Recently, the Forest Stewardship Council released their revised FSC-DIR-40-004 document, containing a series of advice notes which every certified printer (and converter, and merchant, and broker) “should have” received through their certifying body (CB). Included in this document is Advice Note ADVICE-40-004-03 which deals with the ability for printers to FSC-Label certain classifications of paper.
A synopsis of the official background for ADVICE-40-004-03 which is contained in FSC-DIR-40-004 and is titled: “Reduced labelling threshold of 50% for chip and fibre based products” states in effect that when the new Chain of Custody standard was approved in November 2007, a labeling exemption threshold of 50% (certified material, the balance being “controlled”) for chip and fibre based products under a percentage (or transfer) system was maintained by means of an Advice Note. (All solid wood products such as or made from lumber, plywood or veneer had to implement a 70% minimum at that time which is still in force today).
The FSC would have loved to enforce the conformance for all chip and fiber products which includes all paper and paperboard to the 70% minimum back in 2007, but the mills pushed back and reduced labeling threshold was born. This advice note now the latest twist added to the existing requirement as a way to definitively force the mills to conform with the intended 70% minimum within five years (their other option being to move to a Credit System).
The official advice note can seem quite cryptic:
- FSC certificate holders may request authorization from their certification bodies to continue labelling chip and fibre products based on a reduced labelling threshold of 50% until 31 December 2015
- Authorization shall only be granted for those product groups with chip and fibre components registered as being commercially produced based on a labelling threshold of 50% before 01 April 2011.
- Certificate holders operating a transfer system that have not registered their product groups can also label products based on a labelling threshold of 50% in case they are able to demonstrate to their Certification Body that the material they receive has already been registered by a previous company or the material was received with an FSC on-product label.
a. In the first case, sales and delivery documents issued by the supplier shall include the additional claim “registered” (e.g. “FSC Mixed 50% registered”);
b. In the second case, the certificate holder shall retain evidence that the product was received with an on-product FSC label (e.g. packaging or product sample).
- Certificate holders interested in the product registration shall submit the following documentation to their Certification Body until 31 March 2011:
a. A list of product groups with products labelled on the basis of a 50% threshold, using the template provided in Annex A of this Directive;
b. Copies of sales invoices for the registered products in each listed product group as evidence that they have been commercially produced.
- Certification bodies shall upload the approved registration form into the FSC database following the procedures to make it publicly available. No new product groups can be added to this list after 31 March 2011.
- Product groups registered by certification bodies according to this advice shall be in compliance with a labelling threshold of 70% as of 01 January 2016.
NOTE: Companies that do not comply with the requirements of this advice are not eligible to label FSC products based on a 50% threshold as of 01 April 2011, and therefore shall apply a labelling threshold of 70% from this date onwards.
“So what does this mean to me?” is a natural question that every FSC certified printer should be asking their CB if they don’t know already.
Let me put it in real-life terms most printers can understand. The majority of paper mills use the Credit System which effectively renders a product the equivalent of 100% certified. This advice note does not pertain to any inputs purchased from these mills or their merchants which are received with a claim of “FSC Mixed Credit”.
There are however a handful of paper mills using the Percentage System for calculating certified content for their products. Generally speaking, none historically have been consistently sold at a minimum 70% level, which necessitates conformance with this requirement in order to maintain the status quo for the next five years. (Most on the market today range between 50% and 60% certified material, sold for example as “FSC Mixed 50%”).
This “transitory” exemption allows for paper that contains at least 50% certified fiber (but less than 70%) to still be eligible for the FSC label up until January 1, 2016. The way the advice is worded in item 3 (above), you the printer are dependent on your supplier’s complete conformance. As long as your supplier either passes along the phrase “Registered” as part of the FSC Mixed XX% claim and/or; the product is received by you as an FSC labeled input; the product remains eligible for you to apply the FSC label. You may however have to provide evidence to your CB in order to gain labeling approval, which becomes another hoop to jump through.
Things to take into consideration are that first, there is a note within the advice note which states: “The exemption detailed in this advice is specifically related to the eligibility for labelling FSC products and not to the eligibility of producing or selling products with an FSC claim on invoices.” Therefore because not all merchants may apply for this exemption because it technically doesn’t affect them, the product could be rendered ineligible if sold by them without them registering and without an FSC label (FSC labels, even for paper in cartons, are an option, not a requirement).
The easier way is to register for the exemption with your CB. This is a one-time deal and should be a very simple process for most printers. The information required is to simply furnish your Product Group as defined on your Product Group Schedule for FSC Mixed Products (i.e.;FSC Mixed Printed Materials) on the form (which should have been) provided by your CB along with an X in the appropriate space denoting “Use of the labelling threshold of 50% until 31/12/2015” along with a few copies of invoices for said Product Groups that you have sold (i.e.;FSC Mixed Printed Materials).
Do it now and save yourself a headache in the future.