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CASE STUDY FOR FSC SUPPLY CHAIN INTEGRITY PROJECT (SCIP)

FSC’s rapid response ensures inaccurate claims are dealt with swiftly

In May of 2017, a German organisation, Stiftung Warentest contacted FSC with potential infringements within the FSC system. Stiftung Warentest is one of the leading consumer rights and product test organisations in Germany, and is highly regarded by consumers and media alike.

Stiftung Warentest had done tests on FSC-certified products, and found inconsistencies in three of them - two different types of outdoor wooden tiles and a garden bench. Stiftung Warentest then contacted FSC to notify us of these inconsistencies. The tiles were manufactured by one company and the bench by another, and the two incidents were unrelated.

Rapid response

FSC immediately sprang into action, with FSC Germany doing initial checks on the information received and formulating the issue that needed to be investigated. FSC Germany then contacted the FSC Supply Chain Integrity Manager, Emily Crumley who in turn reported the incident to ASI immediately.

ASI then noted the incident within their incident registry and started initial investigations into the allegations. The incidents were arranged according to whether they were critical or major, both to receive rapid response. ASI also contacted the relevant certification bodies to inform them of the potential infringements, and then initiated further investigation to find out what exactly had occurred.

During this time, Stiftung Warentest were kept updated on all actions, and ASI also requested some more information on the issues from them.

ASI, along with the relevant certification bodies, set and performed short-notice audits on each of the certificate holders responsible for the products with potential inaccuracies, requested audit reports and supporting documentation, and also sent product samples for fibre testing to determine whether the products were what they claimed to be and where they claimed to be from. 

Outcomes and actions taken

After the various investigations had taken place, it was determined that both incidents regarding the tiles and the garden bench had merit. The garden bench manufacturer’s FSC certification was terminated due to volume and species mismatches. 

The tile manufacturer was found to have committed a trademark infringement, and relabelling of that FSC-certified product is to take place. A compliance audit for the tile manufacturer was also performed in August 2017. 

Once the investigation had concluded and the actions had been determined, Stiftung Warentest were immediately informed.

Timeline

10 May

• First emails from Stiftung Warentest sent to FSC

11 May

• Press office informs FSC Germany of the incidents

• FSC Germany collates the info and forwards to the SCIP Manager

12 May

• SCIP Manager informs ASI about the incidents

• Incidents are recorded on ASI’s registry

• Investigations into incidents begins

15 May

• First update from ASI received

17 May

• Second update from ASI received

26 May

• Third update from ASI received

5 June

• Short-notice audit for distributor of garden bench performed

1 August

• Short-notice audit for manufacturer of garden bench performed

May - July

• Investigations continue for tile manufacturer

• Trademark infringement corrective action requests doled out

• Certificate holder to relabel product

• Compliance audit scheduled for August

4 August

• FSC certification for manufacturer of garden bench terminated

• Stiftung Warentest immediately notified of the actions

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FACT SHEET FOR FSC SCIP PROJECT

Strengthening the FSC Supply Chain - fibre testing

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What is Supply Chain Integrity?

FSC is dedicated to providing a credible system for responsible forest products. In some supply chains, there are allegations that the FSC system is being misused or contaminated with non-FSC-certified materials. These assertions are taken very seriously, and FSC has enforced its processes to investigate the claims. Should risks be confirmed, FSC will implement additional actions to protect the system and ensure supply chain integrity.

FSC has a long-term plan to systematically address integrity risks in the supply chains of our certificate holders. As part of this plan, we are taking three immediate actions to address misuse of the system; by 

• thorough investigation of product groups or species suspected of having an increased risk of misleading FSC claims;

• implementation of mandatory transaction verification to address inaccuracies of FSC transactions in confirmed high-risk supply chains; and 

• randomized fibre tests of FSC-certified products to identify possible species used in the product, and potentially the country or region of harvest as a spot-check mechanism.

What is transaction verification?

The revised Chain-of-Custody standard (FSC-STD-40-001 V3) has included a new criterion for transaction verification. The intention of this criterion is to ensure that FSC systematically investigates high-risk product types, species and regions, and limits the amount of inaccurate transactions.

Transaction verification is a process of comparing and then verifying all transactions within a specific product type, group or region over a given time period.

How does transaction verification work?

There are currently four options for verification. The verification can be done via the Online Claims Platform (OCP), where certificate holders will register, connect with suppliers, enter relevant data from their invoice directly to the platform (no financial information required), and the transaction is automatically verified once the suppliers validate their claim.

A second option includes the OCP where the certificate holder will also register, connect with suppliers and enter relevant data from their invoice directly to the platform but verification of transactions is completed by ASI instead of automatically.

Alternatively, a desk audit will allow certificate holders to fill in a downloadable spreadsheet template and send that on to their certification bodies, or they can opt to do an on-site audit where transaction information is collected manually by the auditor for ASI to verify.

Fibre testing is a tool of transaction verification which will also be utilised by FSC. Random fibre testing of FSC-certified products deriving from high-risk supply chains will be performed as a spot-check mechanism. 

​

What is fibre testing?

Fibre testing encompasses a range of forensic wood scientific techniques to identify wood and wood-derived products, and involves comparing test specimens to scientifically verified reference material. In this way, depending on the type of fibre testing, the botanical and/or geographic origin of a product can usually be verified. 

Fibre testing can be applied to various categories of wood such as solid wood, plywood and veneers, and engineered wood products, as well as pulp-based products, including paper, cardboard, fibreboards, and even loose pulp. 

Why is FSC utilising fibre testing?

When used in conjunction with transaction verification (comparing volumes of products bought and sold) in order to map supply chains, fibre testing is a very effective quality control / assurance measure in that it is possible to identify inaccurate FSC claims and consequently deter fraud. 

It is also widely accepted in the scientific and legal communities as a way to identify various wood products and where they come from.

Methods of fibre testing

There are a range of methods from forensic wood science that fall under the fibre testing umbrella, and FSC typically employs three of these methods. The FSC product claim makes it easier to assist in transaction verification through these methods of fibre testing by making it clear whether the species and/or origin of the materials in the final product are acceptable.

Traditional wood anatomy testing depends on microscopy, where thin sections of the wood product (or a suspension of the pulp sample) are placed under a microscope. The detailed cellular features of the unknown specimen are studied and these are then compared to scientifically verified reference samples. Using this method, the species or genus of the wood, and sometimes the origin, can be determined.

For DNA testing, the outer surfaces of a specimen are cut away to display the unexposed surfaces and to eliminate contaminants. The DNA is then extracted, isolated and purified (or amplified). Depending on the type of DNA testing, the geographic origin of the wood product, the species, or even matches between individual boards or stumps can be established depending on the availability of scientifically verified DNA reference libraries.

Stable isotope testing is the third method commonly utilised by FSC, wherein a wood sample is chemically processed to the point where the basic chemical building blocks can be analysed. When ratios of common isotopes to stable isotopes in a specimen are compared to reference samples that have been scientifically verified, the geographic origin of the wood product can be ascertained. 

Requirements for submitting samples for fibre testing

If you’d like to submit a sample for fibre testing, please note the following procedure:

• Contact Emily Crumley, Supply Chain Integrity Manager at e.crumley@fsc.org to discuss your requirements.

• Emily will send through a service agreement submittal form.

• Fill in the submittal form and submit electronically to Emily, and to Flavio Ruffinatto at flavio.ruffinatto@unito.it.

• Ship sample to the lab (details contained in the submittal form), along with the hardcopy of the submittal form.

• Once results are available, they will be shared with the stakeholder and depending on the result, also the certification body.

Good-to-know:

• Fibre testing costs $100 per sample.

• FSC will sponsor 5 tests for each network partner per year.

• Network partners can choose to use the free fibre testing for certificate holders or themselves.

To submit a product please note:

• Fibre products: sample must be the size of an A5 sheet or bigger; 2-3 sheets are preferred.

• Solid wood products or fibreboard: sample must be the size of a deck of cards or bigger.

Additional information

For additional information, please contact Emily Crumley, the Supply Chain Integrity Manager at e.crumley@fsc.org.