Individual member, Environmental North
What has Control Achieved?
FSC controlled wood is material from acceptable sources that can be mixed with FSC-certified material in products that carry the FSC Mix label. FSC risk assessments are used to determine the risk of an organization obtaining material from unacceptable sources when sourcing controlled wood. Currently, 90 per cent of risk assessments are undertaken by the companies themselves. If a company determines that the risk is low, then they can receive FSC certification according to the controlled wood standard.
This system, which has been amended a number of times in a number of ways, has been controversial from its beginning. Recently, the system has changed to allow a company to transfer credits from one site where FSC-certified material exceeds 70 per cent, to sites where FSC-certified material is less than 70 per cent. While the company, over all its sites, maintains a 70/30 ratio, individual products could, theoretically, contain 100 per cent controlled wood.
It is sobering that 90 per cent of FSC controlled wood certificates are still granted based on company risk assessments. Motion 51, Strengthening the Controlled Wood System, was passed by an overwhelming majority at the FSC General Assembly in 2011. This motion set a 2012 deadline for the end of company-based risk assessments. This change has been fought, and resisted, at every juncture.
Controlled Wood in Australia: A Case Study
FSC Australia was formerly established in 2005. I was a founding board member, and I have served as chair of the board on two occasions.
Early on, FSC Australia had to deal with a major controversy surrounding Australia’s largest paper manufacturing company, who was in conflict with environmental NGOs (ENGOs). The company sourced FSC-certified imported pulp, but its Australian-sourced native-forest pulp only came from FSC controlled wood sources.
However, the company did not undertake a required verification process and, thus, incorrectly used the FSC Mix label on its paper product. A complaint was lodged by an NGO claiming the company was being supplied with material from old-growth forests and endangered species habitats that took years to resolve. As a result of this issue, I was mandated to represent the Australian ENGOs at the FSC General Assembly in 2008, and present a motion to phase out controlled wood on a company, rather than system-wide, basis.
Following a cross-chamber discourse two motions were passed.
- Motion 2008/23 mandated that the controlled wood system be evaluated, and that three options be tested, including elimination, linkage to forest management uptake, and a completely different approach to facilitating FSC uptake.
- Motion 2008/24 required FSC to address credibility issues surrounding controlled wood, with specific focus on stakeholder consultations, transparency, and high conservation values (HCVs).
Neither of these motions were fully implemented, but the work undertaken set the foundations for the revision of the controlled wood system embodied in Motion 2011/51.
Domestically, Australia undertook a national risk assessment process, and found that HCVs occurred in all bioregions and conversion was occurring in two Australian states. To help organizations with their verification process, FSC Australia wrote a HCV evaluation framework that is normative for all organizations seeking FSC controlled wood certification in the country.
Despite these steps, sourcing controlled wood from native forests remains controversial in Australia, with active disputes in both Western Australia and New South Wales.
Controlled Wood at the FSC General Assembly 2017
It appears to me that we have arrived back at the beginning, with a very similar motion to the one I took to the FSC General Assembly in 2008 being submitted, along with three other controlled wood motions, for this year’s general assembly. I have proposed motion 2017/56 to try and stabilize the new controlled wood system, because it is far from clear that FSC can ensure compliance under these new guidelines. That this has occurred represents a huge failure for FSC – why has it happened?
Fundamentally, most companies providing controlled wood to the large North American market are hostile to FSC. The large paper manufacturers prefer the company-based risk assessment model because they are operating in a ‘don’t ask, don’t tell’ environment. Despite trying for nearly 10 years, FSC US and FSC Canada have failed to complete national risk assessments. At this year’s general assembly the FSC membership must give very clear signals that the new system, which FSC has taken eight years to implement, must be fully accepted, or FSC may not continue.
Currently, controlled wood is not controlled, the FSC Mix label misrepresents the truth, and the promise of FSC 20 years ago to provide a gold standard of sustainability has not been met.
Assuming that FSC can stabilize the system and ensure compliance with the new normative framework, FSC desperately needs a strategy for how, or if, controlled wood should remain part of the FSC normative framework. There has been much thought given to this over the years, but views amongst the FSC membership are sharply divided. Some members want controlled wood to remain part of the system with as few controls as possible, and some want it removed from the system immediately.
There is strong support from all chambers to increase FSC forest management certification. There is growing support within the social and environment chambers for two options: 1. FSC provides a pathway for companies out of controlled wood over a 10 year period, or 2. FSC limits the amount of time individual companies can source controlled wood material, with a sliding scale of increasing FSC-certified inputs over time.
Whichever strategy is developed, it is in all members’ interests to grow the amount of FSC-certified material and limit the use of controlled wood within the system.