More Certified Paper Stuff? Really??

By on August 16th, 2010

As if you need more banter about FSC, SFI and PEFC, here comes yet another slew of mindless babble about paper certification. First however, I must digress.

I always tell my clients to look at the forests in which they live and find a grove over 100 years old. Although this is a generalization, for the most part, we screwed things up with our early logging practices when the supply was “limitless”. That said, this is now our collective legacy and our responsibility. No offence, but many of you have no concept of what our forests looked like before we got here. What’s occurring now in under-developed nations world-wide happened here a hundred or more years ago. Ok, now back to the drivel at hand.

What most people don’t realize is that there are two types of “certified” virgin fibers that can go into our paper. First is from managed (read third-party audited) forests. Second is what we’ll generically call verified responsible procurement, where the forests themselves are not audited, but the wood is confirmed to have been legally sourced, and basic environmental, social and local economic criterion are met.

Now listen very carefully; both go through a certification process of one type or another. Both are considered “certified” and both can be included in a Chain of Custody (CoC) certified product, because both can be traced back to their origin. Got it? Good!

Although there are philosophical differences between FSC, SFI and PEFC as to what constitutes good forest management, the purpose of this writing is not to discuss the merits of one certification system over the other, but simply to state that any management system is better than no management at all.

Let’s be brutally honest. If you are currently certified to anything, chances are it’s because you were told you had to be. Your clientele’s marketing and public relations folks are in the business of positive image and profitability (or at least accountability). Credibility and transparency are key components of that. Oddly enough they are also the main tenants of responsible sourcing and of CoC.

Look at a CoC label like you do the UL or CE label on your electronics. It’s a guarantee, a promise. To your customers it means that you voluntarily have someone looking over your shoulder as a partner to give them the assurance that, odd as it may sound; certified paper is actually verified to have been used in their certified product.

Did you know there are many papers out there that are available as either CoC certified or not depending on whether credits (based on equivalent Forest Management (FM) certified purchase volumes) have been applied? And that the non-FM certified portion still comes from certified procurement sources? Is it a perfect process? No, but until enough land is third-party audited to any kind of FM standard, it’s the best we have. Bottom line is that (and listen carefully) none of the fiber that goes into any CoC certified product comes from unknown or illegal sources.

Ok, back to the banter. So once again, there is FM-certified wood and there is responsibly procured wood. FSC’s responsible sourcing program is called FSC Controlled Wood (FSC CW). SFI’s version is called SFI Fiber Sourcing. The difference between the two is philosophical at best, although I know others would argue that.

Among other things, the FSC has made the decision not to sell FSC CW as a labeled product to end-users, but only as a component as an FSC Mixed CoC product. Although there is no such thing as a Controlled Wood label, when you buy brand of paper that is available as FSC certified upon request, but what you’re purchasing isn’t, the fiber is actually equivalent to the volume of FSC CW. The SFI on the other hand allows for the sale of Fiber Sourcing-labeled products to end-users, but this is not CoC certified (I’m sure that’s clear as mud).

One thing must be understood. If clients request CoC certified rather than simply certified paper, then SFI Fiber Sourcing products are not an option. Only SFI CoC, PEFC CoC or FSC CoC are. Case-in-point; Sears Holdings instituted just such a paper purchasing policy in November 2009. Many other private-sector, government and institutional organizations have also implemented similar policies. Just Google “paper purchasing policy” and see what pops up. Some say “certified” others say “CoC certified”.

So with all of this confusion what is the definition of “certified”? The (triple) bottom line is that even SFI Fiber Sourcing/FSC Controlled Wood certification goes through an in-depth risk analysis which includes among other things the reputations of the providers, the level of corruption in the region, as well as other aggravating factors.

High risk situations trigger third-party audits even under certified sourcing programs. As an example, based on historical environmental and human rights violations, this past April (the month), APRIL (Asia Paper Resources International Limited) had their FSC Controlled Wood certification suspended. Remember, this was not a CoC certification that was revoked, but simply a responsible procurement certification. What does that tell you about the bigger issues out there?

And finally as many of you know, pending expected legislation is the elephant in the room; the 110 year-old Lacey Act. Under the Lacey paper and print amendment it will be “unlawful to import, export, transport, sell receive, acquire or purchase in interstate or foreign commerce any plant taken or traded in violation of the laws of a US State or most foreign laws”. The reality is that Lacey as it pertains to paper and printing goes back under consideration on September 1, 2010.

Although not yet, eventually, it will become law, and when it does, any paper product is subject to at the very least confiscation upon even the accusation that the paper was illegally sourced. The scary part is that even if your supplier’s supplier is charged, you and your customers technically become confiscation-liable. And although CoC certified paper and to a slightly lesser degree, certified responsibly procured paper is not the end-all, it goes a long way in establishing “due care”. So in effect, oddly enough right now it is not illegal to purchase paper sourced illegally, but it soon will be.

If your customers are satisfied with your word, and they don’t require a licensed CoC (or Fiber Sourcing) brand to be printed on their material, then fine. But if they do require their suppliers to be certified everybody’s on a level playing field anyway. If you don’t believe me, go buy your next computer without a UL or CE label.

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    2 Responses to “More Certified Paper Stuff? Really??”

    1. Laura Says:

      Please check your facts regarding Lacey….
      http://www.aphis.usda.gov/plant_health/lacey_act/downloads/LaceyActPrimer.pdf

      The Lacey Act Amendment became effective March 22, 2008.
      http://www.aphis.usda.gov/plant_health/lacey_act/index.shtml

      What is not yet in effect for some products is the declaration requirement. For instance, printed books fall under Federal Register Chapter 49, and are not yet scheduled for declaration requirements.
      http://www.usitc.gov/tata/hts/bychapter/index.htm

      SECTION X: PULP OF WOOD OR OF OTHER FIBROUS CELLULOSIC MATERIAL; WASTE AND SCRAP OF PAPER
      OR PAPERBOARD; PAPER AND PAPERBOARD AND ARTICLES THEREOF
      Section Notes
      Chapter 47 Pulp of wood or of other fibrous cellulosic material; waste and scrap of paper or paperboard
      Chapter 48 Paper and paperboard; articles of paper pulp, of paper or of paperboard
      Chapter 49 Printed books, newspapers, pictures and other products of the printing industry; manuscripts, typescripts and plans

    2. Vic Barkin Says:

      Thanks for your comments Laura,

      I did check my facts. My information is that this amendment was supposed to go into effect as of March 2008 concerning paper and printing, but was tabled until later this year to even be considered, to wit from the Federal Register:

      Revised Phase-in Schedule
      After review of the comments
      received, further internal consideration,
      and experience with implementation of
      the first phase of enforcement of the
      declaration requirement, we have
      revised the phase-in schedule, which
      covers the period from December 15,
      2008, to August 31, 2010. In our
      February notice, we committed to
      providing affected individuals and
      industry with at least 6 months’ notice
      for any products that would be added to
      the phase-in schedule. Although we
      have modified phase III, which is
      scheduled to begin on October 1, 2009,
      we have only removed items from this
      phase. Phase IV, scheduled to begin
      April 1, 2010, has been substantially
      revised. Those changes were based on
      information supplied by commenters
      and further consideration within the
      interagency group of the products that
      would supply the most valuable
      information to inform the Federal
      Government as we continue to
      implement the statute and develop
      recommendations for Congress as
      required by the Act.
      Several commenters contended that
      identifying composite and recycled or
      reused materials (e.g., medium density
      fiberboard, particleboard, and scrap
      wood) to the genus and/or species level
      would be difficult and in some cases
      impossible. In response to those
      comments, we have decided to further
      delay enforcement of the declaration for
      such products. We currently propose to
      begin enforcing the declaration for those
      products no earlier than September 1,
      2010. This delay in enforcement of the
      declaration requirement will allow the
      Federal Government more time to
      evaluate options for enforcing the
      declaration for these goods.
      The revised phased-in enforcement
      schedule through August 31, 2010, is
      described in the table below with the
      date that enforcement of the declaration
      requirement begins listed at the top of
      each column. It is important to note that
      while enforcement of the declaration
      requirement is being phased in, the
      other Lacey Act amendments are
      already effective, and actions to enforce
      provisions of the Act other than the
      declaration requirement may be taken at
      any time.

      Hope this helps,

      Vic