What is new?
The changes to the directive introduce a new advice note and changes an old advice note.
In both cases, the directive now requires that when an “old NRA” is used, the risk assessment category for illegally harvested wood must be replaced by the corresponding category of the new risk assessment.
Both advice notes include a transition period in order to give time to comply with the revised requirements. The new advice note’s transition period ends 31 December 2017. The old advice note’s transition period ends 30 September 2017.
What does this mean for Certificate Holders?
In some countries, the advice notes introduce a change in risk designation from low to specified risk.
Certificate Holders using V3-1 of the controlled wood standard: Control measures will be required to mitigate the risk if the risk designation is specified risk.
Certificate Holders using V2-1 of the controlled wood standard: Field verification will be needed for category 1 (illegally harvested wood) in order to source controlled wood using the old version of the standard if the risk designation is no longer “low risk” in the new risk assessment.
Why change the requirements now?
These changes ensure that the FSC framework is fully aligned with timber legality legislation. Currently, the FSC framework is not aligned with this legislation where companies are using “old NRAs”. This is because “old NRAs” were developed without considering the full scope of the timber legality legislation. The processes of alignment began in 2012, but the recent changes are not sufficient, and there have been delays in replacing “old NRAs” with new risk assessments.