New derogation on the Evaluation of Contractors against the FSC Core Labour Requirements

Background

FSC introduced FSC-ADVICE-40-004-23 V1-0 Evaluation of contractors against the FSC core labour requirements and FSC-ADVICE-20-011-16 V1-0 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 V3-1 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 of 1st July 2023, 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).
 

Revision of Advice Notes 

To address stakeholder 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. The revision process will following an accelerated process according to FSC-PRO-01001 V4-0 The Development and Revision of FSC Requirements. This will include a consultation on the FSC consultation platform from 1st March 2024. You can find more information on the consultation here.

Derogation

To address the current concerns, whilst the advice notes are revised, it was deemed necessary to provide a normative reference in the form of a derogation, to waive requirements relevant to the certification bodies. The derogation is effective immediately (from 14th February 2024) and waives requirements in Sections 2 to 5 in both advice notes. As section 1 of the advice notes remains effective for certificate holders, certification bodies are required to evaluate contractors using the information provided in the self-assessment, following the general provisions in clause 11.3 of FSC-STD-20-011 V4-2 Chain of Custody Evaluations. 

For more information, see FSC-DER-2024-002 below.