FSC-DIR-40-004 - FSC Directive On Chain of Custody Certification - 2024!04!30.cleaned

Directive
FSC-DIR-40-004 EN
30/04/2024
Page 1 of 67 FSC Directive on Chain of Custody Certification

FSC-DIR-40-004 EN
Title: FSC Directive on Chain of Custody Certification
Dates: Approval date: 30 April 2024
Timeframes: Transition period: not applicable

Period of validity: not applicable
Contact for FSC International – Performance and Standards Unit

comments: Adenauerallee 134
53113 Bonn
Germany
Phone: +49 (0)228 36766 0

Fax: +49 (0)228 36766 65
Email: [email protected]
Publication date: 30 April 2024
Version Description Date
V1-0 Not applicable Not applicable
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FSC-DIR-40-004 EN
FSC received various comments from certification bodies and stakeholders requesting a reduction in the
number of normative documents to make the documented certification system more comprehensible. FSC
therefore combined all previous advice notes into single documents which are called “directive”. A directive
includes all advice notes issued in relation to a single standard. The relation to a standard is reflected in
the document code. Where new advice note is approved, these will be added to the directive and the
revised document will be reissued.
The intention of this document is to standardize understanding and implementation of requirements by

FSC accredited certification bodies and certificate holders.
This document will be revised as required. The content of the directive will be incorporated into the related
standards in each major review as feasible.
Changes and amendments to the directive will be announced to the FSC Network immediately.
Note on use of this directive
All aspects of this document are considered to be normative, including the scope, effective date,
references, terms and definitions, tables and annexes, unless otherwise stated.

FSC-DIR-40-004 EN
Foreword 3
A. Scope 6
B. References 6
C. Terms and definitions 6
Part 1 General Issues 7
Part 2 FSC Advices 8
ADVICE 40-004-01 FSC certified CoC contractors
ADVICE 40-004-02 After the certificate issuance, when the company products will be eligible
to carry the FSC logo?
ADVICE 40-004-03 Reduced labelling threshold of 50% for chip and fibre based products
ADVICE 40-004-04 Use of uncontrolled co-products (Withdrawn)
ADVICE 40-004-05 Identification of FSC claims on sales and delivery documents
ADVICE 40-004-06 Which components of a product need to be certified?
ADVICE 40-004-07 Sale of FSC certified products through non-FSC certified auction entities
ADVICE 40-004-08 Non-conforming product
ADVICE 40-004-09 Minor components
ADVICE 40-004-10 Access to information required by timber legality legislations
ADVICE 40-004-11 Trade and customs laws
ADVICE 40-004-12 Pre-consumer reclaimed wood compliance with the EUTR
ADVICE 40-004-13 Classification of pre-consumer reclaimed paper as equivalent to FSC

certified and post-consumer reclaimed materials
ADVICE-40-004-14 Supply chain integrity
ADVICE-40-004-15 Neutral materials that cannot be distinguished from FSC certified

ingredients
ADVICE-40-004-16 Disassociated organizations operating as outsourcing contractors
ADVICE-40-004-17 Claiming 100% reclaimed products as FSC Mix

FSC-DIR-40-004 EN
ADVICE-40-004-18 Addressing deliberate false claims
V1-0
ADVICE-40-004-18 Addressing false FSC claims on products/projects containing material

V2-0 from unacceptable sources
ADVICE-40-004-19 Species information in FSC Product Groups (Withdrawn)
ADVICE-40-004-20 Confirmation of origin for FSC certified Paulownia products

V1-0
ADVICE-40-004-20 Confirmation of origin for FSC certified products from species of a

V2-0 particular risk to FSC´s integrity
ADVICE-40-004-21 Moratorium on sales of wood and wood products with FSC certified or FSC
Controlled Wood claims originating from sanitary logging from Irkutsk
Oblast region of Russia
ADVICE-40-004-23 Evaluation of contractors against the FSC core labour requirements
ADVICE-40-004-24 Evaluation of FSC core labour requirements using FSC approved

verification schemes
ADVICE-40-004-25 Requirements for the organization to provide information to the

certification body (CB) for Annual Administration Fee (AAF) calculation
ADVICE-40-004-27 Inclusion of the FSC CFM claim in the Chain of Custody Certification

FSC-DIR-40-004 EN
This document provides FSC’s formal interpretation of the requirements included in FSC-STD-40-004.
The following referenced documents are indispensable for the application of this document. For undated
references, the latest edition of the referenced document (including any amendments) applies:
FSC-STD-40-004 Standard for Chain of Custody Certification
FSC-STD-20-011 Chain of Custody Evaluations Standard
FSC-STD-40-005 Requirements for Sourcing FSC Controlled Wood Standard
FSC-PRO-01-001 Development and Revision of FSC Normative Documents

Procedure
For the purposes of this document, terms and definitions are provided in <FSC-STD-01-002 FSC
Glossary of Terms> and in <FSC-STD-40-004 Standard for Chain of Custody Certification>. Further
advice-related definitions may be provided in the context of each advice.
Advice Note: errata or addenda to normative documents.

Change request: a documented and justified request from any stakeholder for adding, deleting or
changing a requirement of an approved and valid FSC normative document.
Directives: compilations of Advice Notes.
Verbal forms for the expression of provisions:
[Adapted from ISO/IEC Directives Part 2: Rules for the structure and drafting of International Standards]
“shall”: indicates requirements strictly to be followed in order to conform with the standard.
“should”: indicates that among several possibilities one is recommended as particularly suitable,
without mentioning or excluding others, or that a certain course of action is preferred but not
necessarily required. A ‘should requirement’ can be met in an equivalent way provided this
can be demonstrated and justified.
“may”: indicates a course of action permissible within the limits of the document.
“can”: is used for statements of possibility and capability, whether material, physical or causal.

FSC-DIR-40-004 EN
1 The FSC Directive contains all advice notes related to a specific FSC international policy or
standard that are collected into a single document for improved accessibility for certification bodies,
certificate holders and other interested stakeholders. The FSC Directive provides clear advices on
the implementation of FSC's international policies and standards.
2 If a certification body is in doubt about the correct implementation of an FSC policy or standard,
the certification body must request clarification from the FSC Performance and Standards Unit. If
required, such clarification will be provided in the form of a new advice note or standard
interpretation.
3 Prior to the finalisation of an advice note, a certification body may make its own decision in relation
to a question for which clarification has been sought. In such a case, responsibility for the
consequences of the decision shall rest exclusively with the certification body concerned. Formal
advice note subsequently provided by the FSC International will be applicable retrospectively.
4 The advices provided in this document represent the formal position of the FSC International unless
and until it is superseded by the approval of a more recent policy, standard, or advice note. In such
cases the requirements specified in the more recent document shall take precedence.
5 Certification bodies are required to comply with the most recent formal advice notes, and the FSC
Accreditation Business Unit will base its evaluations and issue of corrective actions on these.
6 Finalised advice notes are approved by the Head of the Unit of the Performance and Standards
Unit or the FSC Director General. If a certification body wishes to contest the advice note provided
it may do so by requesting a formal review and decision by the FSC Policy and Standard
Committee. Until and unless such a review and decision has been finalised, the certification body
shall continue to comply with the position of the FSC International.
7 Directives are under continual review and may be revised or withdrawn in response to new
information, experience or changing circumstances, for example by the development of new
policies or standards approved by the FSC Board of Directors.

FSC-DIR-40-004 EN
ADVICE-40-004-01 FSC certified CoC contractors
Normative reference FSC-STD-40-004 V2-1 Section 12 and FSC-STD-40-004 V3-0

Section 12
Effective date FSC certified CoC organizations may apply this advice from
9th February 2010 and, if applicable, shall be assessed for
compliance from 1st January 2011 onwards. Amended in 08
September 2017.
Terms & definitions The terms defined in FSC-STD-20-011 and FSC-STD-40-004 apply.
The following terms are introduced by this Advice Note and are put in
italics throughout the document:
Contracting organization: Individual, company or other legal entity
contracting a contractor for the production or processing of an FSC
certified product under an outsourcing agreement.
NOTE: The contracting organization may or may not be an FSC
certified CoC organization. Part C of this Advice Note is structured
according to the FSC certified status of the contracting organization
(see Part C, Table 1).
Contractor: Individual, company or other legal entity contracted by a
contracting organization for the production or processing of an FSC
certified product under an outsourcing agreement.
NOTE: In the context of this Advice Note, the contractor is an FSC
certified organization (see Part C, Table 1).
FSC certified CoC organization: Individual, company or other legal
entity holding a valid FSC Chain of Custody certificate which confirms
that appropriate procedures are in place for the production, processing
or trade of a specific product – or that FSC certified CoC contractors
are used for this purpose – that allow the organization to sell, provide
or promote the product with FSC claims.
Outsourcing agreement: A written agreement between a contracting
organization and a contractor about the service of producing or
processing an FSC certified product or material, where the contracting
organization retains control of and responsibility for the purchasing of
input material from the (billing) supplier and for the sale of the output
product to the customer. Input material may be shipped from the
contracting organization or from the (delivering) supplier to the
contractor and the output product may be returned or shipped from
the contractor to the contracting organization or to the contracting
organization’s customer.
Supplier (billing): FSC certified CoC organization selling material with
FSC claims to the contracting organization.

FSC-DIR-40-004 EN
Supplier (delivering): FSC certified CoC organization delivering the
material to the contractor and selling the material with FSC claims to
the billing supplier or to the contracting organization.
Background This directive deals with the implications for FSC certified CoC
organizations, either functioning as or making use of FSC certified
CoC contractors. In particular, clarification is provided on the following
issues:
• under which conditions contract work for an FSC certified product
can be provided for non-FSC certified CoC contracting
organizations;
• what the benefits and implications are for FSC certified CoC
contracting organizations that use FSC certified CoC contractors.
The FSC Standard for Chain of Custody Certification (FSC-STD-40-
004) requires organizations that take legal ownership of materials and
want to maintain or change the FSC claim associated with the output
product to have FSC Chain of Custody certification. The standard
further specifies the requirements to follow for FSC certified CoC
contracting organizations in order to use non-FSC certified CoC
contractors for this purpose.
The questions, however, what the implications are for an FSC certified
CoC contracting organization to use FSC certified CoC contractors,
and whether contract work for an FSC certified product could be
provided also for non-FSC certified CoC contracting organizations
were not consistently dealt with in practice. In particular the latter
question required some fundamental judgement, as some certification
bodies considered contract work for non-FSC certified CoC
contracting organizations to be generally not in line with standard
requirements, while others found outsourcing arrangements where
the non-FSC certified CoC contracting organization would not obtain
physical possession of the input material to be acceptable under
certain additional stipulations.
This Advice Note follows the latter approach based on the judgement
that there would not be an increased risk associated with such
outsourcing arrangements for non-FSC certified products to be
labelled and sold as FSC certified, provided that additional
safeguards were in place. The Advice Note stipulates these
safeguards and aims at providing the relevant answers to the
questions raised above.
Advice
Table 1: Outsourcing scenarios dealt

FSC certified status
with by this Advice Note
Requirements Contracting
Section Details Contractor
for organization

FSC-DIR-40-004 EN
Providing contract
work for non-FSC
1 Contractor FSC non-FSC
certified CoC
organizations
Contracting Using FSC certified

2 FSC FSC
organization CoC contractors
1. Providing contract work for non-FSC certified CoC

organizations – conditions for FSC certified CoC
contractors
NOTE: This section applies for outsourcing
arrangements where the contractor is an FSC certified CoC
organization and the contracting organization is a non-FSC
certified CoC organization. Under this scenario, the contracting
organization cannot sell the product with an FSC claim to
commercial customers. The contracting organization may,
however, use the FSC trademarks to promote the product
towards final consumers as specified by FSC-STD-50-002.
This section 1 is applicable to organizations certified against
V2-1 and V3-0 of FSC-STD-40-004.
Eligibility
1.1 FSC certified CoC contractors are only eligible to provide FSC
certified products for non-FSC certified CoC contracting
organizations, if:
1.1.1 The input material for the contract work is shipped directly
from the delivering supplier(s) to the contractor, i.e. the
contracting organization does not obtain physical possession
of the input material.
1.1.2 The contractor is provided with a copy of the invoice(s) from
the delivering supplier(s) and, if not identical, from the billing
supplier(s) that include(s) information sufficient to link the
invoice(s) and related transport documentation to each other.
NOTE: Information on prices can be blacked out.
1.1.3 The output product provided by the contractor is:
a) a finished product;
b) FSC labelled; and
c) branded with the name, label or other identifying
information of the contracting organization.
Labelling
1.2 For each contract work, the contractor shall maintain control
of applying the correct FSC label.
1.3 The contractor shall ensure that its license code is used in the
FSC label and submits the proof to its certification body for
approval.

FSC-DIR-40-004 EN
2 Using FSC certified CoC contractors – conditions for FSC
certified CoC contracting organizations
NOTE: This section applies for outsourcing scenarios
where the both the contractor and the contracting organization
are FSC certified CoC organizations. Under this scenario, the
product does not have to be FSC labelled or a finished product.
This section 2 is only applicable to organizations certified
against V2-1 of FSC-STD-40-004.
Outsourcing agreement
2.1 The outsourcing agreement shall specify the following:
2.1.1 that the contractor provides the service under his FSC Chain
of Custody system,
2.1.2 that the contractor makes available relevant records and
documentation to the contracting organization’s certification
body upon request, and
2.1.3 that the contracting organization’s license code shall be used,
if the product shall be FSC labelled.
2.2 The outsourcing agreement and, if FSC certified CoC
contractors are used for specific processes exclusively, the
contracting organization’s control system for the outsourced
process do not need to cover the following requirements
stipulated by FSC-STD-40-004 V2-1:
– clauses 12.1.1 c), second sentence, and 12.1.1 d);
– clause 12.2.1;
– clauses 12.5.1, 12.6.1, and 12.7.1
NOTE: FSC certified CoC contractors may use their own
subcontractors in accordance with FSC-STD-40-004,
section 12.
Supplier validation
2.3 The contracting organization shall apply the provisions for
‘supplier validation’ as specified by FSC-STD-40-004 V2-1
also to the contractor.
Labelling
2.4 The contracting organization shall maintain control and
responsibility of the correct FSC label being applied, if product
labelling is part of the outsourced processing.
2.5 The contracting organization shall ensure that its license code
is used in the FSC label and shall submit the proof to its
certification body for approval.
Auditing
2.6 FSC certified CoC contractors are exempted from a potential
inspection by the contracting organization’s certification body,
if the outsourced process is covered by the scope of the
contractor’s certificate.

FSC-DIR-40-004 EN
NOTE: The contractor is subject to evaluation and monitoring by its
own certification body.
ADVICE-40-004-02 After the certificate issuance, when the company products will
be eligible to carry the FSC logo?
Normative reference FSC-STD-40-004 V2-0 Clause 10.1.1
Effective date March 2005
Background A forest product manufacture is often a continuous process. At the

time that a certificate is issued there are likely to be products
undergoing manufacture, products that have been manufactured but
not yet shipped, and products that have been shipped but not yet put
on sale by the buyer. Which of these products are eligible to carry
the FSC Logo?
Advice 1. The scope of the certificate defines the point at which the
certified chain of custody starts, and the point at which it
finishes. The chain of custody certificate provides a credible
guarantee of compliance with the requirements of the specified
standards between these points. This guarantee is valid from
the time that the certificate is issued. Any product which is
within the defined scope of the certificate at the time the
certificate is issued may be considered to comply with the
requirements of the applicable standard(s). Such products
may be eligible for sale as 'FSC-certified' products. Products
which have already left the scope of the certificate at the time
the certificate is issued cannot be considered to be certified.
2. Normally this will mean that products that have already been
sold, or shipped, prior to the issue of a certificate may not be
described as certified, and are not eligible to carry the FSC
Logo.
3. Clearly a company cannot issue an invoice describing
products as certified prior to the issue of chain of custody
certificate. Products sold without such an invoice cannot be
described as certified, and are not eligible to carry the FSC
Logo.
4. In the case of joint forest management and chain of custody
certification, application of this guideline means that timber that
had been felled prior to the issue of a certificate, but which has
not yet been sold by the forest management enterprise may be
sold as certified.
5. Equivalent considerations apply when a certificate is
withdrawn or expires. Products which left the chain of custody
whilst the certificate was valid were certified, and remain
certified even after the certificate has been withdrawn.

FSC-DIR-40-004 EN
Products which have not yet left the chain of custody at the
time the certificate is withdrawn will not be certified.
ADVICE-40-004-03 Reduced labelling threshold of 50% for chip and fibre based
products
Normative reference FSC-STD-40-004 V2-0 Clauses 11.2.1a and 11.2.2
Effective date 14 February 2011. Amended 09 December 2015 and 08 September

2017.
Terms & definitions Registered product: Chip and fibre product or product group
registered by the organization prior to 01 April 2011 as being
commercially produced based on a labelling threshold of 50%.
Output stock: products that had left the production process.
Background When the new Chain of Custody standard “FSC-STD-40-004 (Version

2): FSC Standard for Chain of Custody Certification” was approved in
November 2007, the following previously established exemption was
maintained by means of an Advice Note: A labeling threshold of 50%
for chip and fibre based products under a percentage or transfer
system.
This Advice was amended twice. The first amendment occurred in
December 2015 to incorporate the following decisions by the FSC
Board and the FSC Director General:
• An extension of the deadline of this Advice until FSC-STD-40-
004 V3-0 becomes effective, and
• A phase out rule for output stocks after the effective date of
FSC-STD-40-004 V3-0.
The second amendment occurred in 08 September 2017 to
incorporate the effective date of FSC-STD-40-004 V3-0.
Advice NOTE: In the context of this Advice, the term ‘organization’ refers only
to FSC certificate holders that have obtained the product registration
for the use of a reduced labelling threshold of 50%.
1. The organization may produce chip and fibre products based
on a reduced labelling threshold of 50% until 01 April 2017 (the
effective date of FSC-STD-40-004 V3-0).
2. Registered products are eligible to be FSC labeled and to be
sold with the “FSC Mix 50% registered” claim on sales and
delivery documents according to the requirements of this
Advice.
3. Registered products that were already FSC labeled before 01
April 2017 will keep their certified status after this date. Thus,
the organization and companies operating the transfer system

FSC-DIR-40-004 EN
further down in the supply chain may relabel and sell these
products with the “FSC Mix 50% registered” claim until their
stock is depleted.
4. The organization that has remaining output stock of unlabeled
registered products by 01 April 2017 may sell or label and sell
these products with the “FSC Mix 50% registered” claim for a
maximum of 6 months after this date.
5. The organization shall report to their certification body an
inventory of its unlabeled output stock of registered products
as of 01 April 2017 for the purpose of monitoring sales of
stocks in subsequent surveillance audits. The report shall be
sent to the certification body no later than01 July 2017.
ADVICE-40-004-04 Use of uncontrolled co-products
Status Withdrawn
ADVICE-40-004-05 Identification of FSC claims on sales and delivery documents
Normative reference FSC-STD-40-004 V2-0 Clause 6.1
Effective date 14 February 2011
Terms & definitions N/A
Background The FSC Chain of Custody standard requires certificate holders to

identify FSC certified products on sales and delivery documentation in
order to pass on the FSC claim of certified products to subsequent
customers. However, several organizations have limitations with
providing complete FSC claims that are required due to space
constraints in these documents.
Advice When the certificate holder has demonstrated it is not able to include
the required FSC claim as specified in the FSC Chain of Custody
standard in sales and delivery documents due to space constraints,
through an exception, the certification body can approve the required
information to be provided through supplementary evidence (e.g.
supplementary letters, a link to the own company’s webpage with
verifiable product information). This practice is only acceptable when
the certification body is satisfied that the supplementary method
proposed by the company complies with the following criteria:
a) There is no risk that the customer will misinterpret which
products are or are not FSC certified in the document;

FSC-DIR-40-004 EN
b) The sales and delivery documents contain visible and
understandable information so that the customer is aware that
the full FSC claim is provided through supplementary
evidence;
c) In cases where the sales and delivery documents contain
multiple products with different FSC Claims, a clear
identification for each product shall be included to cross-
reference it with the associated FSC claim provided in the
supplementary evidence.
ADVICE-40-004-06 Which components of a product need to be certified?
Normative reference FSC-STD-50-001 V1-2 Clause 2.4 and FSC-STD-40-004 V3-0 Box 2.
Effective date 30 March 2011. Amended in 08 September 2017.
Terms & definitions Inserts: Enclosed advertising in a periodical (e.g. newspaper,

magazine) that is distributed through the carrier publication and is a
clearly distinguishable element in relation to the other pages of the
periodical (e.g. different paper, size, etc.). For example, inserts may
take the form of return cards, coupons, recipe booklets, forms,
booklets, brochures, gift premiums, reply envelopes, etc.
Background Clause 2.4 of FSC-STD-50-001 V1-2 Requirements for the use of FSC
Trademarks by Certificate Holders establishes that “The FSC label
shall not be used to make a partial claim about a product. Where
permanent parts of the product (other than any packaging materials
or non-forest based materials) are not covered by FSC certification,
the FSC label shall not be used.”
FSC receives repeated inquiries from different stakeholders in relation
to which components of a product are considered to be “permanent“,
due to the fact that these products can contain several forest-based
elements that are included in the product with secondary functions
such as transportation, protection, etc. This advice aims to clarify
which of these components are required to be certified and provides
examples of practical implementation.
Advice All components of a product which are made of or contain material

originating from forests that are incorporated into the product to fulfil
its function for the consumers’ specific need shall be certified. It
represents that all certified components of a product shall comply with
the definition of eligible input (e.g. FSC 100%, FSC Controlled Wood,
etc.) and its quantities in volume or weight shall count towards the
calculation of FSC product composition determining its eligibility to
carry the FSC label.
Forest-based components that have secondary functions in the
product (e.g. for transportation, protection, etc.) don’t need to be

FSC-DIR-40-004 EN
certified unless they are added to the product with a functional
purpose (e.g. If the product will have its function compromised by the
removal of this secondary component, then this component also
needs to be certified).
Packaging that is made from forest-based inputs (e.g. paper, wood,
etc.) is considered a separate element from the product inside.
Therefore, the organization can choose to certify only the packaging
or its content individually, or both.
The FSC label generator allows the creation of labels with specific
product type claims (e.g. wood, paper, packaging). Thus, in cases
where, the product contains wood and paper components that are
clearly separate elements, the organization can opt to certify them
independently, provided that the appropriate product type claims are
applied on the FSC label. To avoid risks of misinterpretation in relation
to which components of the product are certified, an additional
clarification statement is recomended. The same applies to products
that contain a combination of wood-based components (wood, paper)
and NTFPs (e.g. rattan, cork). In this case, the wood-based
components shall be certified and the NTFPs may be uncertified
provided that FSC label cleary indicate the FSC-certified wood-based
components of the product (e.g. a woden chair made of FSC-certified
wood and non certified rattan. In this case, the FSC label shall indicate
the product type wood). The opposite situation is not possible (a
woden chair where only the NTFP is certified but not the wood).
The table below provides some examples of practical application of
this advice and it is not expected to cover all range of FSC certified
products:
Examples Which components of a product need to be

of certified?
products
Matches Yes
Box Optional
Rationale: Matches and matchbox are

Matches &
distinguishable components that can be certified
Matchbox independently when the FSC label claim is sufficiently
clear to avoid misinterpretations. However, when the
matches and matchbox are made with the same
material (e.g. paper), both shall be certified in order to
carry the FSC label.
Games Paper and wood components Yes
Instructions manual Optional

FSC-DIR-40-004 EN
Packaging Optional
Rationale: The wood and paper components of the

game have a functional purpose and therefore are the
components that require certification. However, a
more flexible approach is also possible with the
condition that the proper label statement is applied.
For example, when only the wood components are
certified, the FSC label shall contain the claim “wood”
and the paper components don’t need to be certified.
On the other hand, when only the paper components
are certified, the FSC label shall contain the claim
“paper” and the wood components don’t need to be
certified. The instructions manual and packaging are
not product components and for this reason don’t
need to be certified.
Cover Yes
Internal paper Yes
Dust jacket and slip cases Optional
Wraparound band Optional

Books
Rationale: The cover and internal paper are needed
for the accomplishment of the product’s function, and
for this reason shall be certified. Additional items such
as dust jackets, slip cases and wraparound band are
not necessary for the acomplishment of the product’s
funtion and therefore don’t need to be certified.
Cover Yes
Adhesive paper sheets Yes
Internal paper Yes

Notebooks
Rationale: Notebook cover, internal paper, adhesive
paper sheets are permanent product components and
are needed for the accomplishment of the product’s
function. Therefore, all these components shall be
certified.
Cover Yes
Internal Paper Yes

Magazines
Inserts Optional
Detachable promotional stickers Optional

FSC-DIR-40-004 EN
Rationale: Magazine cover and its internal paper are
needed for the accomplishment of the product’s
function and therefore shall be certified. Inserts and
detachable promotional stickers are not needed for
the accomplishment of the product’s function and
therefore, independently of the fixation method
(bounded, glued, loose, etc.), don’t need to be
certified.
Toilet paper Yes
Cardboard roll Optional
Rationale: The toilet paper is the component seeked

by the consumer to fulfil its specific need. The
Toilet cardboard roll is a method of dispensing or
Paper transporting the paper and can be separated from the
product without compromising its function. For this
reason, the cardboard roll does not need to be
certified. The same rationale applies for all paper
products sold in rolls and bobbins (e.g. paper bobbins,
rolled thermal paper, paper towels).
Tissues Yes
Box Optional
Boxes of Rationale: The tissue paper is the component seeked

Tissues by the consumer to fulfil its specific need. The box is
a method of dispensing or transporting the paper and
can be separated from the product without
compromising its function. For this reason, the box
doesn‘t need to be certified.
Furniture Yes
Packaging Optional
Price tag or promotional label Optional
Furniture Rationale: The furniture is the component seeked by

the consumer to fulfil its specific need. The packaging,
price tag and promotional label have secondary
functions in the product and can be separated from
the furniture without compromising its function. For
this reason, the packaging and price tag or
promotional label doesn‘t need to be certified.
Stickers Yes
Release paper Optional

FSC-DIR-40-004 EN
Adhesive Rationale: The sticker is the product seeked by the
Labels in consumer and the release paper has a secondary
Sheets function (transporting the product). Therefore, the
release paper doesn’t need to be certified.
Pre- Permanent structural components of Yes

fabricated the house, including flooring, roof,
houses walls, stairs, windows and doors.
(or entire
Other secondary wood elements (e.g. Optional
houses
furniture, cabinets, toilet seats, shelves,
sold as an
fences, wall paper).
unit)
Rationale: A house sold as a unit can be claimed as
an FSC certified product if all permanent structural
components made with forest-based materials that
are added to the house to fulfil the specific consumer’s
need (a place to live in) are certified. Other secondary
wood elements (e.g. furniture, cabinets, toilet seats,
shelves, fences, wall paper) are not permanent
components of the house. Therefore, they don’t need
to be certified. Houses made with non-forest based
materials (e.g. bricks) that have specific wooden
components (e.g. doors, flooring) incorporated cannot
be claimed as an FSC certified house. However, the
organization can label and promote these
components individually; identifying the FSC certified
elements to the consumers.
Wood Wood Yes

flooring
with paper Paper or veneer inlays Yes
or veneer
inlays Rationale: The wood and paper/veneer inlays are not
distinguishable elements by consumers and cannot
be separated without compromising the products
function. Therefore, both the wood and paper or
veneer inlays shall be certified in order to claim the
flooring as a FSC certified product.
ADVICE-40-004-07 Sale of FSC certified products through non-FSC certified

auction entities
Normative reference FSC-STD-40-004 V2-1 Scope and Clause 6.1.1 and FSC-STD-40-
004 V3-0 Clause 5.1
Effective date 30 March 2011. Amended in 08 September 2017.

FSC-DIR-40-004 EN
Terms & definitions Auction: A process of buying and selling goods or services by offering
them up for bid, taking bids, and then selling to the winning (generally
highest) bidder. The auction house, auctioneer, log market, etc.,
managing the auction does not gain legal ownership of the
goods/services for sale but does collect the funds due and issues the
sales invoice to the winning bidder.
Background This advice aims to provide clarification on whether or not auction

houses, log markets or other related entities need to be certified. If
so, define the required procedures in order to ensure the traceability
of the products traded by these organizations.
FSC-STD-40-004 establishes that Chain of Custody certification is
required for all organizations that want to
 produce and sell FSC-certified materials or products; or
 produce and promote FSC-certified products; or
 trade materials or products with FSC claims.
NOTE: Chain of Custody certification is not required for
organizations that do not gain legal ownership of such materials or
products but simply arrange for buyer and seller:
a) to make a deal without taking physical possession (often called
an ‘agent’); or
b) to transport the materials or products.
Advice Auctioning entities that do not gain legal ownership of FSC certified
products during trading activities are not required to be FSC chain of
custody certified, even when the auctioning entity takes physical
possession of the product.
Non-certified entities are not permitted to include FSC claims or
certification codes on their own sales or transport documents.
In order for the customer (winning bidder) to consider material
purchased through a non-FSC certified auction entity as FSC certified,
a supplementary letter or transport document must be provided by the
certified supplier to the customer including all information required by
FSC-STD-40-004 V2-1, 6.1.1. or FSC-STD-40-004 V3-0, 5.1.
ADVICE-40-004-08 Non-conforming product
Normative reference FSC-STD-40-004 V2-1 Clauses 1.2.1 and 10.1.1
Effective date 01 November 2012

Amended 27 February 2013

FSC-DIR-40-004 EN
Terms & definitions Non-conforming product: Product or material for which an organization
is unable to demonstrate that it complies with FSC eligibility
requirements for making claims and/ or for using the FSC on-product
labels.
Small COC enterprises: Organizations with:
i. No more than 15 employees (full time equivalent), or
ii. No more than 25 employees (full time equivalent) and a
maximum total annual turnover of US$ 1,000,000.
Background Implementation of Chain of Custody procedures and control systems
as required by FSC-STD-40-004 aim to ensure that non-conforming
products do not occur. This advice introduces an additional safeguard
to prevent non-certified products from being delivered as certified, by
requiring that procedures are put in place to handle non-conforming
products.
Specific requirements are included to apply to cases where non-
conforming products are detected after they have been supplied to a
customer.
The action taken to address the issue of non-conforming product is
targeted to the organization that is responsible for the nonconformity,
but it may also affect onward buyers and sellers e.g. in the event that
a product is re-called.
Advice 1. The organization shall have a documented procedure

defining the controls and related responsibilities and
authorities for dealing with non-conforming products. The
organization’s chain of custody system shall be designed to
ensure that products which do not conform to FSC
requirements are identified and controlled to prevent its
unintended delivery.
NOTE: Small COC enterprises are not required to have the

procedure in writing.
2. In case non-conforming products are detected after they have
been delivered, the organization shall:
a) immediately cease to sell any non-conforming products
held in
stock;
b) identify all relevant customers, and advise those
customers in writing within three (3) business days of the
non-conforming product and maintain records of that
advice;
c) analyse causes for occurrence of non-conforming
products and implement measures to prevent its re-
occurrence.
d) notify their certification body;
e) cooperate with the certification body in order to allow the

FSC-DIR-40-004 EN
certification body to confirm that appropriate action is
taken to
correct this non-compliance.
ADVICE-40-004-09 Minor components
Normative reference FSC-STD-40-004 V2-1 Clause 6.1.3 and Section 13

Background Minor components were first introduced to the FSC system in 2007.
They are forest based materials (timber and non-timber forest
materials) that can be exempted from the requirements for Chain of
Custody control, according to the requirements of FSC-STD-40-004
V2-1.
In early 2012, following a mandate of the FSC Board of Directors, FSC
initiated an updating process of its standards to ensure harmonization
with timber legality legislations, such as the EU Timber Regulation
(EUTR), US Lacey Act, FLEGT and the Australian Illegal Logging
Prohibition Act. As a consequence of this process, FSC identified the
need to phase out the exemption for minor components.
Advice 1. From 01 January 2013 onwards, Clause 6.1.3 of FSC-STD-40-

004V2-1 will also apply to organizations selling semi-finished
products containing minor components below 1% of the product
composition. The following claim shall be provided to customers:
“This product contains “x” of minor components”, where “x” is the
quantity in volume, weight or percentage of minor components.
2. From 01 March 2013, uncertified and uncontrolled minor

components shall no longer be used in products and commercial
activities (such as import, export, placing on the market,
processing, etc.) in countries where timber legality legislation
applies and where these products and activities are included in
the scope of the legislation (including any official interpretation
and guidance). From this date onwards, these minor
components shall be made of FSC certified or FSC Controlled
Wood materials.
3. After 31 December 2013 and applying worldwide, the production

of FSC products containing uncertified and uncontrolled minor
components is no longer allowed.
4. After 31 December 2014 and applying worldwide, the sale of

FSC products containing uncertified and uncontrolled minor
components is no longer allowed.

FSC-DIR-40-004 EN
ADVICE-40-004-10 Access to information required by timber legality legislations
Normative reference FSC-STD-40-004 V2-1 Clauses 1.4 and 2.1.1

Background In early 2012, following a mandate of the FSC Board of Directors, FSC
with the EU Timber Regulation (EUTR) and other timber legality
legislations such as the US Lacey Act, FLEGT and the Australian
Illegal Logging Prohibition Act. This process includes adjustments in
the FSC COC requirements to ensure that FSC certified products
comply with legally required information regarding species, origin of
timber and timber products and compliance with trade and custom
laws which include, but may not be restricted to:
• Bans, quotas and other restrictions on the export of timber
products (e.g. bans on the export of unprocessed logs or
rough-sawn lumber)
• Requirements for export licences for timber and timber
products
• Official authorisation that entities exporting timber and timber
products may require
• Taxes and duties applying to timber product exports
Advice 1. Upon request, FSC certified suppliers shall provide customers

with the following information about FSC certified and FSC
Controlled Wood timber or timber products subject to compliance
with applicable timber legality legislations:
a) Common name and/or scientific name of timber species as
required by the applicable legislation;
NOTE: This requirement takes precedence over Clause 2.1.1 c)
of FSC-STD-40-004 V2-1.
b) Origin of timber (countries of harvest and where applicable,
sub-national regions and concessions of harvest);
NOTE: Information on the sub-national regions or concessions of
harvest shall be provided where the risk of illegal harvesting
between concessions of harvest in a country or sub-national
region varies. Any arrangement conferring the right to harvest
timber in a defined area shall be considered a concession of
harvest.
c) Proof of compliance with relevant trade and customs laws.
2. FSC certified suppliers shall provide timely responses to the
information requests specified in Clause 1 above.

FSC-DIR-40-004 EN
3. The form and frequency of providing this information may be
agreed between FSC certified supplier and customer, as long as
the information is accurate and can be correctly associated with
each material supplied as FSC certified or FSC Controlled Wood.
4. In case the FSC certified supplier does not possess the requested
information specified in Clause 1 above, the request shall be
passed on to the upstream FSC certified suppliers, until the
requested information can be obtained.
ADVICE-40-004-11 Trade and customs laws
Normative reference FSC-STD-40-004 V2-1Clause 1.2 and FSC-STD-40-004 V3-0 Clause

6.1
Effective date 27 February 2013. Amended in 08 September 2017.

In early 2012, following a mandate of the FSC Board of Directors, FSC
Background
with the EU Timber Regulation (EUTR) and other timber legality
legislations such as the US Lacey Act, FLEGT and the Australian
Illegal Logging Prohibition Act. This process includes adjustments in
the FSC COC requirements to ensure that FSC certified products
comply with applicable trade and custom laws which include, but may
not be restricted to:
• Bans, quotas and other restrictions on the export of timber
products (e.g. bans on the export of unprocessed logs or rough-
sawn lumber)
• Requirements for export licences for timber and timber products
• Official authorisation that entities exporting timber and timber
products may require
• Taxes and duties applying to timber product exports.
FSC certificate holders exporting and/or importing timber or timber
Advice
products shall have procedures in place to ensure that the
commercialization of FSC certified and FSC Controlled Wood
products comply with all applicable trade and customs laws.
ADVICE-40-004-12 Pre-consumer reclaimed wood compliance with the EUTR
Normative reference FSC-STD-40-004 V2-1 Clause 3.3.1
Effective date 01 October 2014.
Terms & definitions Pre-consumer reclaimed material: Material that is reclaimed from a
process of secondary manufacture or further downstream industry, in
which the material has not been intentionally produced, is unfit for end

FSC-DIR-40-004 EN
use and is not capable of being re-used on-site in the same
manufacturing process that generated it.
Europe: in the context of this Advice, this refers to the European
countries that fall within the scope of EU Regulation No 995/2010
(known as “EU Timber Regulation”).
Background In 2012, following a mandate from the FSC Board of Directors, FSC
initiated a revision process of its standards to ensure harmonization
with the EU Timber Regulation (EUTR). According to the EUTR,
reclaimed wood such as sawdust and chips are not classified as
waste, and are therefore subject to compliance with the regulation.
Paper scraps are currently excluded from the scope of the EUTR. As
a result of this revision, FSC identified the need to introduce
requirements for the control of pre-consumer reclaimed wood in order
to ensure FSC certified products comply with the EUTR, for products
placed on the European market.
Advice 1 FSC certificate holders placing FSC certified products

containing pre-consumer reclaimed wood material (except
paper scraps) on the European market for the first time shall
exercise due diligence to ensure that these materials do not
contain illegally harvested timber according to EU Regulation
No 995/2010.
2 FSC certificate holders located in countries outside of Europe
and exporting FSC certified products that contain pre-
consumer reclaimed wood material to companies in Europe
shall either:
a) Inform their customers about the presence of pre-
consumer reclaimed wood material in the product before
its delivery and commit to support their customers in
applying their due diligence system, as required by the
EUTR, or;
b) Ensure that pre-consumer reclaimed wood (except paper
scraps) used in the manufacturing of FSC certified
products is FSC Controlled Wood, according to FSC-STD-
40-005 requirements.
3 FSC certificate holders applying option 2 b) above, may apply
the requirements for co-products outlined in the ADVICE-40-
005-17, to demonstrate the district of origin of pre-consumer
reclaimed wood and the ADVICE-40-005-20 for the risk
assessment of pre-consumer reclaimed wood.
ADVICE-40-004-13 Classification of pre-consumer reclaimed paper as equivalent to

FSC certified and post-consumer reclaimed materials
Normative reference FSC-STD-40-004 V2-1 Clauses 8.2.1, 8.3.1, 9.2.1, 9.3.1 and Footnote
4

FSC-DIR-40-004 EN
Effective date 07 October 2015
Background At the FSC General Assembly in 2011, the FSC membership

mandated FSC to conduct a chamber-balanced study to evaluate the
risks and benefits of valuing pre-consumer reclaimed paper fibre
materials as FSC certified content (Motion 38). The results of the study
and consultation feedback demonstrated the FSC membership
support to the proposal.
At its 66th meeting in July 2014 the FSC Board approved the proposal
to classify pre-consumer reclaimed paper to count as equivalent to
FSC certified and post-consumer reclaimed materials for the purpose
of percentage and credit claims calculations. PSU was instructed to
implement this decision through the incorporation into the revision
process of FSC-STD-40-004. As this revision is delayed the Board
approved this Advice Note to bring the decision forward and to allow
companies to start applying it. This Advice Note will be withdrawn at
the effective date of FSC-STD-40-004 V3-0.
Advice FSC CoC certificate holders may classify pre-consumer reclaimed

paper materials as equivalent to FSC certified and post-consumer
reclaimed materials for the purpose of determining the FSC Mix or
FSC Recycled output claims for products controlled under the
percentage or credit system.
ADVICE-40-004-14 Supply chain integrity
Normative reference This advice notes applies to all certificate holders that are certified
against FSC-STD-40-004 V2-1 and FSC-STD-40-004 V3-0.
Effective date 08 September 2017.
Terms & definitions FSC Transaction: Purchase or sale of products with FSC claims on
sales documents.
Fibre Testing: a suite of wood identification technologies used to
identify the family, genus, species and origin of solid wood and fibre
based products.
Background The FSC Board of Directors has approved in November 2016 the
revised versions of the FSC-STD-40-004 (V3-0), FSC-STD-20-011
(V4-0) and additionally a set of actions for ensuring supply chain
integrity and addressing false claims in the FSC system. This advice
note presents the requirements that apply to all certificate holders
during the transition period between V2-1 and V3-0 of FSC-STD-40-
004.

FSC-DIR-40-004 EN
Advice 1. The organization shall support transaction verification conducted
by its certification body and ASI, by providing samples of FSC
transaction data as requested by the certification body.
NOTE: Pricing information is not within the scope of transaction
verification data disclosure.
2. The organization shall support fibre testing conducted by its
certification body and ASI, by upon request surrendering samples
and specimens of materials and products, and information about
species composition for verification.
ADVICE-40-004-15 Neutral materials that cannot be distinguished from FSC

certified ingredients
Effective date 08 September 2017. Amended in 30 January 2018.
Background The FSC Board has approved in its 74th Meeting in February 2017 the
inclusion of a new requirement in the FSC Chain of Custody normative
framework to address the problem of misleading claims on FSC
products that contain neutral materials that cannot be distinguished
from FSC certified input materials. Some examples of these products
are:
- Paper made of a combination of forest (virgin or reclaimed) and
agricultural fibres (cotton, sugar cane);
- Tires made of a combination of natural and synthetic rubber;
- Briquettes made of a combination of forest and agricultural
residues;
- Textiles made of a combination of wood and other organic
fibres (cotton).
The absence of requirements to regulate such products was posing a
potential risk for the FSC credibility, since consumers may perceive
claims made on these FSC products as misleading (e.g. a paper that
is 95% made of cotton and 5% FSC certified being labelled as FSC
100%).
After the publication of this advice note, FSC received stakeholder
feedback about anticipated negative impacts of the requirement
regarding the specification of the certified ingredient(s) on the FSC
label. In order to further evaluate these impacts and potential
solutions, FSC decided to suspend this requirement until FSC has
completed the evaluation of the requirement and provided a final
decision about its implementation.
Advice FSC certified products that contain neutral materials that cannot be
distinguished from FSC certified ingredients and may be
misinterpreted as being FSC-certified (e.g. non-certified agricultural

FSC-DIR-40-004 EN
materials such as cotton fibre used in FSC certified paper, synthetic
rubber used in combination with natural rubber in the production of
tires) shall only be labelled and claimed as FSC Mix.
NOTE: This advice note does not apply to inorganic materials that
have a different function in the product in relation to the certified
ingredient (e.g. glass, plastic, metal) or to products where the FSC
certified ingredient is distinguishable from other ingredients (e.g.
cosmetics containing FSC certified plant extract that is clearly
specified to consumers).
ADVICE-40-004-16 Disassociated organizations operating as outsourcing

contractors
Normative reference FSC-STD-40-004 V3-0 Clause 12.4 e)
Effective date 08 September 2017.
Background The FSC-STD-40-004 V3-0 that has been published on the 01

January 2017 introduced a new requirement about outsourcing
contracts, which specifies that contractors shall notify certificate
holders within 10 business days if they have been included in the list
of organizations that are disassociated from FSC. FSC received
considerable negative feedback on this requirement, mainly related to
the considerable impact on existing contracts to address an unclear
risk for the system integrity. Based on this, FSC decided to re-evaluate
the impacts and relevance of this requirement, and consequently
delay its implementation until a final decision has been taken.
Advice Organizations are not required to include the provisions specified in

Clause 12.4 e) in their outsourcing contracts until FSC has completed
the evaluation of the requirement and provided a final decision about
its implementation.
NOTE: Once this decision has been taken, this advice will be updated
accordingly.
ADVICE-40-004-17 Claiming 100% reclaimed products as FSC Mix
Effective date 30 January 2018.
Background FSC-STD-40-004 V3-0 that has been published on 01 January 2017

specifies that products that are 100% made of reclaimed materials
shall only be claimed as FSC Recycled and cannot be claimed as FSC
Mix. FSC was informed about significant negative implications of this
requirement for some certificate holders. Based on this input, FSC
decided to re-evaluate the impacts and relevance of this requirement,

FSC-DIR-40-004 EN
and consequently to delay its implementation until a final decision has
been taken.
Advice Organizations are allowed to claim products that are 100% made of
reclaimed materials as FSC Mix until FSC has completed the
evaluation of the requirement and provided a final decision about its
implementation.
NOTE: Once this decision has been taken in late March 2018, this
advice will be updated accordingly.
ADVICE-40-004-18 Addressing deliberate false claims

V1-0
Normative reference FSC-STD-20-001, Clauses 1.2.3 i) & 14.5 b)

FSC-STD-20-007, Clause 8.1
FSC-STD-20-011 V4-1, Clauses 4.1; 7.4 and 9.1
FSC-STD-20-012, Clauses 7.1 & 4.5
FSC-STD-40-003 V2-1 Clause 5.1.2, FSC-STD-30-010, Clauses 1.5
& 1.6
FSC-STD-40-004 V3-0 Clauses 1.1, 2.3 and 12.3
Effective date 06 April 2020; amended on 25 October 2021 (See ADVICE-40-

004_18 V2-0)
Effective from 06 April 2020 until 31 December 2021
Scope This Advice Note applies to certification bodies and certificate holders
and specifies the actions that shall be taken when false claims are
identified.
In addition, it provides measures for certificate holders to ensure that
they do not inadvertently enter into a business relationship with a
blocked organization when they outsource services or want to add a
new group member or a participating site.
Terms and Blocked organization: A certificate holder or a former certificate

definitions holder that is blocked from the FSC Certification Scheme in response
to false claims by:
(1) the suspension of the Granted Rights, alternatively the termination
of the License Agreement for the FSC Certification Scheme, and
(2) the restriction from carrying out processes or activities that are
included within the scope of their FSC certification.
Clear and convincing evidence: Evidence available to the
certification body, ASI and/or FSC that supports a conclusion that a
fact is substantially more probable to be true than not. In other words,
there must be a firm conviction or belief that the organization

FSC-DIR-40-004 EN
deliberately made false claims. Clear and convincing evidence shall
be supported by documents, facts, other information or records, either
quantitative or qualitative, that can be verified through analysis,
observation, measurement, and other means of research (See
Graphic 1).
Graphic 1. Standards of certainty on a probability scale
Contractor: Individual, company, or other legal entity contracted by

an organization for any activities under the scope of an FSC COC
certificate.
Deliberate: with knowledge and awareness of the consequences.
False claim: FSC claim made on sales documents (physical or
electronic) or the use of the FSC trademarks, on products and for
projects that are not eligible to be claimed, labelled and/or promoted
as being FSC-certified or FSC Controlled Wood. A false claim is
different from an inaccurate claim, in which a product, that is eligible
to be sold as FSC certified, is sold with the wrong claim.
NOTE: An incident with a false claim is linked to a root cause and
multiple incidents of false claims may originate from the same root
cause. In all such cases, these instances of false claims (which would
normally trigger a single non-conformity in an assessment) count as
one false claim event for the purpose of this Advice Note.
FSC database: A computer-based system containing data about the
FSC Certification Scheme (e.g. certificate holders, FSC licensees,
etc.), accessible at www.info.fsc.org.
Granted Rights: The right to use the FSC trademarks for FSC claims,
as defined in FSC-STD-40-004, for on-product labeling on FSC-
certified products and for promotional use worldwide as licensed and
further regulated by via the FSC Trademark License Agreement.
Negligence: Failure to exercise reasonable care.
FSC Trademark License Agreement: The License Agreement for
the FSC Certification Scheme signed by the certificate holder
permitting use of the FSC trademarks (‘licensed materials’).

FSC-DIR-40-004 EN
In November 2016, the FSC Board of Directors approved the revised
Background
versions of FSC-STD-40-004 (V3-0), FSC-STD-20-011 (V4-0) and an
additional set of actions for ensuring supply chain integrity and
addressing false claims in the FSC system. Therefore, this Advice
Note aims to clarify the actions that shall be taken by:
a) Certification bodies when false claims are identified (see
Graphic 2);
b) blocked organizations and how they can reinstate and
reestablish processes or activities in the scope of their
certificate;
c) Certificate holders with a valid COC certificate outsourcing
services or adding a new group member or site to prevent a
business relationship with blocked organizations;
d) FSC and ASI when false claims are identified (see Graphic 2).
Advice 1. Identification of false claims
1.1 Any false claim identified by a certification body shall be registered
in the FSC database for further investigation by FSC and/or ASI.
1.2 FSC independently and/or jointly with ASI may identify and
investigate false claims.
2. Response to false claims
2.1 In the event that (i) the investigation conducted by FSC and/or ASI
reveals that there is clear and convincing evidence that the
certificate holder deliberately made a false claim or (ii) the
certificate holder has made more than two (2) false claims with
negligence within a five (5) year period:
2.1.1 FSC will:
a) Suspend the Granted Rights held by the certificate holder
according to the FSC Trademark License Agreement or
terminate the FSC Trademark License Agreement, whichever
is most appropriate;
b) block the certificate holder from the FSC Certification Scheme;
and
c) inform the responsible certification body about the results of
the investigation.
2.1.2 The certification body shall:
a) suspend or terminate the FSC COC, CW/FM, FM or
FM/COC certification of the blocked organization;
b) update the FSC database to indicate the blocked
organization’s status as 'Suspended and Blocked' or
'Terminated and Blocked' (Clause 1.4.7 of FSC-STD-20-001
V4.0); and
c) inform the blocked organization (Clause 1.4.8 of FSC-STD-20-
001 V4.0).
NOTE 1: Clause 2.1 does not apply to certificate holders where

they have received or unintentionally passed on false claims. In
such a scenario Clause 1.6 of FSC-STD-40-004 applies.
NOTE 2: In the case of identified risks to the integrity of the FSC

system, FSC may also require the blocked organization to

FSC-DIR-40-004 EN
participate in transaction verification activities and/or participate in
the FSC wood identification programme.
NOTE 3: If a false claim is made by a group member or

participating site then this Advice Note applies to that specific
group member or participating site and not to the Central Office.
However, if false claims are made by multiple group members or
participating sites then this Advice Note applies to each individual
member/site who made the false claim. In addition, the
requirements of FSC-STD-40-003 (Clause 4.2, and Annex 2 –
Clause 1.2 and Clause 2) also apply.
2.2 Certification bodies shall not issue, reissue, transfer or reinstate
the certification of blocked organizations while they have the
status “Suspended and Blocked” or “Terminated and Blocked” in
the FSC database.
3. Consequences for Blocked organizations
3.1 The blocked organization, which made a false claim or false
claims, shall be blocked for the period of six (6) to sixty (60)
months. The duration of the blockage is linked to the amount of
the compensation fee as specified in FSC-PRO-10-003.
3.2 For the duration of the blockage, the blocked organization shall
not carry out any processes or activities that are included within
the scope of their FSC certification (e.g. trading, processing,
manufacture, labelling, storage, and/or transport). For example,
selling FSC-certified products with FSC claims or labelling
products as FSC certified.
3.3 The blocked organization shall fulfill the conditions specified in this
Advice Note, in the FSC Normative Framework, including, but not
limited to FSC-PRO-10-003 and further instructions during the
duration of blockage.
3.4 Organizations outsourcing services or adding a new group
member or participating site
3.4.1 The blocked organization may not be a member of a Group
or Multi-site COC certification and/or may not act as a
contractor for other certificate holders with valid FSC
certification.
3.4.2 Certificate holders with valid FSC certification shall verify if
another organization is blocked in the FSC database and
consider the blocked organization ineligible for any of the
following activities:
a) outsourcing services related to FSC certified material
and/or;
b) adding a new group member to the Group COC
certification and/or;
c) adding a participating site to the Multi-site COC
certification.
3.5 Certification bodies adding sites or members and verifying
outsourcing agreements

FSC-DIR-40-004 EN
3.5.1 In the case of a Group or Multi-site COC certification, the
certification body shall verify the certificate holder’s status
in the FSC database before adding new sites to registered
certificates and shall restrict blocked organizations as a site
or member to a COC certificate.
3.5.2 In the case of outsourcing agreements, the certification
body shall verify the blocked list shared by FSC and shall
restrict blocked organizations to act as a contractor.
4. Lifting the blockage
4.1 The blocked organization can have the status “Suspended and
Blocked” or “Terminated and Blocked” revoked before the end of
the duration of the blockage if it is confirmed that the blocked
organization has fulfilled the following requirements:
a) by the certification body: implementation of corrective and
preventive actions, and the application of requirements for
non-conforming products (as specified in clause 1.6 of FSC-
STD-40-004) and other applicable conditions established by
FSC to remedy the shortcomings; and
b) by FSC: payment of the compensation fee in accordance
with FSC-PRO-10-003.
4.2 FSC will issue an invoice for the payment of the compensation
fee within two (2) weeks after receiving a request from the
blocked organization.
4.3 If a blocked organization's status is 'Suspended and Blocked,'
and the suspension period has exceeded twelve (12) months or
in exceptional cases, up to eighteen (18) months (FSC-STD-20-
001, Clause 4.7.5) and the blocked organization has not
implemented the measures specified in Clause 4.1, the
certification body shall terminate the blocked organization’s
certificate and the status of the blocked organization shall be
updated to “Terminated and Blocked”.
5. Contesting a blocked status and financial
penalty/compensation fee
5.1 The organization which has been blocked according to Clause
2.1.1 may submit evidence to contest the blockage decision made
by FSC as specified in FSC-PRO-10-003.
Graphic 2. Process flowchart when false claims identified by Certification bodies and FSC and/or ASI.

FSC-DIR-40-004 EN
ADVICE-40-004- Addressing false FSC claims on products/projects containing
18 (V2-0) material from unacceptable sources
Normative FSC-PRO-10-003 V1-1

references
FSC-STD-20-001, Clauses 1.2.3 i) & 1.4.5 b)
FSC-STD-20-007, Clause 8.1
FSC-STD-20-011 V4-1, Clauses 4.1, 7.4 and 9.1
FSC-STD-20-012, Clauses 7.1 & 4.5
FSC-STD-30-010, Clauses 1.5 & 1.6
FSC-STD-40-003 V2-1 Clause 5.1.2
FSC-STD-40-004 V3-1 Clauses 1.1, 1.8, 2.3 and 13.3
Approval date 06 April 2020; amendment 25 October 2021

FSC-DIR-40-004 EN
Effective date From 01 January 2022 until withdrawn
Scope This Advice Note addresses situations where ineligible input is used in
products and projects claimed, labelled and/or promoted as FSC
certified or FSC Controlled Wood.
The Advice Note primarily applies to certified organizations who have
generated such a false claim and specifies the actions for them, their
certification bodies (CBs), as well as for Assurance Services
International (ASI) and FSC to address these false claims.
It further applies to organizations adding new group members/sites and
certificate holders/organizations outsourcing services - to prevent them
from developing business relations with organizations who generated
false claims and have been blocked from the FSC system.
This Advice Note does not apply to situations where organizations have
generated inaccurate claims. The applicable requirements of the Chain
of Custody Certification FSC-STD-40-004 standard shall continue to be
used to regulate inaccurate claims.
Terms and Blocked Organization: A certificate holder or a former certificate

definitions holder that is blocked from the FSC Certification Scheme in response to
False Claims by:
i. the suspension of the Granted Rights to use the FSC
trademarks, alternatively the termination of the License
Agreement for the FSC Certification Scheme, and
ii. the restriction from carrying out processes or activities that are
included within the scope of their FSC certification as a result of
suspension/termination of FSC certification, and
iii. prevention of re-entry to the FSC system by re-certification or by
becoming a member of a Group or Multi-site COC certification,
or by becoming a contractor for other certificate holders with valid
FSC certification.
NOTE: An organization may be blocked from the FSC system for
reasons other than as a response to False Claims. The above definition
is provided in the context of this Advice Note.
NOTE: For organizations having Group CoC certification, the blockage
will apply to the whole group in case root cause analysis establishes that
the false claim developed due to a failure (negligent or deliberate) at the
group level (or Group manager level). In other scenarios, if the root
cause analysis establishes the development of the false claim to a failure
at the group member level, then this Advice Note will apply at the Group
member level.
Clear and convincing evidence: Evidence available to the certification
body, ASI and/or FSC or to the Blocked Organization that supports a
conclusion that a fact is substantially more probable to be true than not.
Clear and convincing evidence shall be supported by documents, facts,
other information, or records, either quantitative or qualitative, that can

FSC-DIR-40-004 EN
be verified through analysis, observation, measurement, and other
means of research (See Graphic 1).
Contractor: Individual, company, or other legal entity contracted by an
organization for any activities under the scope of an FSC COC
certificate.
CPR measures: The collection of corrective, preventive and remedial
measures to be implemented by an organization to address a False
Claim incident.
Corrective measures – aimed primarily at stopping the further
circulation of non-conforming products and related promotional claims.
Preventive measures – aimed at preventing future occurrence and
shall be developed based on a root cause analysis to be conducted by
the organization responsible for the False Claim incident.
Remedial measures – aimed at compensating for any volume of False
Claims released into the market which had not been properly allocated
to and deducted from the relevant product group volume accounts. In
such cases, the organization responsible for a False Claim incident shall
take remedial measures by using (purchasing, allocating from existing
stock, and/or deducting credits) the same volume of FSC input material
that would have been necessary to correctly produce the non-
conforming products. (Refer Clauses 7.1-7.4 for further information on
implementing remedial measures.)
False Claim: FSC claim made on sales documents (physical or
electronic) or the use of the FSC trademarks, on products and/or for
projects that are not eligible to be claimed, labelled and/or promoted as
being FSC-certified or FSC Controlled Wood. A False Claim is different
from an inaccurate claim, in which a product, that is eligible to be sold
as FSC certified, is sold with the wrong claim.
Deliberate False Claim: A False Claim that has been made
deliberately/intentionally by an organization with knowledge and
awareness of the consequences. Clear and convincing evidence is
required to determine a False Claim incident as deliberate.
Negligent False Claim: A False Claim that has been made by an
organization due to its failure to exercise reasonable care. A negligent
False Claim would result in the unintentional application of an FSC claim
on sales documents (physical or electronic) or the use of the FSC
trademarks, on products and for projects that are not eligible to be
claimed, labelled and/or promoted as being FSC-certified or FSC
Controlled Wood.
Other False Claim: A False Claim that has been made neither
deliberately, nor due to the failure of the organization to exercise
reasonable care, but under exceptional or uncontrollable circumstances.
Typically, these circumstances cannot be reasonably anticipated, hence
a differentiating characteristic is that it cannot be expected at reasonable
costs for the organization to have preventive measures in place to
prevent the (re-)occurrence of relevant False Claims. Clear and

FSC-DIR-40-004 EN
convincing evidence is required to determine a False Claim incident as
‘other’.
False Claim incident: A single instance of a False Claim that can be
attributed to a root cause. Multiple incidents of False Claims may
originate from the same root cause.
False Claim event: One or several incidents of False Claims which
originate from the same root cause. All these instances of False Claims
(which would normally trigger a single non-conformity in an assessment)
count as one False Claim event for the purpose of this Advice Note.
FSC Certification database: A computer-based system containing
inter alia information on Certification Data, Certification Bodies,
Certificate Holders and other license holders. It includes a search
function which is publicly accessible at info.fsc.org (‘FSC Public
Search’) and which enables producers, traders and consumers to verify
the status and scope of an FSC Certification as well as provides
transparency for stakeholders.
FSC Trademark License Agreement: The License Agreement for the
FSC Certification Scheme signed by the certificate holder permitting use
of the FSC trademarks (‘licensed materials’).
Granted Rights: The right to use the FSC trademarks for FSC claims,
as defined in FSC-STD-40-004, for on-product labeling on FSC-certified
products and for promotional use worldwide as licensed and further
regulated by via the FSC Trademark License Agreement.
Inaccurate claim: FSC claim made on sales documents (physical or
electronic) on products and for projects that are eligible to be claimed as
being FSC-certified or FSC Controlled Wood but have been sold with
the wrong claim.
Negligence: Failure to exercise reasonable care.
Non-conforming product: Product or material for which an
organization is unable to demonstrate that it conforms to the applicable
FSC certification requirements and eligibility requirements for making
FSC claims.
NCP requirements: The requirements (consisting of procedures and
activities) for organizations to address non-conforming products, as
defined in Clause 1.6 of FSC-STD-40-004 V3-0.
Self-declared False Claim: A False Claim is considered self-declared
if the organization:
a. detects it in an unforced manner, and
b. notifies its certification body and all affected direct customers in
writing within five business days of the detection, and maintain
records of that notice, and
c. analyzes the root cause for occurrence of the False Claim, and
implement measures to prevent their reoccurrence, and
d. cooperates with its certification body in order to allow the
certification body to confirm that appropriate actions were taken to
correct the non-conformity.

FSC-DIR-40-004 EN
NOTE: False Claims declared by organizations which are subject to a
transaction verification or any other announced or ongoing investigation
would not be considered to be made unforced and hence not fall into
this category.
Background In November 2016, the FSC Board of Directors approved the revised
versions of FSC-STD-40-004 (V3-0), FSC-STD-20-011 (V4-0) and an
additional set of actions for ensuring supply chain integrity and
addressing false claims in the FSC system.
However, there was observed a clear need to have specific actions to
prevent organizations who, either due to negligence or deliberate
actions, affect the integrity of the FSC system. These include measures
to ‘block’ such organizations from the FSC system and initiate a series
of preventive and corrective measures to address the issue of false
claims. In addition, there was also a need to ensure that organizations
do not inadvertently enter into a business relationship with a Blocked
Organization when they outsource services or want to add a new group
member or a participating site.
NOTE: For organizations responsible for a false claim event or for those
who were not responsible (but who have passed on false claims
unknowingly), the actions to address the delivery of non-conforming
products are defined in Clause 1.6 of FSC-STD-40-004.
Advice Identifying and recording False Claims

1.1. Upon detection of a False Claim incident, either by the CB and/or
ASI, or detected by FSC/ASI (as a response to a complaint), or self-
declared by the organization,
1.1.1. The certification body shall register the False Claim event on
the FSC certificate database as a Transaction Verification (TV)
finding for further investigation. This shall be done even if the False
Claim incident was detected outside a Transaction Verification
(TV) investigation.
1.1.2. The certification body shall verify that the organization has
informed its downstream buyers that products with False Claims
were delivered to them.
1.1.3. The certification body shall verify the relevance and accuracy
of the root cause analysis undertaken by the organization (see
Clause 1.1.4 below) as a response to a False Claim incident.
NOTE 1: The registration of the False Claim on the FSC database
is not dependent on the final classification of the False Claim as
negligent, deliberate or other.
NOTE 2: FSC or ASI may independently or jointly identify and
investigate False Claims.
1.1.4. The organization shall undertake a root cause analysis to
determine the reason for occurrence of the False Claim and
identify appropriate measures to address the root cause.

FSC-DIR-40-004 EN
1.1.5. FSC and/or ASI will classify the False Claim incident, based on
the root cause analysis undertaken by the organization, as either:
a. Deliberate False Claim, or
b. Negligent False Claim, or
c. ‘Other’ False Claim.
NOTE 1: For classifying the False Claim event as
deliberate/negligent/other, FSC/ASI would consider the root cause
analysis provided by the organization, but the classification
decision does not need to be based on that analysis only. FSC/ASI
may look at other sources of information also.
NOTE 2: Clear and convincing evidence is used as a basis to
determine whether a False Claim incident is classified as
‘deliberate’ or ‘other’ (neither deliberate nor negligent). In the
absence of clear and convincing evidence (presented by FSC or
ASI to qualify a False Claim as ‘deliberate’, or by the organization
to qualify as ‘other’), the default classification would be ‘negligent’.
2. Response to False Claims

Depending on the nature and frequency of a False Claim incident, the
response to a False Claim shall be as per one of the following
scenarios (See Graphic 2):
2.1. Scenario 1: ‘Other’ False Claim incident
2.1.1. The organization shall implement the requirements of FSC-
STD-40-004 pertaining to non-conforming products (Hereafter
referred to as “NCP requirements”).
2.2. Scenario 2: Negligent False Claim incident
2.2.1. The organization shall implement the NCP requirements;
and
2.2.2. The organization shall implement the corrective, preventive
and remedial measures (CPR measures – as defined in the
section ‘Terms and Definitions’ above).
2.2.3. The certification body shall review the implementation of
these measures as part of the ‘Corrective Action Request’
issued by the certification body in response to the False
Claim.
NOTE: A ‘self-declared’ False Claim shall be treated in the same
manner as a negligent False Claim incident.
2.3. Scenario 3: Negligent False Claim events – three (3) or more
within a five (5) year period
2.3.1. The organization shall implement NCP requirements and
CPR measures. This will be a pre-condition for the Blocked
Organization to reenter the FSC system post the blockage
period.
2.3.2. FSC will:

FSC-DIR-40-004 EN
a) suspend the Granted Rights held by the organization
terminate the FSC Trademark License Agreement,
whichever is most appropriate to protect the integrity, trust
and credibility of the FSC Certification Scheme as well as
customers, other participating certificate holders but also
FSC International, and
b) block the organization from the FSC Certification Scheme for
the period of three (3) to sixty (60) months (see exception
under 2.3.4 below), and
c) inform the relevant certification body about the results and
consequences of the investigation and the blocked status of
the organization.
NOTE 1: The exact duration of the blockage is specified in FSC-
PRO-10-003.
NOTE 2: Self-declared False Claims are exempted from scenario 3.
2.3.3. The certification body shall:
a) suspend or terminate all FSC certifications of the Blocked
Organization.
b) update the FSC Certification database to indicate the
Blocked Organization’s certification status as 'Suspended' or
'Terminated' (Clause 1.4.7 of FSC-STD-20-001 V4.0) based
on Clause 2.3.2 c); and
c) inform the Blocked Organization of its
suspension/termination status as per Clause 1.4.8 of FSC-
STD-20-001 V4.0.
NOTE : The five (5) year period is triggered with the first negligently
made False Claim incident and the False Claim count is regardless
of the regular cycle for FSC Certification.
2.3.4. The Blocked Organization can have the status “Suspended
and Blocked” or “Terminated and Blocked” revoked before
the end of the duration of the blockage if it is confirmed that
the Blocked Organization has fulfilled the following
requirements:
a) by the certification body: implementation of NCP
requirements and CPR measures; and
with FSC-PRO-10-003 and any other applicable conditions
established by FSC to remedy the shortcomings.
2.4. Scenario 4: Deliberate False Claim incident – investigation
conducted by FSC or ASI concludes that the organization
deliberately made a False Claim
2.4.1. The Blocked Organization shall implement the NCP
requirements and undertake the CPR measures. This will
be a pre-condition for the Blocked Organization to reenter
the FSC system post the blockage period.
2.4.2. FSC will:

FSC-DIR-40-004 EN
a) suspend the Granted Rights held by the organization
terminate the FSC Trademark License Agreement,
whichever is most appropriate to protect the integrity, trust
and credibility of the FSC Certification Scheme as well as
customers, other participating certificate holders but also
FSC International, and
b) block the organization from the FSC Certification Scheme for
two consecutive and equivalent periods, each ranging in
duration from three (3) to sixty (60) months (see exception
under 2.4.5 below), and
c) inform the relevant certification body about the results of the
investigation and the blocked status of the organization.
NOTE: The exact duration of the individual blockage periods is
specified in FSC-PRO-10-003.
2.4.3. The certification body shall:
a) suspend or terminate all FSC certifications of the Blocked
Organization.
b) update the FSC Certification database to indicate the
Blocked Organization’s certification status as 'Suspended
and Blocked' or 'Terminated and Blocked' (Clause 1.4.7 of
FSC-STD-20-001 V4.0) based on Clause 2.4.1 c); and
c) inform the Blocked Organization of its
suspension/termination status as per Clause 1.4.8 of FSC-
STD-20-001 V4.0.
2.4.4. For deliberate False Claims, FSC will not revoke the
status “Suspended and Blocked” or “Terminated and
Blocked” before the end of the duration of the first
period of blockage.
2.4.5. The Blocked Organization can have the status “Suspended
and Blocked” or “Terminated and Blocked” revoked after
the end of the first period of blockage and before the
end of the duration of the second period of blockage if it is
confirmed that the Blocked Organization has fulfilled the
following requirements:
a) by the certification body: implementation of NCP
requirements and CPR measures; and
with FSC-PRO-10-003 and any other applicable conditions
established by FSC to remedy the shortcomings.
NOTE: The revocation of the blocked status for deliberate False

Claims by payment of compensation fees is only applicable to the
second period of blockage. This will only be possible after the
organization has stayed blocked from the FSC system for the first
period.
2.4.6. The implementation of the NCP requirements and CPR

measures shall be verified by the certification body that

FSC-DIR-40-004 EN
is recertifying the Blocked Organization at the end of its
blockage period.
Consequences for Blocked Organizations

3.1. For the duration of the blockage, the relevant certification body
shall suspend/terminate the organization’s FSC certification. As a
consequence of this, the Blocked Organization shall not trade,
process, manufacture, label, store, or transport FSC material or
undertake any activity as part of their certification scope.
3.2. Certification bodies shall not grant, maintain, transfer, or
reinstate the certification of Blocked Organizations while they have
the status “Suspended and Blocked” or “Terminated and Blocked”
in the FSC Certification database.
3.3. If a Blocked Organization's status is 'Suspended and Blocked,' and
the suspension period has exceeded twelve (12) months or in
exceptional cases, up to eighteen (18) months (FSC-STD-20-001,
Clause 4.7.5) and the Blocked Organization has not implemented
the measures specified in Clause 2.3.4 a) and b) and Clause 2.4.4,
the certification body shall terminate the Blocked Organization’s
certification and the status of the Blocked Organization shall be
updated to “Terminated and Blocked”.
3.4. The Blocked Organization shall fulfill all the conditions specified
in this advice note, and the applicable requirements in the FSC
Normative Framework, including, but not limited to FSC-PRO-10-
003 and further instructions during the duration of blockage.
NOTE : If a False Claim is made by a group member or
participating site, then this Advice Note applies to that specific
group member or participating site and not to the Central Office. In
case False Claims are made by multiple group members or
participating sites, then this Advice Note applies to each individual
member/site who made the False Claim. In addition, the
requirements of FSC-STD-40-003 (Clause 4.2, and Annex 2 –
Clause 1.2 and Clause 2) also apply.
Organizations outsourcing services or adding a new group
member or participating site
3.5. In the case of outsourcing agreements, the contracting organization
shall not outsource services related to FSC material to organizations
that are listed as ‘suspended and blocked’ or ‘terminated and blocked’
on the FSC Certification Database.
3.6. Organizations with valid FSC certification shall verify if another
organization is blocked in the FSC database and consider the Blocked
Organization ineligible for any of the following activities:
i. adding a new group member to the Group COC certification
or
ii. adding a participating site to the Multi-site COC certification.

FSC-DIR-40-004 EN
Certification bodies adding sites or members and verifying
outsourcing agreements
3.7. In the case of a Group or Multi-site COC certification, the
certification body shall verify the organization’s status in the FSC
Certification database before adding new participating site to the
Multi-site COC certification or adding a new group member to the
Group COC certification.
3.8. In case of sub-contractors, the certification body shall verify the
sub-contractor’s status in the FSC Certification database and shall
not verify any outsourcing agreement where the sub-contractor is
listed as ‘suspended and blocked’ or ‘terminated and blocked’ on
the FSC Certification Database.
4. Lifting the blockage
4.1. Upon receiving a request for unblocking from a Blocked
Organization, FSC will evaluate the integrity and/or reputational risk
posed by the organization and decide whether to unblock the
organization.
NOTE 1 : FSC reserves the right to reinstate and unblock the
Blocked Organization based on its assessment of individual cases.
As such, based on the integrity/reputational risk, it can also choose
not to unblock an organization.
NOTE 2: The organization may be subject to additional monitoring
measures specified by ASI/FSC as conditional to lifting the
blockage. The organization would be required to fulfill these
additional measures and that might result in additional ongoing
expenses for unannounced audits, documents review etc.
NOTE 3: In the case of identified risks to the integrity of the FSC
system, FSC may also require the Blocked Organization to
participate in transaction verification activities or participate in the
FSC wood identification programme or both.
NOTE 4: FSC may, at its discretion, enter into a Memorandum of
Understanding (MoU) with the Blocked Organization, as a response
to the False Claim. The MoU may contain specific additional
conditions on a case by case basis for organizations to the blockage
to be lifted. In such situations, the provisions of the MoU supersede
this Advice Note, unless specified otherwise.
4.2. If FSC decides to unblock the organization, it will issue an invoice
for payment of the compensation fee after fulfillment of Clause
2.3.4 a) or Clause 2.4.5 a) as applicable.
5. Contesting a blocked status and compensation fee

5.1. The organization which has been blocked according to Clauses
2.3.2 or 2.4.2 may submit evidence to contest the blockage
decision made by FSC as specified in FSC-PRO-10-003.
6. Duty to cooperate with investigation

FSC-DIR-40-004 EN
6.1. Organizations are obligated to use its commercially reasonable
efforts to take all actions to assist and cooperate with FSC, ASI
and/or CB in doing all things necessary or advisable to perform the
investigations into False Claims. In case the organization fails to
cooperate in this regard, FSC can block the organization for the
period up to one hundred twenty (120) months.
For implementing Clause 2.2.1 (Remedial measures)

7.1 Within three (3) months of detection of the False Claim, the
organization that produced and released non-conforming product
shall purchase or allocate from existing stock an equivalent amount
of eligible FSC input material to the corresponding product group.
NOTE: If corresponding FSC credits / percentage volumes had
been allocated / deducted to the non-conforming products from the
product group volume accounts and only ineligible material had
been used resulting in the False Claim event, then this requirement
is considered to be covered.
NOTE: In case the organization is not able to purchase an
equivalent amount of FSC input material (due to lack of availability,
capacity etc.), the certification body may, under exceptional
circumstances, extend the period for implementing remedial
measures to up to 12 months from the date of detection of the
False Claim, provided the organization is able to justify the delay
and has made credible and verifiable measures to start
procurement of the equivalent quantity of FSC input material.
7.2 If the non-conforming products carrying False Claims cannot be
recalled, de-labeled or otherwise stopped from reaching the destined
final customer, the purchased or allocated FSC input material shall
not be used to produce new, conforming product, but instead any
FSC credits or percentage values carried by that material would be
void (products made from such material shall not be sold with the
FSC claim).
NOTE: In other cases, the organization may produce and release
‘conforming product’ from that FSC input.
7.3 If the organization cannot purchase / allocate such an amount (e.g.,
because there is no such material available), then it shall pay a
compensation fee to FSC in accordance with FSC-PRO-10-003.
7.4 If the organization cannot or does not pay the compensation fee,
then it will be blocked in accordance with FSC-PRO-10-003.
NOTE: The organization has to implement remedial measures
irrespective of its blocked status. Implementation of remedial
measures is independent of whether the organization is paying the
compensation fee to avoid blockage.

FSC-DIR-40-004 EN
Graphic 1. Standard of certainty on a probability scale
Graphic 2: Hierarchy of scenarios and applicable requirements
‘Deliberate’ false claim

incident
‘Negligent’ false claim

event – 3 in 5 years
‘Negligent’ false claim

incident
‘Other’ false claim

FSC-DIR-40-004 EN
ADVICE-40-004-19 Species information in FSC Product Groups
Status Withdrawn
ADVICE-40-004-20
Confirmation of origin for FSC certified Paulownia products
(V1-0)
Normative reference FSC-STD-40-004 V3-1

- Clauses 2.1
- Clause 2.2
- Clause 2.4
- Clause 5.1
- Clause 8.3 c)
Scope This advice note applies to all CoC certificate holders trading in
products made with Paulownia carrying an FSC claim
Approval FSC Director General, 05 May 2021
Effective date 07 May 2021 until 31 March 2024
Background In 2019 FSC commissioned ASI to undertake a Transaction

Verification for FSC certified Paulownia products traded in 2018 and
2019, which revealed systematic violations of certification
requirements by organizations that were trading non-certified
Paulownia products as certified. Furthermore, these investigations
found that there were no sales activities of Paulownia material from
any FSC certified FM/CoC certificate holders in 2018 and 2019. FSC
therefore informed certification bodies in December 2019 of the results
of the investigation and advised them to implement measures to
address the risk of false claims with any certificate holder that has
Paulownia in the scope of their FSC certificates.
By the end of 2020, there are still no FSC certified forests known to
FSC that have produced and sold FSC certified Paulownia. Therefore,
FSC had requested ASI to accelerate the implementation of the
interpretation INT-STD-40-004_40 with regards to Paulownia. The
interpretation does not translate to an automatic removal of Paulownia
from certificate holders’ product group lists nor to a designation of
products with Paulownia as non-conforming products.
Although it cannot be excluded that there could be eligible inputs in
FSC certified Paulownia products, given the investigation findings and
the current lack of availability of Paulownia in FSC certified forests,
there is a high risk that the vast majority of FSC certified Paulownia
products produced over the last three years contain non-eligible
sources. Hence, FSC does not see any alternative to now take

FSC-DIR-40-004 EN
precautionary measures that no further ineligible Paulownia material
is sold and labelled as FSC certified.
Advice 1. From 01 August 2021, organizations shall not include Paulownia or

products containing Paulownia in their product group list, nor
sell/label products containing Paulownia. The only exception is if
the organization can trace the Paulownia carrying an FSC claim to
its FSC certified forest management unit of origin through
documentary evidence.
2. Certification bodies shall verify the accuracy and plausibility of the
supplier documentation tracing the material back to the forest
management unit of origin. This verification shall be undertaken at
a minimum during the annual evaluations.
NOTE: The above requirements also apply to products
manufactured or sold from pre-existing inventory of FSC certified
Paulownia as of 31 July 2021.
NOTE: This Advice is applicable only to Paulownia that comes
with an FSC claim and does not apply to Paulownia obtained as
controlled material/FSC Controlled Wood which is verified
through a Due Diligence System (DDS) as specified in FSC-STD-
40-005 V3-1.
ADVICE-40-004-20 Confirmation of origin for FSC certified products from species

of a particular risk to FSC´s integrity
(V2-0)
Normative reference FSC-STD-40-004 V3-1,

- Clause 2.1
- Clause 2.2
- Clause 2.4
- Clause 5.1
- Clause 8.3 c);
FSC-STD-20-011 V4-2
- Clauses 2.2 a)
- Section 12, Table B
Scope This Advice Note applies to all CoC-certified and applicant

organizations sourcing FSC-certified material or trading products
made with species of a particular risk to FSC’s integrity and carrying
an FSC claim (see Annex I). The Advice Note is also applicable to all
organizations that have FSC-certified material in stock and products
manufactured from pre-existing FSC-certified raw material stocks.
This Advice Note does not apply to the CoC-certified organizations
dealing with controlled material / FSC Controlled Wood verified

FSC-DIR-40-004 EN
through a due diligence system as specified in <FSC-STD-40-005 V3-
1 Requirements for Sourcing FSC Controlled Wood>.
This Advice Note also applies to FSC-accredited certification bodies
(CBs) responsible for evaluating CoC-certified organizations under the
aforementioned condition.
Approval date 18 September 2023
Effective date 01 January 2024
Transition end date 01 April 2024
Background In 2019 FSC commissioned ASI to undertake a Transaction

Verification for FSC certified Paulownia products traded in 2018 and
2019. The Transaction Verification investigation was concluded in
2020 and revealed systematic violations of certification requirements
by organizations that were trading non-certified Paulownia products
as certified in absence of any sales of Paulownia from FSC forest
management units. In order to ensure FSC’s system integrity, in 2021
FSC introduced an Advice Note ADVICE-40-004-20 on Confirmation
of origin for FSC certified Paulownia products. A year later, in 2022,
the second Transaction Verification investigation for Paulownia
products was launched by FSC and ASI to check besides other issues
and the effectiveness of the Advice Note. No critical violations were
identified and therefore the Advice Note proved to be a functional
working tool to secure integrity of FSC certified Paulownia supply
chains.
A Transaction Verification on Mangifera and Dalbergia launched by
FSC and ASI in 2022 showed a similar situation like Paulownia in FSC
certified supply chains of Mangifera and Dalbergia, where a limited
capacity of FSC certified forest management units could not be
compatible with the volumes claimed in supply chains.
Considering the effectiveness of the Advice Note ADVICE-40-004-20
on Confirmation of origin for FSC certified Paulownia products and
with the intention of responding in an expedite manner to the risk of
introduction of ineligible inputs of Mangifera and Dalbergia or any
other species of a particular risk of integrity that FSC identifies via
Transaction Verification or other investigations, FSC decides to take
precautionary measures by expanding the scope of the ADVICE-40-
004-20, as defined here below.
Relevant species are identified by FSC after the conclusion of
Transaction Verification or other investigations, where there is
reasonable and convincing evidence that the trade in these species
raises critical integrity risks for FSC.
Advice Section 1: Certificate holder requirements

FSC-DIR-40-004 EN
1.1. The organization shall not include species of a particular risk to
FSC’s integrity in their product group list, not accept relevant
material as certified input into their certified product groups, nor
label or sell products containing such material with an FSC claim
unless the organization can trace the material to its forest
management unit of origin through objective evidence.
1.2. The organization that uses material from species of a particular
risk based on Clause 1.1 above shall ensure that the full species
information is recorded in the product groups list (and not only the
genus).
1.3. The organisation shall review and, if necessary, revise the
product group list after a new species is added to Annex I.
Section 2: Certification body requirements
2.1. The certification body shall verify the accuracy and plausibility of
the supplier documentation tracing the material back to the forest
management unit of origin. This verification shall be undertaken
at a minimum during the annual evaluations.
2.2. If the certification body comes to the conclusion that the supplier
documentation is insufficient to clearly trace the material to the
forest management unit of origin, the certification body shall
inform FSC and ASI of the suspicion of false claim and share the
relevant information.
2.3. The certification body shall assess the organization’s certification
scope to include the species details and update the FSC
database accordingly in case only the genus has been recorded.
NOTE 1: FSC will update Annex I based on the conclusions of
Transaction Verification or other investigations as deemed necessary.
NOTE 2: In case that only the genus is listed, it applies to all species
within this genus.
Annex I This annex lists the species of a particular risk to FSC’s integrity to
which this advice note applies.
• Dalbergia latifolia
• Dalbergia scleroxylon
• Dalbergia sissoo
• Mangifera indica
• Paulownia spp.
ADVICE-40-004-21 Moratorium on sales of wood and wood products with FSC

certified or FSC Controlled Wood claims originating from
sanitary logging from Irkutsk Oblast region of Russia

FSC-DIR-40-004 EN
Normative reference FSC-STD-40-004 V3-0, Clauses 1.1.b), 1.6, 3.1 and 5.1
FSC-STD-40-005 V3-1, Clause 2.1
FSC-STD-RUS-V6-1-2012 V6-1, Indicators 8.3.1, 8.3.2 and 8.3.4
FSC-STD-RUS-02.1-2020, Indicators 8.5.1 and 8.5.2
Scope Organizations with FM in their certification scope, having management

units in Irkutsk Oblast of Russia and introducing FSC certified material
into the market.
Organizations with COC/CW in their certification scope sourcing
controlled material through DDS (Due Diligence System) from Irkutsk
Oblast of Russia.
Approval 14 July 2021
Effective date 14 August 2021
Terms & definitions Sanitary logging (transliteration from Russian “sanitarno-

ozdorovitelnye meropriyatiya”; in Russian “санитарно-
оздоровительные мероприятия”): in Russia and in some other
countries is a combined term for sanitary logging and salvage logging,
where sanitary logging is primarily a preventive forest management
operation that seeks to maintain the health and value of the forest by
removing weak or infected trees, and salvage logging is an emergency
operation to remove heavily damaged or dead trees after events like
windfalls, fires or pest outbreaks. Salvage logging often has a sanitary
function as well which makes it difficult to classify relevant
interventions as one or the other.
NOTE: This definition is used for the purpose of this advice note
only.
Background Despite measures taken by the Russian government to address the

issue of illegal sanitary logging, it remains a problem across the
country, especially in Irkutsk Oblast, and a great concern for FSC.
Over the past years, high levels of illegal sanitary logging and related
high-profile cases have been observed in Russia, specifically in
Irkutsk Oblast, including logging broader areas than defined in the
permit, logging healthy trees, or having some authorities issue a
permit without good reason. This issue has been noted by the Russian
government, stakeholders, NGOs and confirmed by FSC in its
National Risk Assessment for Controlled Wood for Russia (NRA) in
2018 and an FSC Russia study launched in December 2020. To
mitigate the immediate risks, local authorities of Irkutsk Oblast
temporarily stopped sanitary logging in the region in 2020 with a plan
to reinstate it later.
Although FSC certification requires that any type of forest
management operations including sanitary logging is duly recorded
and complies with relevant harvesting regulations, risks associated
with illegal sanitary logging are presently not fully addressed in the
National Forest Stewardship Standard for Russia (NFSS) and NRA.

FSC-DIR-40-004 EN
This advice note is developed to address the risk of wood from illegal
sanitary logging in the Irkutsk Oblast region entering the FSC supply
chain, with the consideration that it is the most problematic region of
Russia in regard to sanitary logging and that the official pausing of
sanitary logging in this region is to be lifted by the local government in
2021.
Advice 1. Certificate holders with forest management in their certificate

scope and having management units in Irkutsk Oblast of Russia
shall not (either directly or through any affiliate organization)
undertake sales or delivery of FSC certified material (in any form,
including rough wood, sawn timber or any type of processed wood)
harvested from sanitary logging in Irkutsk Oblast, Russia.
2. Chain of custody certificate holders with <FSC-STD-40-005
Requirements for Sourcing FSC Controlled Wood> in their
certificate scope implementing a DDS (Due Diligence System)
shall not undertake sales or delivery of FSC certified material or
FSC controlled wood (in any form, including rough wood, sawn
timber or any type of processed wood) harvested from sanitary
logging in Irkutsk Oblast, Russia.
NOTE: This advice note may be withdrawn or modified once FSC
establishes other normative or policy changes (in terms of
interpretations, updates to Russian National Risk Assessment
(NRA), update to Russian National Forest Management Standard
(NFSS) etc.) to more effectively address the risk of material from
sanitary logging areas in Irkutsk Oblast region illegally entering
FSC supply chains.
ADVICE-40-004-23 Evaluation of contractors against the FSC core labour

requirements
Normative reference FSC-STD-40-004 V3-1:

Clause 1.6,
Clause 13.2,
Clause 13.4
Terms and definitions: ‘Scope’
FSC-STD-20-011 V4-2:
Section 9
Clause 11.3
Scope This advice note applies to:

– CoC certificate holders that outsource activities within the
scope of their certification to non-FSC-CoC-certified
contractors.
– Certification bodies auditing certificate holders under the
aforementioned condition.

FSC-DIR-40-004 EN
Approval date 11 April 2023, amended 01 September 2023
Effective date 01 July 2023
Transition end date 31 December 2024
Background Clause 13.2 of <FSC-STD-40-004 V3-1 Chain of Custody

Certification> states that activities subject to outsourcing agreements
are those that are included in the scope of the organization’s CoC
certificate.
Clause 11.3 of <FSC-STD-20-011 V4-2 Chain of Custody
Evaluations> requires the certification body to design and implement
a system for evaluating the relevance, effectiveness, and adequacy of
the organization’s self-assessment and conformity to Section 7 of
<FSC-STD-40-004 V3-1 Chain of Custody Certification>, according to
the scope, scale, intensity, and risk of the organization's operation.
This allows each certification body to define individual requirements
on how and when to conduct on-site audits for contractors or when
not. To ensure that all certification bodies apply the same level of
scrutiny and ensure a fair “level playing field” (i.e., audit conditions for
organizations are not dependent on the certification body they choose)
the following advice is provided.
This advice note’s objective is to provide clear instructions on how the
FSC core labour requirements have to be applied to contractors
operating under outsourcing agreements.
Terms and First party audit: an assessment that is performed within the
definitions organization by their own auditing resource (i.e., internal audit).
Second-party audit: an assessment that is performed by a person or
organization that has an interest in the object of the assessment (e.g.,
an organization conducts an audit of their contractor).
Advice 1. Inclusion of contractors within the organization’s self-

assessment
1.1 The organization shall include provisions in the outsourcing
agreement with non-FSC-certified contractors which are
specifying their commitment to the FSC core labour
requirements or shall be able to refer to an internal policy of the
contractor that is demonstrating such a commitment.
1.2 The organization shall include non-FSC-certified contractors with

an outsourcing agreement within their self-assessment which
describes how the organization has confirmed the
subcontractor’s conformity to the FSC core labour requirements.
NOTE: Contractors who are certified by a verification scheme1
identified by FSC as equivalent to the FSC core labour
1
Verification schemes consist of voluntary sustainability standards (VSS), national and regional regulatory mechanisms, corporate practices,
internal procurement policies, and sustainability initiatives.

FSC-DIR-40-004 EN
requirements are exempt from organizations’ self-assessments
and certification bodies’ risk assessments, similar to FSC-
certified contractors. Any observations or complaints about
potential non-conformities should be shared with responsible
certification bodies and verification scheme owners.
2. Risk assessments of contractors’ conformity to the FSC

core labour requirements
2.1 In addition to the risk assessment of the organization’s chain of
custody control system used during outsourcing activities with
respect to the risks of mixing, substitution, or false claims, the
certification body shall conduct a risk assessment of the
organization’s control over their contractors’ conformity to the
FSC core labour requirements.
2.2 An outsourcing arrangement with a non-FSC-certified contractor

can be classified as ‘low risk’ if the following applies:
a) there are no substantiated complaints regarding the
contractor’s conformity to the FSC core labour requirements
since the last surveillance audit; AND
b) the previous evaluation has not resulted in any non-
conformities in regard to the contractor’s conformity with the
FSC core labour requirements; AND
c) the previous evaluation was conducted as an on-site audit at
the contractor; OR
d) the contractor's conformity to the FSC core labour
requirements described within the organization’s self-
assessment is confirmed with evidence of documentation and
records from a first-party or second-party audit conducted at
least annually; OR
NOTE: “Annually” is to be interpreted as follows: at least once
per calendar year, but no later than 15 months after the last
first- or second-party audit (determined by the date of the on-
site visit).
e) the contractor is in a country with a rating of 1 or 2 under the
ITUC Global Rights Index2 and with a CPI3 score >50.
2
The ITUC Global Rights Index rates countries on a scale from 1 to 5+ on the degree of respect for workers’ rights,
https://www.globalrightsindex.org/
3
Corruption Perception Index, https://www.transparency.org/en/cpi/

FSC-DIR-40-004 EN
3. Evaluations of ‘low risk’ outsourcing agreements
3.1 For outsourcing agreements classified as ‘low risk’ related to
violations of FSC core labour requirements, the certification body
shall at least conduct a desk-based audit of the contractor.
3.2 A desk-based audit shall cover at minimum verification of the

organization’s conformity to clauses 1.1 and 1.2 above to identify
any changes regarding:
a) the contractor’s commitment towards the FSC core labour

requirements (e.g., the existence of complaints);
b) the status of the contractor’s country with respect to ITUC and
CPI scores.
4. Evaluations of ‘high risk’ outsourcing agreements

4.1 For outsourcing agreements classified as ‘high risk’ related to
violations of FSC core labour requirements, the certification body
shall conduct an on-site audit of the contractor.
NOTE: When ‘high risk contractors’ are located in different
countries, the certification body may contract the following third
parties to complete the audit:
i. an FSC-accredited certification body; or
ii. a certification body accredited to a verification scheme that
is identified as equivalent to the FSC core labour
requirements.
4.2 On-site audits shall include, in addition to the organization’s

conformity to Clauses 1.1 and 1.2 above, interviews with
personnel and site observations.
5. Sampling of contractors
5.1 If more than one outsourcing agreement is identified as high risk,
a sampling of relevant contractors according to Clause 9.6 of
<FSC-STD-20-011 V4-2 Chain of Custody Evaluations>, can be
applied.
NOTE: If the organization wants to include new high-risk
outsourcing agreements in its certificate scope in the period
between the certification body evaluations, Clause 9.5 of <FSC-
STD-20-011 V4-2 Chain of Custody Evaluations>, applies
accordingly.
5.2 The certification body may add relevant contractors to the pool
of contractors identified as having high-risk situations with
respect to mixing different input materials and take a sample from
the overall resulting pool. In this case, the sample shall be
structured in such a way that it results in a balanced coverage of
the two risk scenarios.

FSC-DIR-40-004 EN
NOTE: For group and multisite certificates, the calculation of the
contractor sample shall be conducted at the participating-site
level.
ADVICE-40-004-24 Evaluation of FSC core labour requirements using FSC approved

Normative reference FSC-STD-40-004 V3-1 Chain of Custody Certification

Clause 1.6
Clause 1.11
Section 7
Annex D: ‘FSC core labour requirements self-assessment’
FSC-STD-20-011 V4-2 Chain of Custody Evaluations
Section 11
Section 12
PSU-PRO-10-003 V1-1 Procedure for equivalence assessment of
verification schemes against the FSC core labour requirements
Approval date 11 April 2023
Scope This Advice Note is applicable to certification bodies and certificate

holders specifying actions to follow when using FSC approved
verification schemes in conformity with FSC core labour requirements.
Clause 1.11 of <FSC-STD-40-004 V3-1 Chain of Custody
Background
Certification>, states that “The organization may demonstrate
compliance with other certification schemes as evidence of conformity
to Section 7 FSC core labour requirements.”
Section 11 of <FSC-STD-20-011 V4-2 Chain of Custody Evaluations>,

provides requirements for certification bodies to evaluate FSC core
labour requirements.
<PSU-PRO-10-003 V1-1 Procedure for equivalence assessment of

verification schemes against the FSC core labour requirements>
provides a clear and transparent methodology for identifying,
benchmarking, assessing, and approving verification scheme that can
demonstrate conformity with the FSC core labour requirements in
<FSC-STD-40-004 V3-1 Chain of Custody Certification>.
The objective of this Advice Note is to provide instructions for using
FSC approved verification schemes in evaluations of the FSC core
labour requirements. This also aims to ease the verification of FSC
core labour requirements by leveraging other verification schemes.

FSC-DIR-40-004 EN
Terms and FSC approved verification schemes: Third party verification
definitions schemes recognized as partially or fully equivalent to the requirements
entailed under FSC core labour requirements in <FSC-STD-40-004
V3-1 Chain of Custody Certification> and <FSC-STD-20-011 V4-2
Chain of Custody Evaluations>, based on <PSU-PRO-10-003 V1-1
Procedure for equivalence assessment of verification schemes
against the FSC core labour requirements>.
Verification schemes: Voluntary sustainability standards (VSS),
national and regional regulatory mechanisms, corporate practices,
internal procurement policies and sustainability initiatives.
Advice Section 1: Certificate holder requirements

1.1 The organization may use an FSC approved verification scheme
to demonstrate conformity with the FSC core labour
requirements.
NOTE: FSC approved verification schemes are listed in the final
section of this Advice Note.
1.2 The organization using an FSC approved verification scheme
according to this Advice Note may be exempted from
implementing Clause 1.6 of <FSC-STD-40-004 V3-1 Chain of
Custody Certification>.
1.3 The organization shall make available all records related to the
FSC approved verification scheme such as audit reports,
certificates, corrective action requests, non-conformities, etc., to
the certification body.
1.4 The organization shall inform the certification body of any update
or change in the status of its attestation of conformity by the FSC
approved verification scheme.
Section 2: Certification body requirements
2.1 The certification body may waive the requirements in Clause
11.3 of <FSC-STD-20-011 V4-2 Chain of Custody Evaluations>,
if the following requirements are met:
a) the FSC approved verification scheme is valid at the time of
the FSC evaluation; and
b) the authenticity of the attestation of conformity by the FSC
approved verification scheme has been verified against a
publicly available database published by the verification
scheme’s owner or its assurance provider.
2.2 The certification body shall document the findings and
conclusions from applying this Advice Note in the evaluation
report under ‘evaluation findings’ as per Section 12 ‘Reporting
requirements’ of <FSC-STD-20-011 V4-2 Chain of Custody
Evaluations>.
2.3 The certification body shall record any changes in the status of
attestation of conformity as per Clause 1.4 of this advice and take

FSC-DIR-40-004 EN
appropriate actions in accordance with <FSC-STD-20-011 V4-2
Chain of Custody Evaluations>.
FSC approved Certification Schemes:

1. SA8000:2014
ADVICE-40-004-25 Requirements for the organization to provide information to the

certification body (CB) for Annual Administration Fee (AAF)
calculation
Normative reference FSC-STD-40-004 V3-1 Chain of Custody Certification

FSC-STD-40-006 V2-0 FSC Standard for Project Certification
Scope This Advice Note is applicable to all organizations applying for or

holding chain of custody certification.
Background The AAF Policy <FSC-POL-20-005 V3-4 AAF Policy> provides

requirements that the CB shall collect from the organization necessary
information for calculating the AAF, in order for the CB to verify and
enter this information on the FSC Certification Database (Clause 2.2
of <FSC-POL-20-005 V3-4 AAF Policy>).
For CoC certification, including projects, the calculation of the AAF is
based on Forest Products Turnover (FPT) (Clause 5.1.1 of <FSC-
POL-20-005 V3-4 AAF Policy>), and for the organizations that do not
have FPT, AAF is calculated based on the annual overall purchasing
cost of certified material and products (Clause 5.6.1 of <FSC-POL-20-
005 V3-4 AAF Policy>). For projects under <FSC-STD-40-006
Standard for Project Certification>, AAF is calculated on the overall
cost of each project (one-time projects) or the aggregated overall
costs (multiple projects) instead of FPT.
Neither the chain of custody certification (CoC) standard <FSC-STD-
40-004 V3-1 Chain of Custody Certification> nor the project
certification standard <FSC-STD-40-006 Standard for Project
Certification> have specific requirements for the organization to
provide information for calculating the AAF to the CB.
The objective of this Advice Note is to provide normative reference
and clarification on the requirements for the organization to provide
the necessary information for the calculation of AAF to the CB on
request. Additionally, for exceptional cases, this advice note clarifies

FSC-DIR-40-004 EN
how the AAF shall be calculated when an organization does not
provide the FPT and/or Revenue.
Terms and Annual Administration Fee (AAF):

definitions The AAF is the fee charged by FSC Global Development (FSC GD)
to accredited certification bodies (CBs) calculated on the basis of the
respective certificate holder (CH) portfolio. The purpose of the fee is
to support the service provided by FSC GD to uphold the FSC
certification scheme.
(Source: FSC-POL-20-005 V3-4)
Forest Product Turnover (FPT):

a) The Revenue of all certified and uncertified forest products; and
b) The Revenue of all products containing wood or fibre, and all

products containing non-timber forest components, including forest-
based reclaimed materials regardless of the percentage.
NOTE 1: Forest products refers to wood products, pulp and paper

products, and non-timber forest products as per <FSC-STD-40-004a
FSC Product Classification>.
NOTE 2: FPT does not refer to 100% non-forest products that

companies might produce.
NOTE 3: FPT does not refer to related services that a CH may provide
to another organization. The related services a CH receives under an
outsourcing agreement, that contribute to adding value of the product
are already inherently included in the Forest Products Turnover figure
and do not need to be incorporated in addition to the value.
(Source: FSC-POL-20-005 V3-4)
Revenue: Revenue means the total revenue of an organization

derived from the provision of goods and services, less trade
discounts, VAT, intracompany sales (i.e., after any consolidation
where a financial group is existing), and any other Taxes based on
this Revenue. Revenue refers to the most recently completed fiscal
year and is the exact number to the nearest whole USD.
NOTE 1: The Revenue figure includes the Revenue from all certified
and uncertified products that an organization produces irrespective of
the fact whether they include forest-based material or not.

FSC-DIR-40-004 EN
NOTE 2: Intracompany sales relate to sales within one specific
certification only, including the sales within a multi-site certification.
Sales from one CH to another CH (even if within the same corporate
group) and sales made within a group between group members are
not considered intracompany.
(Adapted from: FSC-POL-20-005 V3-4)
1. The organization shall, on request of the CB, provide for each site
Advice
(or participating site) verifiable information on FPT and/or Revenue
for calculation of the AAF.
NOTE: Some options for providing this information are included in the
Annex I of this advice note.
2. If the organization does not have an FPT, because the organization

does not sell any certified or uncertified forest-based materials or
products (e.g., free certified catalogues and certified packaging for
products they sell), the organization shall provide information on
the annual overall purchasing cost of certified material and
products.
NOTE: The cost of certified material and products include the cost of
FSC Controlled Wood material and products.
3. If the organization is a newly founded company that has not yet

completed a full fiscal year and therefore cannot provide the
required FPT, information on the FPT shall be provided in the
following annual audit.
NOTE: In the aforementioned case, the CB would use USD ‘100,000’

as a fictitious figure for the FPT, as per AAF Policy, as the basis for
the AAF calculation, until the fictious figure is replaced by the actual
FPT figure in the following annual audit.
4. If the organization is an existing company that has been purchased

by another legal entity and has not yet completed the first fiscal
year, information on the FPT shall be provided in the following
annual audit
NOTE: In the aforementioned case, the CB would use USD ‘100,000’

as a fictitious figure for the FPT, as per AAF Policy, as the basis for

FSC-DIR-40-004 EN
the AAF calculation, until the fictious figure is replaced by the actual
FPT figure in the following annual audit.
5. For projects certified according to <FSC-STD-40-004 Chain of

Custody Certification Standard>, the organization shall provide
information on FPT. This shall include all projects independent of
whether a project claim is made or not.
6. For projects certified according to <FSC-STD-40-006 V2-0 Project

Certification>, the organization shall provide:
a) For single projects under one-time project certification, the
overall cost of the project that is finalized; or
b) For multiple projects under continuous project certification,
the total aggregated project costs for the projects that are
finalized.
7. If the organization chooses not to disclose information on FPT

and/or Revenue, and neither clause 3 nor clause 4 of this advice
note apply, only one or more of the following reasons for the non-
disclosure of this information are permitted for provision to the
certification body, and a relevant exception provided in clause 8
shall then apply:
a) Legal restriction(s); and/or
b) Organizational policy restriction(s).
8. If the organization provides the certification body with at minimum

one of the permitted reasons for exception under clause 7, the
following applicable figure shall be used to calculate the AAF:
a) For organizations that have previously provided information

on FPT and/or Revenue, based on the mid-point of two AAF
Classes higher than the latest figure provided, or at a cap of
USD ‘10,000,000,000’, whichever is lower); or
b) For organizations that have not previously provided

information on FPT and/or Revenue, based on:
i) A cap of USD ‘5,000,000’ for each participating site of

Group CoC certification; or
ii) A cap of USD ‘10,000,000,000’ for all other types of CoC

certification.

FSC-DIR-40-004 EN
NOTE: In the aforementioned cases, the AAF may be charged on the
applicable basis until the required information has been provided.
Annex I Examples of evidence and supporting documentation

To provide the CB information on FPT and/or Revenue according to
clauses 1 to 6 of this advice note, the organization may choose from
the options provided below.
Option 1
A signed statement from a reputable professional services firm
that includes the name of the Chartered Accountant or auditor, as
well as the organization.
NOTE: For Option 1, the CB may not request additional supporting
documentation for the further investigation of the validity of the
numbers stated.
Option 2
Financial data published by a reputable risk management and
scoring company:
a) In the case of organizations with a 100% forest-based
business where the Revenue reported by a reputable
risk management and scoring company represents the
FPT.
b) In the case of organizations with a business that is not

100% forest-based, the Revenue reported by a
reputable risk management and scoring company
represents the Revenue instead of FPT.
NOTE 1: If a range for the FPT can be determined from a reputable

risk management and scoring company, the upper value is to be
used.
NOTE 2: For Option 2, the CB may choose not to assess or
investigate the validity of the provided information.
Option 3
A formal self-declaration that meets the following criteria:
a) State that the information is correct to the best of the
organization’s knowledge; and
b) Be in writing (and not oral);and
c) Be personally, or electronically (the threshold of
advanced electronic signature according to Article 3

FSC-DIR-40-004 EN
no.11 and Article 26 eIDAS regulation applies here)
signed by an authorized individual (such as a legal
representative or a designated accountant).
NOTE 1: A central office for a CoC Multi-site or Group is not

required to collect written self-declarations of their individual
sites/group members.
NOTE 2: Option 3 is not considered sufficient on its own. A self-
declaration may be used as supporting documentation only and it
will be assessed by the CB for its reasonableness, plausibility and,
as far as possible, accuracy.
Other documentation that the CB may ask for in order to assess

the reasonableness, plausibility, and accuracy of the reported
FPT and/or Revenue include, but are not limited to:
a) Sales tax filings;
b) Income tax records and filings;
c) Accounting records;
d) Financial statements;
e) Declaration from an accountancy firm;
f) Management accounts showing financial general ledger
coding.
ADVICE-40-004-27 Inclusion of the FSC CFM claim in the Chain of Custody

Certification
Normative reference FSC-STD-40-004 V3-1:

- Clause 2.4
- Clause 5.1, Table C, 5.6, 5.9
- Section 8
- Clause 9.3, Table D
- Annex E
Scope This advice note applies to the CoC organization aiming to include the
FSC CFM claim in their product groups scope, whether to source as
an eligible input only or also use it as an output claim.
Terms and New definitions

Definitions
FSC CFM: FSC claim for products based on inputs from Controlled
Forest Management (CFM) certified management units.

FSC-DIR-40-004 EN
NOTE: The claim can also be presented as “FSC Controlled Forest
Management”.
Current definitions amended
Claim-contributing input: Input material that counts towards the
determination of the FSC Mix or FSC Recycled claims for products
controlled under the percentage or credit system. Eligible claim-
contributing inputs are the following: FSC-certified materials (except
FSC CFM), post-consumer reclaimed materials, and pre-consumer
reclaimed paper (Note: this last category excludes other pre-
consumer reclaimed materials, such as wood and cork). The amount
of input materials received with an FSC Mix x% or FSC Recycled x%
claims that count as claim-contributing input is proportional to the
percentage stated on the supplier’s sales documents (e.g., if 10 kg are
received with an FSC Mix 70% claim, only 7 kg counts as claim-
contributing input). The full amount of input materials received with an
FSC Mix Credit or FSC Recycled Credit claim counts as claim-
contributing input (i.e., 100% of the input amount).
FSC-certified material: Input material that is supplied with an FSC
100%, FSC Mix, FSC CFM, or FSC Recycled claim from an FSC-
certified supplier.
FSC claim: A claim made on sales and delivery documents for FSC-
certified or FSC Controlled Wood output products. The FSC claims
are: FSC 100%, FSC Mix x%, FSC Recycled x%, FSC Mix Credit, FSC
Recycled Credit, FSC CFM, and FSC Controlled Wood.
FSC Mix: FSC claim for products based on inputs of one or more of
the following material categories: FSC 100%, FSC Mix, FSC
Recycled, controlled material, FSC CFM, FSC Controlled Wood, post-
consumer reclaimed, and/or pre-consumer reclaimed.
NOTE: Product groups that are exclusively made of reclaimed
material, controlled material, FSC CFM and/or FSC Controlled Wood
are not eligible to be sold with the FSC Mix claim.
Material category: Class of virgin or reclaimed material that can be
used in FSC product groups. The material categories are the
following: FSC 100%, FSC Mix, FSC Recycled, FSC CFM, FSC
Controlled Wood, controlled material, post-consumer reclaimed, and
pre-consumer reclaimed.
Abbreviations CFM: Controlled Forest Management
Background <FSC-STD-30-010 V3-0 Controlled Forest Management> has

introduced a new output claim (FSC CFM) to incentivize controlled
forest management, and to distinguish it from forest products sourced
as controlled material or FSC Controlled Wood (CW) that conform to
<FSC-STD-40-005 Requirements for Sourcing FSC Controlled
Wood>.

FSC-DIR-40-004 EN
This change in the FSC normative framework means that material
originating from a forest management certified against FSC-STD-30-
010 V2-0 (with the FSC CW claim), will be sourced as FSC CFM, once
the certification is transitioned to V3-0 of the standard. It does not
affect the chain of custody for material previously purchased and sold
as FSC CW.
The objective of this advice note is to provide instructions for
establishing product groups with the FSC CFM claim for the purpose
of controlling the corresponding output claim. The organization may
use the FSC CFM claim in sales documentation, provided the
conditions in this advice note are met.
Advice 1. Establishment of product groups with an FSC CFM claim

1.1 The organization shall establish separate product groups for the
purpose of controlling the FSC CFM claim.
2. Material sourcing
2.1 The organization shall consider the FSC CFM claim as an eligible
input according to the FSC claim specified for the outputs of a
product group. Table B of <FSC-STD-40-004 V3-1 Chain of
Custody Certification> has been amended accordingly.
FSC output claim specified

Eligible inputs
for the product group
FSC 100% FSC 100%
FSC Mix x% / FSC Mix Credit FSC 100%, FSC Mix x%, FSC
Mix Credit, FSC Recycled x%,
FSC Recycled Credit, controlled
material, FSC Controlled Wood,
FSC CFM, pre-consumer
reclaimed, post-consumer
reclaimed.
FSC Recycled x% / FSC FSC Recycled x%, FSC

Recycled Credit Recycled Credit, pre-consumer
reclaimed, post-consumer
reclaimed.
FSC Controlled Wood FSC 100%, FSC Mix x%, FSC

Mix Credit, controlled material,
FSC Controlled Wood, FSC
CFM.
FSC CFM FSC CFM, FSC 100%

FSC-DIR-40-004 EN
3. Sales
3.1 The organization shall consider FSC CFM as an eligible FSC
claim for output products. Table C of <FSC-STD-40-004 V3-1
Chain of Custody Certification> has been amended accordingly.
FSC output FSC control system

claim
specified for
Transfer Percentage
the product Credit system
system system
group
FSC 100% ✓ N/A N/A
FSC Mix x% ✓ ✓ N/A
FSC Recycled
✓ ✓ N/A
x%
FSC Mix Credit ✓ N/A ✓
FSC Recycled
✓ N/A ✓
Credit
✓ ✓
FSC Controlled
Wood ✓ (see Clause (see Clause
5.9) 5.9 and 11.10)
FSC CFM ✓ N/A N/A
3.2 The organization may only sell products with the FSC CFM claim
on sales and delivery documents if the products are raw or semi-
semifinished and the customer is FSC-certified.
3.3 In addition to clause 5.9 of <FSC-STD-40-004 V3-1 Chain of
Custody Certification>, the organization may opt to downgrade
an FSC output claim as presented in Figure 1.

FSC-DIR-40-004 EN
FSC
100%
FSC CFM
FSC Controlled Wood
Figure 1. Rules for downgrading FSC CFM claim.
4. Transfer system
4.1 For claim periods or job orders in which CFM inputs are
combined with other material categories, the organization shall
use the table below to determine the output claim, which amends
Table D of <FSC-STD-40-004 V3-1 Chain of Custody
Certification>.
FSC
Post-cons.
FSC FSC FSC FSC Pre-cons. Pre-cons. Controlled
FSC reclaimed
Inputs Mix Mix Recycled Recycled reclaimed reclaimed Wood and FSC CFM
100% wood and
Credit x% Credit x% wood paper controlled
paper
materials
FSC
FSC 100% FSC Mix 100% FSC CFM
100% FSC Mix
FSC
Credit
Controlled
FSC Mix Credit FSC Mix Credit FSC Mix Credit Wood FSC Controlled
No FSC Wood
FSC Mix x% claims
FSC Mix x% FSC Mix x%
allowed
FSC Mix Credit FSC

FSC Recycled
Recycled FSC Recycled Credit
Credit
Credit
FSC
Recycled
FSC Recycled x% FSC Recycled x%
x%
Pre-cons.
No FSC claims allowed No FSC claims allowed
reclaimed wood
Pre-cons.
reclaimed paper
FSC FSC FSC FSC FSC
Mix Mix Mix Recycled Recycled FSC Recycled 100%
Post-cons. 100% Credit x% Credit x%
reclaimed wood
and paper
FSC Controlled
Wood and
FSC Controlled Wood
controlled FSC
materials Controlled
Wood
No FSC claims allowed
FSC
FSC CFM FSC CFM
CFM
Revised Table D with the inclusion of CFM claim

FSC-DIR-40-004 EN
FSC International – Performance and Standards Unit
Adenauerallee 134
53113 Bonn
Germany
Phone: +49 (0)228 36766 0

Fax: +49 (0)228 36766 65
Email : [email protected]
FSC-DIR-40-004 EN

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Directive

Page 1 of 67 FSC Directive on Chain of Custody Certification

Dates: Approval date: 30 April 2024

Timeframes: Transition period: not applicable

Contact for FSC International – Performance and Standards Unit

Phone: +49 (0)228 36766 0

Publication date: 30 April 2024

Version Description Date

V1-0 Not applicable Not applicable

® 2024 Forest Stewardship Council, A.C. All Rights Reserved

Page 2 of 67 FSC Directive on Chain of Custody Certification

The intention of this document is to standardize understanding and implementation of requirements by

Note on use of this directive

Page 3 of 67 FSC Directive on Chain of Custody Certification

C. Terms and definitions 6

Part 1 General Issues 7

Part 2 FSC Advices 8

ADVICE 40-004-01 FSC certified CoC contractors

ADVICE 40-004-04 Use of uncontrolled co-products (Withdrawn)

ADVICE 40-004-05 Identification of FSC claims on sales and delivery documents

ADVICE 40-004-06 Which components of a product need to be certified?

ADVICE 40-004-08 Non-conforming product

ADVICE 40-004-09 Minor components

ADVICE 40-004-10 Access to information required by timber legality legislations

ADVICE 40-004-11 Trade and customs laws

ADVICE 40-004-12 Pre-consumer reclaimed wood compliance with the EUTR

ADVICE 40-004-13 Classification of pre-consumer reclaimed paper as equivalent to FSC

ADVICE-40-004-14 Supply chain integrity

ADVICE-40-004-15 Neutral materials that cannot be distinguished from FSC certified

ADVICE-40-004-16 Disassociated organizations operating as outsourcing contractors

ADVICE-40-004-17 Claiming 100% reclaimed products as FSC Mix

Page 4 of 67 FSC Directive on Chain of Custody Certification

ADVICE-40-004-18 Addressing false FSC claims on products/projects containing material

ADVICE-40-004-19 Species information in FSC Product Groups (Withdrawn)

ADVICE-40-004-20 Confirmation of origin for FSC certified Paulownia products

ADVICE-40-004-20 Confirmation of origin for FSC certified products from species of a

ADVICE-40-004-23 Evaluation of contractors against the FSC core labour requirements

ADVICE-40-004-24 Evaluation of FSC core labour requirements using FSC approved

ADVICE-40-004-25 Requirements for the organization to provide information to the

Page 5 of 67 FSC Directive on Chain of Custody Certification

FSC-STD-40-004 Standard for Chain of Custody Certification

FSC-STD-20-011 Chain of Custody Evaluations Standard

FSC-STD-40-005 Requirements for Sourcing FSC Controlled Wood Standard

FSC-PRO-01-001 Development and Revision of FSC Normative Documents

Advice Note: errata or addenda to normative documents.

Page 6 of 67 FSC Directive on Chain of Custody Certification

Page 7 of 67 FSC Directive on Chain of Custody Certification

Normative reference FSC-STD-40-004 V2-1 Section 12 and FSC-STD-40-004 V3-0

Page 8 of 67 FSC Directive on Chain of Custody Certification

Table 1: Outsourcing scenarios dealt

Page 9 of 67 FSC Directive on Chain of Custody Certification

Contracting Using FSC certified

1. Providing contract work for non-FSC certified CoC

Page 10 of 67 FSC Directive on Chain of Custody Certification

Page 11 of 67 FSC Directive on Chain of Custody Certification

Normative reference FSC-STD-40-004 V2-0 Clause 10.1.1

Effective date March 2005

Background A forest product manufacture is often a continuous process. At the

Page 12 of 67 FSC Directive on Chain of Custody Certification