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 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 introducing requirements for the control of pre-consumer reclaimed wood in order to ensure FSC’s products conformance with the EUTR, for products placed on the European market.

Main differences between first and second draft:
The first draft required all certificate holders located in countries without applicable timber legality legislation that use pre-consumer reclaimed wood (except paper scraps) in the manufacturing of FSC certified products to demonstrate that this material is controlled for Controlled Wood category 1 (illegally harvested wood). The second draft limits the application of the Advice note to the companies directly involved in the trade of FSC certified products to the European Union.

Who should provide comments?
This Advice note is mainly developed for COC certificate holders located in countries under the scope of the EUTR and companies exporting FSC products to the European Union.

FSC would like to thank everyone who submitted comments on the first draft. The feedback has been analysed and incorporated to the second draft where applicable. A consultation report has been drafted summarising the results of the consultation and explaining how FSC is addressing the stakeholder comments (please note that the Advice note was consulted together with other COC and Controlled Wood Advice notes).

The second draft will be under consultation until 12 April 2014. Please use the comment form available here and send your comments to Dorothee Jung at d.jung@fsc.org.

Details of all consultations currently open can be found here.