Background
FSC introduced FSC-ADVICE-40-004-23 Vl-0 Evaluation of contractors against the FSC core labour requirements and FSC-ADVICE-20-011-16 Vl-0 Evaluation of contractors against the FSC core labour requirements in 2023, two advice notes which include the same content, to provide clear instructions on how the FSC core labour requirements in FSC-STD-40-004 V3-l Chain of Custody Certification must be applied to contractors operating under outsourcing agreements. In previous communications, these have been referred to as 'Advice Note 23'.
Since their effective dates, various stakeholder concerns on the practical implications have been raised, requesting further clarity on the content of the advice notes, and the associated timelines for implementation. These concerns have heavily focused on the risk classification of outsourcers and evaluation requirements, referring to the indices introduced in clause 2.2e).
To address these concerns, while maintaining the original objective of providing clear instructions on how the FSC core labour requirements have to be applied to contractors operating under outsourcing agreements, the advice notes will be revised. To address the immediate concerns, a derogation has been published to waive certain requirements for certification bodies. You can find more information on the derogation here.
FSC UK is aware that many UK stakeholders were concerned by the implications of Advice Note 23 and we hope that this consultation will provide a valuable opportunity to input into the revision of this.
Advice Notes
The revision of the advice notes intends to ensure clarity, and address the risk assessment classification concerns, providing more flexibility to certification bodies (CB). Additionally, to aid clarification, only content relevant to requirements of the related standards in the Directives (FSC-DIR-40-004 and FSC-DIR-20-0ll) will remain. This means aspects relevant to certificate holders and applicants will be kept in DIR-40-004, whereas aspects relevant for CBs will be kept only in DIR-20-0ll. This means there will be a slight change to the clause numbers, in particular for FSC-ADVICE-20-011-16.
The draft provides revisions of the content of the original versions, including the sections of: scope, background, normative references, relevant terms and definitions, advice, and a new 'Examples' section in FSC-ADVICE-20-011-16 only.
Process
This revision follows an accelerated revision process as described in FSC-PRO-01-001 The Development and Revision of FSC Requirements.
Consultation
The consultation will be opened on the FSC consultation platform from 01 March 2024 until 21 March 2024 (please note: original closing date was 15 March but this has now been extended). To ensure the revised versions can be published and effective in a timely manner, the Director General has approved the reduced consultation time in this instance.
Contact
If you have any comments or questions, please contact the Chain of Custody team here.