Requirements for Project Certification

Administrative Requirements

A management representative who acts as compliance officer needs to be appointed, with responsibility and authority for the organization’s conformity to mitigate and manage the risk of non-conforming products.

It has to be checked if documentation for verification is available. When verifying information that points to any risk that the product doesn’t conform with FSC Regulatory Module there has to be an investigation and appropriate actions have to be taken.

NOTE: The appointed management representative for conformance with applicable certification requirements may also act as the compliance officer.

Project Statement

The following has to be included in the Project Statement:

The Regulatory claim

Due diligence Statement reference number

When asked, details have to be shared about the species (both common and full scientific names), plot of land geolocation, time of production, and any additional information needed by operators and regulatory traders further down the supply chain. This helps to confirm negligible risk in the respective Due Diligence Systems and ensures compliance with timber legality laws.

Due Diligence

The Due Diligence includes completing the following three steps (Unless operating in a country classified as low risk (in this case only a Simplified Due Diligence is necessary)):

The collection of information, data and documents
Risk assessment
Risk mitigation measures

The Due Diligence is in place in order to prove that:

The product is deforestation-free.
The product has been produced in accordance with the relevant legislation of the country of production.

Information Collection

Risk Assessment

Risk Mitigation Measures

Due Diligence Statement

Due Diligence Statement (1/3)

If qualified as an operator and based in the European Union, a due diligence statement confirming that due diligence has been exercised must be submitted. The statement concludes that the relevant products are deforestation-free and produced in accordance with the relevant legislation of the country of production before placing them on the market, exporting them, or selling any product with a claim of conformity as with the FSC Regulatory Module.

Due Diligence Statement (2/3)

The Due Diligence Statement can be generated using an online tool provided by FSC

(Currently under development)

If an authorized representative is mandated to submit the due diligence statement, a copy of the mandate in an official language of the European Union must be provided to the competent authorities and, if possible, a copy in the official language of the member state where the due diligence statement is handled, or in English.

An individual, natural person, or micro enterprise, may mandate the next organization down the supply chain that is not an individual, natural person, or micro enterprise to act as an authorized representative.

Due Diligence Statement (3/3)

Records of sales invoices or similar documentation for a minimum of five years for all products sold with an FSC claim must be kept, including the following:

Description of relevant products
Quantity of relevant products
EU complementary FSC Regulatory claim (if applicable)
Supplier’s reference number/s of due diligence statements quoted for relevant products.

Exceptional Cases

Simplified Due Diligence

A simplified due diligence can be conducted when the Management Unit is located in a country or parts thereof classified as low risk in accordance with the EUDR three-tier risk system.

In cases where a simplified due diligence is exercised, Risk Assessment and Risk Mitigation Measures are not necessary.

Relevant documentation demonstrating that there is a negligible risk of circumventing the EUDR is made available to the competent authority upon request.

NOTE: FSC Forest Management Certification is considered an effective risk mitigation measure to demonstrate no or only a negligible risk.

Non Compliance

If a competent authority establishes non-compliance with the EUDR or that a non-compliant product has been placed on the market or exported, the certification body is informed about the non-compliance immediately.

If new information is obtained or made aware of, including substantiated concerns, indicating that a product placed on the market is at risk of non-conformity with the FSC Regulatory Module, the relevant competent authorities of the country(ies) involved and organizations to whom the product has been supplied must be immediately informed.

Material

Material (1/2)

For using FSC product groups in the scope of the FSC Regulatory Module the following information has to be included:

Name, registered trade name or registered trademark of the supplier;
Postal address, email address and (if available) a web address of the supplier

Verifying supplier documents for sales and delivery involves:

If applicable, the document specifies the regulatory claim (i.e., "Regulatory").
The physical material is checked with the documentation.
The quantity is stated in one of the following ways: a) Kilograms of net mass, and if applicable, against the indicated Harmonized System code; b) Net mass; c) Where applicable, volume or number of items.

NOTE: If the units aren't mentioned above, it's essential to ensure consistency and that it's based on the Harmonized System Code. For further clarification, refer to the Crosswalk guidance about Harmonized System compared to FSC product specifications.

Material (2/2)

To ensure compliance, it is necessary to check if the supplier has provided a reference number for Due Diligence Statements for the materials they supply, where applicable. Up-to-date material accounting records for materials and products within the scope of the FSC Regulatory Module should be maintained, including:

Inputs: Due Diligence Statement reference number(s) and the Regulatory claim

Outputs: Due Diligence Statement reference number(s) and the Regulatory claim

Note 1: FSC claims might be accompanied by a Regulatory Claim such as FSC 100% / Regulatory+, FSC Mix Credit / Regulatory, except for claims of "FSC Recycled."

Note 2: When referring to the separation and/or identification of materials, it includes non-eligible inputs entering FSC product groups in the scope of the FSC Regulatory Module. It also refers to materials for which relevant information about the risk of origin and risk of mixing has been obtained, and where the organization has not yet implemented adequate mitigation measures.

Note 3 (ONLY RELEVANT FOR SME): For small suppliers (SMEs) exempt from providing due diligence statements, seek for reference numbers from the next non-SME upstream supplier.

Sales

Sales (1/2)

Sales documents must include: Due Diligence Statement reference number and a Regulatory Claim for each product. The Regulatory Claim can be REG or REG+.

Due Diligence Statement must be issued before placing a product on the EU market or exporting it (EXCEPTION: SME traders).

Reference to a Due Diligence Statement issued by a supplier/sub-supplier is permissible, provided there is evidence of due diligence conducted.

The information on all customers to whom the material with a Regulatory Claim is supplied has to be maintained, including:

Name, registered trade name or registered trademark;
Postal address, email address and (if available) a web address.

Sales (2/2)

Products exclusively made of input materials from a fully verified supply chain can be identified by adding a plus symbol to the Regulatory Claim, i.e., Regulatory+ or REG+.

Only material in FSC product groups within the scope of the FSC Regulatory Module should be used, and material with the Regulatory Claim should only be sold if it conforms to the requirements of this standard.

The Regulatory Claim for the applicable output must be specified, and the species (common and full scientific name of each species) must also be specified.

An up-to-date list of product groups specifying for each the Harmonized system code(s), with a minimum of six digits has to be maintained.

NOTE 1: A list of possible species is not acceptable in the context of the FSC Regulatory Module.

NOTE 2: One may use the Crosswalk between FSC-STD-40-004a FSC Product Classification and the Harmonized System codes.

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