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Principles and Criteria

Current FSC-US Regional Standards

FSC-US Standards Revision Process

FSC-US Standards Review

Principle 10 (Plantations)

Family Forests Program

Group Chain of Custody

September 15, 2009

FSC members and stakeholders:

We are pleased to announce that the draft FSC-US Group Chain of Custody Eligibility Requirements Policy is now available for a 30-day phase of public consultation. All organization and individuals are welcome and encouraged to submit comments. Comments are due on Thursday, October 16th, 2009.

The current Group CoC Policy is in effect for all current and potential Group CoC Certificates in the world. FSC-IC is now allowing variability to this policy in the realization that the term “small company” varies from country to country. FSC-US has engaged the current FSC CoC certified Groups in dialog to develop an appropriate US policy. The proposed eligibility requirements have recently been approved by the FSC-US board for public consultation. Please provide us with our comments so we can produce a final version to send to FSC International for final approval. We are hopeful that the new FSC CoC Group Eligibility requirements will offer small organizations the ability to become FSC CoC Certified, which will expose a large number of manufacturers, retailers, and end users to the FSC brand.

Current Policy

To be eligible for assessment using these guidelines, group members shall conform to the following eligibility criteria:

Have no more than 15 employees (including full time, part time, and seasonal staff), OR
Have no more than 25 employees and an annual turnover of US $1,000,000.

Proposed Policy

Participation in FSC Group Chain of Custody programs shall be made available to:

Any small business with annual forest product sales less than $5,000,000.

In the fiscal year that a group member surpasses the sales threshold, its membership would become 'Transitional'. Transitional membership in a group certificate is allowed until growth beyond the surpassed threshold is documented for 2 consecutive years. At that time, the individual entity is no longer eligible to be part of the group certificate and shall pursue and transition to an independent certificate in order to continue in the FSC CoC program. New group members shall fall under the threshold before joining/creating a Goup CoC certificate.

Rationale for Proposal

Some stake holders asked for annual sales to be limited to FSC certified sales only. FSC-US was able to come to consensus and feels that placing a cap on gross annual sales of FSC certified products will allow big corporations with little investment in FSC to join a group certificate, which is not the intent of the FSC’s Group CoC Policy. It will also be nearly impossible to evaluate the gross annual sale of FSC certified products before the organization is FSC certified. Finally, FSC-US agreed that the employee cap should be removed. This removes the loop hole for brokers with multi-million dollar operations to take advantage of the Group CoC certification that is meant for small companies. Increasing the cap from $1 Million to $5 Million will still allow small retailers into the Group CoC certification. Therefore FSC-US agrees that the gross annual sales cap should be placed upon all sales of wood products (identical to how the AAF is determined).

The new eligibility requirements will allow more companies to become FSC CoC certified by:

Providing small to medium size enterprises with a tool to encourage participation in FSC certification programs;
Exposing large numbers of production, employees and, as a result retail consumers to FSC brand awareness education;
Creating an affordable program that will allow companies to prepare to market and test the market for FSC certified products.

Comment Process

Please submit comments by sending an email or mail a letter detailing your comments on the Draft Group CoC Eligibility Requirements.

Please send all comments and other correspondence to:

Emily Crumley, FSC-US
212 Third Avenue North, Suite 280
Minneapolis, MN 55401
Email: emily@fscus.org

For More Information

Please contact Emily Crumley with any questions or comments. emily@fscus.org; 612-353-4511