Response to recent media report by ICIJ

Bonn, Germany, 03 March 2023 - For nearly three decades, FSC has been advocating for a holistic approach towards responsible forest management; where environmentalists, Indigenous Peoples, businesses, workers and other actors actively engage in setting the policies and standards to maintain forests as valuable ecosystems. FSC understands and lives its mission as a community where several enablers work together towards one common goal: ensuring the long-term resilience of the world’s forests.

Concerns over global deforestation have been at the heart of FSC’s work since the beginning. In fact, FSC was first founded when a committed group of environmentalists, businesses, and community leaders joined to create a pioneering market-based approach to improve forestry practices worldwide after the 1992 Earth Summit in Rio failed to produce an agreement to stop deforestation. 

Since then, FSC has made significant contributions to ensure that certified companies abide by the most stringent standards and policies that prevent deforestation and maintain living forests. It continuously makes robust improvements to its system and takes integrity issues very seriously by carrying out investigations when necessary and taking immediate action against certified companies that cause or are part of deforestation. Therefore, FSC is an effective tool for implementing strict practices which are proven to be a solution to combat deforestation in productive forests, natural forests and protected areas.

No system designed to create change in real-world complex settings will ever achieve 100% perfection. FSC therefore welcomes criticism and takes it as an opportunity to learn and grow. We understand the crucial role of the media in shaping healthy democracies and improving governance across different sectors, and we see public criticism as a major tool in that context. We will use the ICIJ report as a basis for further improvement in our system.

FSC realizes that tackling a major global challenge such as deforestation is not an easy matter. Any measures put in place are only effective if they are implemented by all actors throughout the supply chain and regulated by all laws and governing systems. We strongly believe that voluntary initiatives and regulatory measures can go hand in hand to create positive outcomes for the world’s forests.

Many of the points raised in the ICIJ investigation are broad statements that do not clearly distinguish between the issues and cases raised and the specific action FSC is criticised for taking – or not taking – in response to them. With that, we would like to clarify some points and misrepresentations put forward in the report and reconfirm FSC’s role and what it is doing to address them.

Certification bodies’ performance

FSC has established a certification system that requires the support and involvement of various third-party actors to operate it on the ground, maintain independence and integrity, and ultimately support the sustainable management of the world’s forests.

Certification bodies (CBs) are responsible for independent third-party verification of the performance of FSC certified operations. These CBs are accredited against FSC standards by our assurance partner, Assurance Services International (ASI), and must also comply with ASI’s normative documents which are publicly available on the ASI website. By using a single, internationally operating accreditation body – rather than relying on national accreditation bodies – FSC ensures global consistency and is able to address relevant weaknesses in international CBs management systems more holistically. ASI evaluates each CB annually to maintain accreditation and for surveillance. Additionally, when triggered by a complaint, incident or other evidence, ASI may conduct other forms of assessments - announced or unannounced. This is a standard process for any accredited CB. If a certification body does not conform with the required standard, then ASI may suspend them. For more information about certification body assessments, please click here.

ASI and FSC will look into specific allegations raised against CBs’ performance in the recent media report. To investigate and ultimately prevent any allegations of corruption, FSC has a diligent complaints procedure that can be used by any stakeholder to https://connect.fsc.org/complaints raise their concerns.

Moreover, there are strict rules in the FSC system governing the relationship between certification bodies and certificate holders, and impartiality is addressed in detail by relevant FSC requirements which are largely adopted from the International Standardization Organization (ISO). To learn more, visit this page.

Teak supply chains

There are no FSC certified forests in Myanmar and therefore no FSC teak coming from there. However, FSC certified teak can come from other countries. FSC is aware that some certificate holders trade in both certified and uncertified teak products, and we are therefore in the process of scrutinizing some certified teak products' origin. There is a transaction verification loop currently underway that is looking into the global FSC certified teak supply chain. FSC will publish its findings once it has been completed by ASI.

FSC’s strict and transparent standards ensure that the legality of wood is not compromised throughout the supply chain. There are certain provisions in all our standards that address timber from conflict zones. For instance, in controlled wood, this is embedded in the requirements for traditional and human rights assessments where the forest sector must not be associated with violent armed conflict. Whereas in chain of custody (CoC) and forest management (FM) standards, this is addressed through the legality of timber and its compliance with the law.

With FSC’s ongoing investigation into teak supply chains, we welcome information and evidence about certificate holders trading illegally sourced teak, especially from high-risk countries like Myanmar.

Fibre Excellence

Fibre Excellence has a FSC Chain of Custody (CoC) certificate and uses FSC controlled wood (CW) – it does not have FSC certified forests. The case mentioned in the media is about controlled wood, not wood from FSC certified forests. Controlled wood can be sourced, based on risk, and in France and Spain, risk for controlled wood is considered low and it is therefore allowed in the FSC system. Incidents of logging without a logging permit can lead to a revision of the risk category which would trigger mandatory control measures for the sourcing of material.

Under FSC’s controlled wood standard, organizations must commit to obtaining their raw materials from low-risk sources which exclude five unacceptable categories.

For more information on the FSC national risk assessment for France, please visit this link.

On undue influence on FSC

To balance the interests of different stakeholders, FSC is governed by three chambers (environmental, social, and economic) in its membership, in the Board of FSC International and the Boards of its independent partners around the world (the FSC Network). One of the FSC certified companies targeted in the report, Fibre Excellence, has been a member of FSC France’s economic chamber since 2018. The company’s director of public affairs was elected as board member of FSC France in 2022.

In order to ensure that each interest group in the FSC membership has an equal say and influence, decisions on a country level and on an international level must be approved by a two thirds majority of the members, and the majority of votes in each chamber. This ensures equal power to all chambers and limits any authority of one member over another under any circumstances.   

On auditing and certification bodies

FSC’s policies do not allow the same individual to both audit and do a consultancy for the same company. ASI takes measures against anyone found to be performing both for the same company. According to FSC’s records, the auditor in question did not perform both at the same time. More information is available publicly in Fibre Excellence’s audit report.

On Paper Excellence

FSC has evaluated the shareholder interests between Paper Excellence and the APP Group multiple times and has concluded each time that there is no majority ownership relationship between APP and Paper Excellence. FSC has to apply the provisions of Policy for Association, version 2 for examining the ownership relationship between APP and Paper Excellence since the alleged deforestation occurred prior to 31 December 2022. The new and stronger provisions of the Policy for Association version 3 only become applicable in cases that occur after 1 January 2023.

Companies in Brazil

The investigations by IBAMA which may or may not be relevant for activities covered by our standards – have not been presented to FSC. If there are gaps in FSC’s current requirements in Brazil, then FSC will follow the normative processes to address them. As with many of FSC’s tools, normative policies and procedures can be amended over time to ensure alignment with national requirements. Brazil has certification requirements for certifying forest operations in the country that were developed in accordance with FSC's normative document for the development and maintenance of Forest Stewardship Standards.

Traceability

FSC leverages science-based technology and innovations to improve traceability in its system and has already launched a number of pilot projects to make its Chain of Custody system stronger and ensure better traceability along its supply chains.

• One of the most notable trends in the timber supply chain traceability is the use of blockchain systems which have the potential to streamline the supply chain management and transform traceability. FSC is working to introduce blockchain to improve its supply chain integrity through real time monitoring of transactions involving products with FSC claims/labels.
• Another growing trend is the use of science-based testing which FSC employs through wood identification techniques (Wood ID). FSC is working to stop illegal logging and ensure that the wood used in the supply chains of FSC-certified products originates from legitimate sources. Therefore, FSC is involved in the WorldForestID project which has set out to build the world’s largest database of geo-referenced wood samples from all regions of the world where illegal logging is an issue. This database will help in cases where wood identification is needed to assess questionable origins.
• At FSC, we use both satellite imagery and geographic information system (GIS) maps to collect data that provides proof of organizations’ forest management and conservation practices. One of the innovative tools that FSC created to support forest management auditors in inspecting conditions in and around certified forests is the FSC GIS Portal. This is a new web mapping application that enables FSC forest management auditors around the globe to access relevant geospatial information.