Contents

FAQ

Requirements Development Process 

  • FSC has developed Consultation Reports to review and indicate how feedback was addressed in the final draft. You can find the summaries of the Consultation Reports for the Regulatory Module and system-wide changes here and the Risk Assessment Framework here. The full Consultation Reports can be found here:

    ·       Consultation Report for FSC-STD-01-004 FSC Regulatory Module

    ·       Second Consultation Report for FSC-PRO-60-006b FSC Risk Assessment Framework

    ·       Consultation Report for Advice Notes

    The Consultation Reports are published on the applicable process pages here:

    ·       FSC Regulatory Module

    ·       FSC Risk Assessment Framework

  • All requirements have been published on 1 July 2024 so certificate holders have time to implement FSC requirements and tools as soon as possible. The requirements are immediately effective for any certificate holders applying the FSC Regulatory Module, while the systemic changes and changes to the FSC Risk Assessment Framework include an 18-month transition starting from 1 July 2024 – with an effective date on 1 October 2024 – and ending December 2025[SH1] [JM2] . A summary and overview of relevant links and documents can be found here:

    Getting certified with the Regulatory Module

    Learn more about the Regulatory Module here. Download the module in the Document Centre here.

    Supporting documents of the FSC Regulatory Module

    FSC has published complementary documents to support the implementation of the FSC Regulatory Module and clarify requirements and alignment with EUDR further. This includes FSC-GUI-40-004a-01 FSC Product Classification & Harmonized System Codes Alignment which outlines how FSC product codes align with EUDR’s Harmonized System (HS) codes; download the document in FSC’s Document Centre here. In addition, related interpretations for chain of custody (INT-STD-40-004-71), controlled wood (INT-STD-40-005-34 & INT-STD-40-005-35) and forest management (INT-STD-01-004_01, INT-STD-01-004_02, INT-STD-01-004_03, INT-STD-01-004_04, INT-STD-01-004_05, INT-STD-01-004_06, INT-STD-01-004_07 & INT-STD-01-004_08) have been published to clarify how FSC’s requirements are aligned with related definitions in EUDR. These interpretations have been compiled with a comparison on FSC and EUDR terminology in FSC Regulatory Module Supporting Materials here.

    Download the FSC Risk Assessment Framework in the Document Centre here.

    System-wide changes through Advice Notes

    To further tighten the FSC system to deliver deforestation-free products, FSC fast-tracked the implementation of changes from the intention of FSC’s Policy to Address Conversion. These changes are in the form of Advice Notes - which will ensure products are deforestation and degradation free in alignment with the EUDR and do not enter the system and become FSC-certified. Additional Advice Notes for chain of custody and controlled wood users are included to support the implementation of the Regulatory Module and align with global best practices. The following Advice Notes have been published and are immediately effective for users of the FSC Regulatory Module:

    -          ADVICE-20-007-24 Deforestation-free products from FSC-Certified management units

    -          ADVICE-20-007-02 Certification of Primary Forests

    -          ADVICE-40-004-26 Inclusion of the FSC Regulatory Claim

    -          ADVICE-40-005-27 Use of FSC-PRO-60-006b Risk Assessment Framework

    -          ADVICE-20-001-19 Evaluation of the use of FSC-PRO-60-006b Risk Assessment Framework

     [SH1]@Jannicka Murphy It might be confusing to refer to 18 month transition period because it is not 18 months from October to December next year. Proposing to remove, or adding ...transition from 1 July - with effective date on 1 October 2024 - and ending 31 December 2025.

  • The transition timeline differs between the FSC Regulatory Module and the Advice Notes that are applicable across the FSC system.

    The FSC Regulatory Module is effective immediately on 1 July 2024 so that certificate holders applying the module can implement the requirements and tools immediately. There is no transition timeline for the FSC Regulatory Module. 

    The Advice Notes applicable across the FSC system became effective immediately on 1 July 2024 for those certificate holders that are applying the FSC Regulatory Module. 

    For all other certificate holders, the Advice Notes are effective on 1 October 2024 with a transition end date of 31 December 2025.

  • FSC has published a range of supplementary materials to understand the upcoming requirements and offerings. They are as follows:

    ·       Webpage to find the resources and information on the FSC Regulatory Module is here. This includes infokits, webinar recordings, the Simplified Risk Assessment template and more.

    ·       Webpage to find the resources and information on FSC’s Risk Assessment Framework is here. This includes the Risk Assessment Template, infokit, a quick guide on risk assessment development and tutorials for using the Risk Assessment Template and more.

    ·       Interactive user journey webpage to understand the FSC Regulatory Module requirements based on user type at https://www.fsc-eudr-journey.org/

    ·       Resources on overall on how FSC is aligning with EUDR on the dedicated EUDR Aligned webpage here: www.fsc.org/eudr.

General
system-wide certification requirements

  • Yes, FSC has developed some Advice Notes that are relevant across the FSC system. To further tighten the FSC system to deliver deforestation-free products, FSC fast-tracked the implementation of changes from the intention of FSC’s Policy to Address Conversion. These changes are introduced to the existing system in the form of Advice Notes - which will ultimately ensure products are deforestation and degradation free in alignment with the EUDR and do not enter the system and become FSC-certified. Additional Advice Notes for chain of custody and controlled wood users are included to support the implementation of the Regulatory Module and align with global best practices. The following Advice Notes have been published and are immediately effective for users of the FSC Regulatory Module:

  • The intentions of the EUDR and FSC are already closely aligned. With the publication of EUDR, FSC is furthering that alignment by accelerating changes already planned based on alignment with the Policy to Address Conversion. As closer align with the intention of the Policy to Address Conversion and the envisaged continued and enhanced alignment with global commitments to end deforestation, FSC is now putting in place strict rules that prevent any material stemming from conversion activities to end up in FSC certified products.

FSC Regulatory Module general 

  • No, the FSC Regulatory Module is a voluntary add-on module only. Once the certificate holder includes the Module in its certification scope, the requirements become mandatory.  For Forest Management certificate holders it applies to all Management Units (MUs); for Chain of Custody users, certificate holders can choose which product groups it applies to.  

    FSC has opted for a voluntary approach due to the different levels of impact depending on the company’s activities or supply chain. To reduce the effort in demonstrating compliance with the EUDR in the EU supply chain, the certificate holder may request their suppliers to sell material with the Regulatory claim.

  • Currently, the FSC Regulatory Module only addresses the European Deforestation Regulation (EUDR). As further regulatory developments progress, FSC could utilize the module for further regulatory alignments.

  • This standard is for voluntary use by organizations applying for or holding FSC certification to extend their certification scope to align with the EUDR. It can be used in addition to all existing certification types and includes accreditation requirements for certification bodies. The FSC Regulatory Module standard focuses on wood, wood-based products and rubber. It can be applied by organizations within and outside the European Union (EU), which in case the latter applies, organizations are exempted to conform with some of the requirements (see Annex 1 of the FSC Regulatory Module).

  • If you are an FSC Certificate Holder and you would like to know if EUDR applies to you, you can search your product code in the FSC Product Classification & Harmonized System Alignment guidance document in the Document Centre here.

  • No, this is not a standalone set of requirements but rather an add-on module. Users must also either already be certified with FSC or selecting to include the FSC Regulatory Module as part of their certification process.

  • No, each company in the supply chain can choose to include the Regulatory Module in its certification scope. Nevertheless, there are benefits to having a ‘fully verified supply chain’, as all the necessary data will be available, lowering the demand, effort and risk while conducting the due diligence.

  • The FSC Regulatory Module includes the definitions for “operator” and “trader” as well as icons to identify which requirement is relevant for which user-type based on the EUDR terminology of “operator”, “trader”, “SME,” and “non-SME.”

    Note: In order to avoid confusion with the term ‘trader’ as defined in <FSC-STD-40-004 Chain of Custody Certification>, FSC uses the term ‘regulatory trader’ in the standard when referring to a trader in the meaning of the EUDR.

  • Certificate holders need to request for a scope extension from their certification bodies to include the FSC Regulatory Module and at minimum a desk-based audit will need to be done either during the next surveillance audit or as agreed with the certification body (so not only from 1 January 2025).

  • Certificate holders will need to request for a scope extension from their certification bodies to include the FSC Regulatory Module and at minimum a desk-based audit will need to be done either during the next surveillance audit or as agreed with the certification body from 1 July 2024 (so not only from 1 January 2025).

  • No, only competent authorities have the authority to verify compliance with the EUDR. FSC has included additional requirements that can support demonstrating this compliance by aligning FSC requirements with EUDR but the decision still rests solely on the competent authority. Certification bodies will check for conformity with FSC requirements, which can benefit users by having another third-party verifying conformity.

  • The requirements depend on the user-type (as defined by the EUDR, and reflected in the Regulatory Module), as well on the characteristics of the supply chain. Important to note that ‘non-SME Trader’ follow the same requirements as ‘non-SME Operators’.

    While conducting the due diligence, the organization shall obtain the information outlined in Section 4.9 (Due Diligence System – Obtaining information on input material) of the FSC Regulatory Module. The organization may engage with relevant suppliers and sub-suppliers in order to obtain clear and convincing evidence of conformity.

    The Regulatory Module allows for some exemptions on conducting risk assessments (and risk mitigation measures) – see Clauses 4.8.2 and 4.8.3, and Section 4.13. For situations where it’s not applicable, and for FSC 100% products, the organization will have a simplified risk assessment template provided by FSC.

  • The Regulatory claim can be used associated to any FSC claim (except FSC Recycled - out of scope), and it may be used in all control systems (i.e., transfer, percentage, credit). Materials within the Regulatory Module scope have to be physically segregated from those not included (if applicable).

    For non-certified material to be included in the Regulatory Module scope, certificate holders are to conform with <FSC-STD-40-005 Requirements for Sourcing Controlled Wood> plus the requirements in the Regulatory Module for chain of custody users.

  • The combination of the FSC Regulatory Module with the FSC Trace (see here for more FSC Trace information) is the stronger solution for the certificate holder. If suppliers/sub-suppliers also apply this combination of FSC tools it is considered the ideal situation to reduce burden and human error, and thus reducing the risk of circumvention of the EUDR, risk of origin and the risk of mixing. Companies can benefit from a detailed description on what to consider when assessing the risk by using FSC Risk Assessments in conformity with FSC-PRO-60-006b Risk Assessment Framework.

  • The FSC Regulatory Module is not required to be implemented by every certificate holder in the supply chain. If a non-certified company takes legal ownership of the FSC-certified / Regulatory claimed material, it will lose its certification status (as any other FSC-certified material). If a certificate holder further down the supply chain wishes to include the material as an eligible input under a Regulatory product group, the existing requirements apply (FSC-STD-40-005 in addition to FSC-STD-40-004), as well as the requirements under the FSC Regulatory Module.

  • No. FSC does not charge an additional fee for the Regulatory Module. However, the module contains extended requirements that require additional audit. The type of evaluation (e.g., on-site audit, document-based, field visit) will vary depending on the specific situation. Therefore, there will be additional costs from CBs to conduct the extended evaluation. The costs for auditing will depend on the CBs’ service fee and the actual scope of the evaluation that the CBs have to perform as mentioned above.

  • Unfortunately, due to limited capacity, we are unable to meet with each company individually. Please contact the FSC regional and national offices for more information and advice on how to become certified and include the Regulatory Module in your scope of certification.

  • As a certification system, we build and maintain the FSC certification system using FSC standards, procedures, policies and supporting tools. However, we do not have access to our certificate holders' harvest or supplier information due to confidentiality and trade secrets. Please engage and work directly with your suppliers to obtain the necessary information.

    If the certificate holders are users of the FSC regulatory module. They are required to collect the geolocation information and make it available to downstream operators and traders upon request.

  • Obligations under the EUDR are not industry specific. They are based on the company’s role in the supply chain (i.e., operator or trader) and whether the company is classified as an SME or non-SME. Since the FSC Regulatory Module mirrors the requirements of the EUDR that are relevant for certificate holders, it works with the same logic.

    The FSC Regulatory Module includes the definitions for “operator” and “trader” as well as icons to identify which requirement is relevant for which user-type based on the EUDR terminology of “operator”, “trader”, “SME,” and “non-SME.”

    NOTE: A single organization can either be classified as SME or Non-SME. However, an organization may act as an operator or a trader at the same time, depending on the position in the supply chain. The type of organization might further differ between different product groups.

  • Regulatory Module users will have the new standard added (and claims Regulatory/Regulatory+) to their scope of certification - which will be displayed in the FSC certificate database.

  • Yes, it would be beneficial for example if you expect your clients to need and ask for the information or would like to make sure your products are easy to place on the EU market for new clients. This will help your clients to comply with the EUDR requirements.

  • The FSC Regulatory Module has been developed to minimize the effort for forest management certificate holders building on the groundwork already done to achieve FSC Forest Management Certification.

    The EUDR requires that due diligence is exercised to demonstrate that the products are deforestation-free and have been produced according to the relevant legislation of the country of production.

    While FSC requirements, including the new ADVICE-20-007-24 Deforestation-free products from FSC certified management units, cover these aspects and there are not additional changes to forest practices required, EUDR (and therefore the module) requires activities, such as collection of information, risk assessments and risk mitigation measures, issuance of a due diligence statement, maintenance of records, etc.

    The module supports forest management certificate holders to demonstrate that several of these aspects are covered by FSC certification, while minor efforts are still needed.

  • FSC has provided a Simplified Risk Assessment Template which serves:

    ·       To support certificate holders to assess the risk if no FSC Risk Assessment exists, and

    ·       To demonstrate that FSC Forest Management Certification is a solution to achieve no or negligible risk, if a non- negligible risk has been identified in the FSC Risk Assessment or the company risk assessment.

  • Certificate holders applying the Controlled Forest Management standard will have to conform with the same requirements as forest management certificate holders.

  • The FSC Regulatory Module includes supplementary requirements regarding how the standard is implemented in a group set up. This includes, for example, how responsibilities are divided or how the internal monitoring system has to be adapted. All group members are obliged demonstrated conformity with the FSC Regulatory Module, if this is to be included in the scope.

  • This would argue for a green lane for forest management certification which is not acceptable for EU authorities - formal steps of information gathering, risk assessment and mitigation are required in all cases of non-negligible risk. However, FSC considers demonstrated conformity to a national Forest Stewardship Standard as a way to achieve negligible risks. Should this not be the case, it may be a risk mitigation measure that would contribute to in any non-negligible risks being effectively mitigated.

  • Term not explicitly defined in the FSC system. FSC definitions of conversion and degradation together with FSC Interpretations #INT-STD-01-004_01, #INT-STD-01-004_02, #INT-STD-01-004_04 and #INT-STD-01-004_05 published in <Forest Management Interpretations>, and ADVICE-20-007-24 Deforestation-free products from FSC certified management units and ADVICE-20-007-02 Certification of primary forests published in <FSC Directive on Forest Management Evaluations> provide the clarification and normative connection to the EUDR definition for full alignment.

Forest Management Regulatory Module 

Chain of Custody Regulatory Module 

  • Following the provisions of the EUDR, FSC’s Regulatory Module includes specific requirements depending on your organization’s position in the supply chain. (i.e., Operators and Traders). One new aspect that was introduced is the development and implementation of a Due Diligence System (DDS) that includes at a minimum the collection of information, a risk assessment, and risk mitigation processes.

    FSC is also introducing a new output claim (i.e., ‘Regulatory’) for products sold through the FSC Regulatory Module. As a result, certificate holders that are not using the FSC Regulatory Module can voluntarily decide to add the Regulatory claim to their scope.

  • FSC is introducing a systemic change so that non-users of the FSC Regulatory Module have clear requirements for the purpose of controlling the Regulatory output claim. The organization may choose to use the Regulatory claim in sales documentation (followed by the FSC claim), provided that the provisions in the new advice note are met.

  • The purpose of a due diligence system (DDS) is to assess and mitigate the risk of sourcing material from unacceptable sources. At a minimum the organization has to annually review (and revise if necessary) and address changes that may affect the relevance, effectiveness or adequacy of the DDS. As long as those changes do not occur (e.g., in supply area, type of products, species), the organization is not required to change its DDS every time it collects information.

  • You are always responsible for the plausibility and accuracy of the information collected no matter where your supplier is based, inside or outside the European Union (EU). EUDR is only applicable to organizations that operate or trade in the EU, so if your supplier is outside of the EU they are not required to be compliant with the EUDR. Hence, a higher level of evaluation may be needed to determine their products’ compliance.

  • The Harmonized System (HS) codes are a standardized numerical method of classifying traded products. FSC product types are a general description of outputs based on the classification system specified in FSC-STD-40-004a. FSC standards apply to all products within the forest matrix, while the EUDR requires the reporting of specific HS codes, detailed in EUDR Annex I.

    This means that not every FSC-certified organization will fall under the provisions of the EUDR, but for those who trade in products that are listed in Annex I, compliance with the EUDR will be required. To bridge the gap between HS codes and FSC Product Classification, FSC has published a guidance tool <FSC-GUI-40-004a> so that organizations can match both classifications.

  • As mentioned in 5.3 of this document, the DDS as a system has to be maintained up-to-date, and be reviewed (and revised if necessary) at least annually and whenever changes occur (see Clause 4.8.5 of the FSC Regulatory Module). The inclusion of a new product is considered a change to the DDS, and would therefore require a risk assessment. Per se, the risk assessment does not need to change for each shipment, but that is an assessment based on the collection of information (see Section 4.9 of the FSC Regulatory Module).  

    The annual volume summary (see Clause 4.4 of FSC-STD-40-004 V3-1), refers to the previous reporting period. The ongoing collection of input information will be used to conform with the referred clause and Clause 4.4.1 of the FSC Regulatory Module.

  • Simplified due diligence (as described in Section 4.13 of the FSC Regulatory Module) can be applied to any FSC claim (except FSC Recycled – out of scope), provided the conditions in the section are met. In addition to the EUDR three-tier risk system, the certificate holder needs to consider the risk designation from the applicable FSC Risk Assessment. Risk still needs to be mitigated if any non-negligible risk (in the FSC Risk Assessment) or any information on substantiated concerns is found. Nonetheless, the certificate holder has to always assess the risk of mixing (Clause 4.10.7) and, where applicable, implement proportionate risk mitigation measures.  

  • The Regulatory Module can be used for all control systems (transfer, credit, percentage). However, regardless of the control system used, a product group shall not have non-eligible inputs (non-controlled under the provisions of the Regulatory Module).

  • The assessment of the risk of mixing aims to avoid mixing with materials of unknown origin or produced in areas where deforestation or forest degradation has occurred or is occurring. The risk of mixing includes the stages of transport, processing and storage. It is dependent on the supply chain itself, but shall include, at minimum, the stage of processing of the products and the complexity of the supply chain (e.g., the number of tiers of suppliers, geographies in which suppliers are located, size and type of supplier’s operations).

  • Within the certification, the organization may choose which product groups are included in the scope of the Regulatory Module. Between FSC-certified and non-FSC-certified products, the latter ones are outside of the FSC scope (and thus, outside the scope of the Regulatory Module), and are not assessed by the certification body (nor can be promoted as being in conformity with the FSC requirements). In any case, the FSC Regulatory Module is a public tool that companies can use for their reference.

  • For sourcing FSC Mix or FSC Controlled Wood material/products, the certificate holder will have to conduct the risk assessment (and applicable risk mitigation measures), using the applicable FSC Risk Assessment based on <FSC-PRO-60-006b FSC Risk Assessment> (if available). When not available, the certificate holder will have to conduct its own risk assessment, according to the requirements of the referred procedure. Together with the system-wide changes, the certificate holder will be able to use the FSC system as a tool for compliance.

  • FSC uses the term ‘regulatory trader’ in the FSC Regulatory Module when referring to a trader in the meaning of the EUDR. It aims to avoid confusion with the already existing term 'trader' within the FSC system, which means ‘not conducting any transformation of a product’.

  • The FSC Regulatory Module maintains the concept presented in FSC-STD-40-004, where product groups are based on the eligibility criteria of the inputs received. All inputs included in the scope of certification of the FSC Regulatory Module must adhere to the requirements of this standard, regardless of whether they are certified or non-certified. See Table 3 of the FSC Regulatory Module for more information.   

  • Yes. For FSC 100% input material, the organization can conduct the risk assessment using the simplified risk assessment template provided by FSC (see also 4.2 of this document), which significantly reduces the workload for organizations compared to other FSC-claimed or controlled materials.     

    Under the EUDR, organizations are required to conduct due diligence regardless of the application of a third-party certification system, such as FSC.

FSC Risk Assessments 

  • To align with EUDR, apart from CW, risk assessments are now also applicable to Forest Management and Chain of Custody certificate holders aiming to conform with the FSC Regulatory Module. In addition, the following are key process-related changes specified in <FSC-PRO-60-006b Risk Assessment Framework>:

    a)    The process requirements have been streamlined considering the need for ensuring that the requirements can be followed by other organizations participating in the Risk Information Alliance (further information under the following link: www.riskinformationalliance.org).

    b)    Experts shall be consulted on the draft risk assessment (including but not limited to selected indicators), if:

                       i.           there are limited publicly available sources of information to evaluate the indicator and to reach a risk conclusion;

                      ii.           there are doubts on how risk conclusions shall be graded (e.g., whether the risk is widespread, systematic, etc.); and

                    iii.           input is needed to establish mitigation measures.

    c)     Establishment of mitigation measures where ‘non-negligible risks’ are identified. In addition, the following requirements have been added: i. In centralized type of processes, only recommended mitigation measures can be established; and ii. Mandatory mitigation measures are only possible to be established by a chamber balanced WG when developing or revising a risk assessment through a major type of process.

    d)    In addition to a complete review and eventual revision every 5 years, annual review of the comments received from stakeholders on published FSC risk assessments to ensure that the applicable legislation, risk designations and mitigation measures are up to date. The responsible organization shall decide if a revision should be done immediately or if the information can be stored and included during the scheduled revision instead.

    For further information on key process related changes, please read the crosswalk document released together with the <FSC-PRO-60-006b V2-0 Risk Assessment Framework> under the following link: https://connect.fsc.org/current-processes/revision-risk-assessment-framework-procedure-fsc-pro-60-006b.

  • The main changes proposed to content requirements can be summarized under the following aspects:

    a)      A common set of indicators: FSC Risk Assessments now include 64 indicators instead of 32 indicators. Although there is an increase in the number of indicators, the topics covered are mostly the same (e.g. legality assessment, human and labour rights, HCVs, conversion, GMO, etc.). The requirements have structurally changed through how the proposed indicators are written.

     

    b)    Assessment of conversion is now aligned with the <FSC-POL-01-007 Policy to Address Conversion> as well as EUDR. Indicator 55 is fully aligned with EUDR, assessing conversion from natural forests and transformation of plantations to agricultural use including adopting the precautionary approach to assess the risk of conversion. Therefore, a ‘non-negligible’ risk designation for conversion is applied as a default. Risk assessments developed by a chamber-balanced working group may change the risk designation through data analysis demonstrating that conversion has not taken place in the area under assessment since 31 December 2020.

    An additional indicator (56) has been added to assess conversion from natural forests to land uses other than agriculture to ensure alignment with the FSC Policy to Address Conversion, which includes a numerical risk threshold of 0.02% gross annual loss of natural forest area.

     

    c)     Assessment of forest degradation: A new indicator (57) introduces the assessment of forest degradation: There is no forest degradation since 31 December 2020, including a numerical ‘non-negligible’ risk threshold to assess this indicator: The degradation since 31 December 2020 in the area under assessment is more than 0.02% of the total natural forest area on average per year.

    A definition on forest degradation has been added in the section ‘Terms and Definitions’. The definition of the term ‘natural forest’ is based on FSC definition, but the approach to assess this indicator is based on EUDR requirements.

    d)    Intact Forest Landscape boundaries may be updated by using other forms of best available information (in addition to the Global Forest Watch maps), such as historical harvesting documentation, existing Forest Stewardship Standard (FSS) frameworks, maps and external data provided by independent organizations, scientists and experts.

    For further information on key content related changes, please read the <FSC-GUI-40-005 Crosswalk of Indicators between Risk Assessment Framework V1-0 and V2-0>, and the crosswalk document released together with the <FSC-PRO-60-006b V2-0 Risk Assessment Framework> under the following link: https://connect.fsc.org/current-processes/revision-risk-assessment-framework-procedure-fsc-pro-60-006b.

  • Risk Assessments can limit the scope of assessment to a country, a region that is part of a country, or a region that covers more than one country, as well as to specific products (e.g. timber, rubber, specific NTFPs, and more) and to some of the indicators that are specified in <FSC-PRO-60-006b V2-0 Risk Assessment Framework>.

  • Indigenous Peoples rights are covered by the risk assessment indicators, including assessment of legal compliance, as well as those rights covered by ILO provisions and the United Nationals Declaration on the Rights of Indigenous Peoples (UNDRIP), including Free, Prior and Informed Consent (FPIC). 

  • With the <FSC-PRO-60-006b V2-0 Risk Assessment Framework> anybody can use the FSC Risk Assessments; there is no requirement for certification.

  • The <FSC-PRO-60-006b Risk Assessment Framework> was published on 1 July 2024. FSC is working to have 20 prioritized Risk Assessments revised and available in 2025.

  • FSC has identified 20 priority countries. They are as follows (listed alphabetically): Austria, Brazil, Canada, Chile, China, Estonia, Finland, France, Germany, Indonesia, Latvia, Poland, Portugal, Romania, Spain, Sweden, Türkiye, United Kingdom, Ukraine and USA. FSC will publish related announcements on the process page here.

  • A chamber-balanced process to develop/revise risk assessments will always be a possibility. In practice, a centralized based risk assessment will be replaced by the chamber balanced based risk assessment, once approved by FSC.

  • Stakeholders are encouraged to provide inputs during consultation for the development or revision of a Risk Assessment. In addition, the Risk Assessments will be reviewed and updated annually to ensure that the applicable legislation, risk designations and mitigation measures are up-to-date. The annual review will be based on expert and stakeholder inputs. Stakeholders and experts will have the possibility to continuously provide inputs to the Risk Assessment and share information through an online platform provided by FSC.

    Furthermore, FSC will be seeking to identify experts to support the revision of Risk Assessments in prioritized countries.

  • If there is no updated FSC Risk Assessment in the country/region, companies aiming to conform with the Regulatory module will have to develop an extended company risk assessments following the requirements under FSC-PRO-60-006b, including a template provided by FSC.

  • You can access to the FSC Risk Assessment Platform which contains the risk designation per indicator of each of the current 60 Controlled Wood Risk Assessments under the following link: https://connect.fsc.org/chain-custody-certification/fsc-risk-assessment-platform

    The existing Framework to develop them is here: https://connect.fsc.org/document-centre/documents/resource/377

    You can also search for the PDF document of each of the existing Controlled Wood Risk Assessments in the Document Centre, under the following link: https://connect.fsc.org/document-centre

    Nevertheless, the results of the revised FSC risk assessments will only be available for the first 20 prioritized countries in 2025.

  • That is the goal of the proposed changes by FSC - as long as the Regulatory Module is being used. This is applicable to all FSC claims (with exception of FSC Recycled - out of scope). Please note that FSC refers to conformity to the requirements, as a supporting tool for company's compliance with EUDR as no certification system can be considered a green lane.

  • No, only risk assessments developed in accordance with <FSC-PRO-60-006b Risk Assessment Framework> are to be used within the FSC Regulatory Module. Please see Part 4 ‘Forest Management Regulatory Module’ regarding the template provided by FSC to be used by certificate holders to assess the risk if no FSC Risk Assessment exists.

  • FSC has formed an alliance between partners facing similar challenges around developing risk assessments through the Risk Information Alliance. This Risk Information Alliance will foster global sustainability leadership by collaborating with other sustainability leaders with a focus on developing a single, standardized Risk Assessment framework that will benefit both certified and non-certified companies.  The Risk Information Alliance aims to streamline the development of requirements and decision-making processes. However, <FSC-PRO-60-006b Risk Assessment Framework> still allows the development of risk assessments through chamber-balanced working groups; thus building flexibility and a means of fast-tracking risk assessment development with new avenues. Learn more about the Risk Information Alliance at www.riskinformationalliance.org.

  • FSC includes environmental and social values through indicators in our current Controlled Wood Risk Assessment Framework which comprise key requirements for FSC system. For example, the assessment of High Conservation Values, child labor including related rights as specified in ILO Fundamental Principles and Rights at Work, among others.

  • Certification bodies are verifying certificate holders’ conformity to the certification requirements of the FSC Regulatory Module.

  • The application of the FSC Regulatory Module requires an extension of the certification scope of certificate holders. This means that certificate holders need to make a request for scope extension to their certification body. At minimum certification bodies will need to conduct a desk check of the certificate holders’ documentation (e.g. procedures) before the scope extension is made (Clause 8.2.1 of the FSC Regulatory Module).

  • As a prerequisite, certification bodies must have controlled wood (CW) in their accreditation scope. Certification bodies need to signal to ASI once they are ready from their side to offer verification against the Regulatory Module. ASI will then do a desk audit or combine the audit with a head office assessment in case the timing coincides. The extension of the accreditation scope to include the FSC Regulatory Module is voluntary.

  • FSC is not planning to provide formal training to certification bodies on the FSC Regulatory Module but will be supporting the introduction and alignment process with FSC and between certification bodies by organizing workshops in Q4 2024 and in the following year. The FSC Regulatory Module accreditation requirements will be similar to the existing accreditation requirements and will not require key new competences from the certification bodies.

  • No, this will not be possible as the FSC Regulatory Module is not designed to ensure independent certification and accreditation against the module but works in conjunction with regular FSC certification and accreditation. Auditors will need to demonstrate the qualifications and trainings as required by <FSC-STD-20-001 General requirements for FSC accredited certification bodies> and <FSC-PRO-20-004 General requirements for an FSC Training Programme>, that are designed specifically for FSC.

  • The Regulatory Module includes a general requirement for certification bodies to respond to Competent Authority requests for information concerning the EUDR compliance of their clients. This is to facilitate the collaboration where needed.

    In practice the Regulatory Module foresees little direct interaction with Competent Authorities, as it is the core responsibility of the certificate holder to exchange with Competent Authorities, e.g. when the certification body detects a major non-conformity with the Regulatory Module. When the Competent Authority detects a non-compliance with the EUDR it is expected that the certificate holder is informed who is then required to notify the certification body. In such cases the certification body is expected to check whether the identified non-compliance constitutes a non-conforming product according to the Regulatory Module and if confirmed to suspend the certificate holder.

Regulatory Module Accreditation Requirements 

Questions about FSC Trace? Visit the FSC Trace page here to find an answer.

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