of 2025, FSC expects to complete several key actions under the EIW. These efforts will help identify where and how integrity risks manifest, enabling FSC to take decisive action against non-compliant actors not only from the Eurasian region, but also globally. The upcoming FSC General Assembly in October 2025 may also influence future integrity measures. 

FSC remains committed to enhancing transparency and ensuring that certified supply chains remain free from illegally harvested timber. 

See the factsheet for more information.