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SCS FSC® Chain-of-Custody Guidance
for Certification of Multiple Sites
Table of Contents
I. Central Office Procedures .......................................................................................................................... 2
A.
Central Office and Certificate Manager ............................................................................................ 2
B.
Participation of Eligible Sites............................................................................................................. 2
C.
Training Plan ..................................................................................................................................... 2
D.
Central Office Audit Program (Internal Audit Program) ................................................................... 3
E.
Record Keeping ................................................................................................................................. 3
II. Central Office Administration ................................................................................................................... 4
A.
Consent Forms (where applicable) ................................................................................................... 4
B.
Training Program............................................................................................................................... 4
C.
Trademarks Management................................................................................................................. 4
III. Management of Participating Sites.......................................................................................................... 5
A.
Provision of Information and Documents ......................................................................................... 5
B.
Number and Increase of Participating Sites...................................................................................... 6
C.
Requirements for Participating Sites ................................................................................................ 7
IV. Central Office Audit Program................................................................................................................... 7
A.
The Central Office Audit Program (Internal Audit Program) ............................................................ 7
B.
Qualifications of Central Office Auditors (Internal Auditors) ........................................................... 8
C.
Requirements for CAR Issuance by the Central Office ..................................................................... 9
D.
Central Office Internal Audit Reporting Requirements and Annual Review .................................. 10
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I. Central Office Procedures
A. Central Office and Certificate Manager
Requirements 4.1, 4.2, 5.1.1, and 5.2.1
Every Multi-site or Group organization must designate a particular site, department, or function to be
the Central Office (CO). This CO will administer the certificate and ensure the requirements of FSC-STD40-003 are met, as well as ensure that the relevant certification requirements for each Participating Site
(PS) are met. As part of this responsibility, the CO must be able to demonstrate that it has the necessary
technical and human resources to manage the number of PS under the scope of the certificate.
The CO must assign a Certificate Manager with legal or management authority and technical support
necessary to implement the responsibilities specified in the multiple sites standard and manage the
number of Participating Sites. The Certificate Manager must be someone with professional experience,
knowledge, and competence to manage the certificate and implement the requirements of the
applicable FSC standards at each PS.
B. Participation of Eligible Sites
Requirements 4.4 and 5.1.2
An organization is not required to include all of their associated sites on their certificate. A Central Office
may also hold or administer more than one Multi-site or Group certificate. In both cases, clear
procedures must be written to ensure that only the Participating Sites (sites included in the respective
FSC certificate) claim their products as FSC-certified and use the FSC trademarks. The CO procedures
must also cover the organization’s process for adding/including and removing Participating Sites (PS),
and procedures describing the measures taken to prevent the mixing of uncertified products from noncertified sites into certified product lines of Participating Sites.
C. Training Plan
Requirements 5.1.3, 5.2.3, and 5.2.4
The CO is responsible for establishing a training program for both the CO’s auditors (those persons who
will conduct the Central Office (aka internal) audits—see D. below) as well as the relevant personnel at
each PS. The plan for the training program must cover the latest version of all FSC Policies and Standards
applicable to the scope of the certificate and any applicable CO procedures. Participating Site
representatives and other relevant personnel must be trained to ensure the COC certification
requirements are being followed. CO auditors (internal auditors) must be trained to ensure CO audits
(internal audits) are conducted objectively and cover the full scope of the certificate at each PS.
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For certificates with more than 20 Participating Sites, and where the Participating Sites are not linked
through common ownership, the internal auditors must be in possession of a formal ISO 9001, ISO
14001, or OHSAS 18001 lead auditor certificate achieved through a recognized accredited training
course. Recognized course certificates include those accepted by auditor registration schemes such as
IRCA and RABQSA.
D. Central Office Audit Program (Internal Audit Program)
Requirements 4.5 and 4.6
All Participating Sites must be included in a Central Office Audit Program (internal audit program)
developed and implemented by the CO. The only exception is in cases where SCS audits 100% of PS; only
then is the CO exempt from implementing an internal audit program. For all cases where SCS conducts
external audits of a sample of PS only (i.e. less than 100% of PS), the CO procedures must include a plan
for the internal audit program. For further information on the CO Audit Program, please see Section IV
below.
E. Record Keeping
Requirements 5.1.4 and 5.1.5
The CO is required to maintain up-to-date records of all PS under the scope of the certificate, including:
a. A list of all Participating Sites, with the following information*:
i. Contact information (name, phone number, email address, physical address);
ii. Appointed Participating Site’s COC representative;
iii. Date of entry into the Multi-site or Group COC certificate;
iv. Date of withdrawal from the scope of the certificate (if applicable);
v. The certificate sub-code assigned;
vi. The site activity (e.g. primary processor, secondary processor, trader, printer,
retailer);
vii. Indication if the PS implements a Controlled Wood verification program, Supplier
verification program for reclaimed materials, and/or outsourcing;
viii. Indication if the PS has signed a declaration stating that no material has been FSC
labeled, sourced as controlled material, or sold as FSC certified or FSC Controlled
Wood since the last internal audit.
b. Where applicable, the signed consent form or contract of each PS (see Section II below);
c. Records demonstrating the scope of COC certification for each Participating Site;
d. Records of all internal audits (see Section IV below), including:
i. Nonconformities identified in such audits;
ii. Actions taken to correct them;
iii. CO’s annual review of its audit program and procedures;
e. Records of training provided by, or on behalf of, the CO, and of participation therein;
f. A list of the CO’s auditors and their qualifications.
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Note that records must be archived for at least five (5) years and be made available to SCS upon request.
*SCS has a template available to facilitate the creation of a list of Participating Sites, covering the
information required in clause (a) above. Please ask for it if you are interested.
II. Central Office Administration
A. Consent Forms (where applicable)
Requirement 4.3
A consent form or contract is necessary for any Multi-site or Group COC certificate where the
Participating Sites are not linked through common ownership. A form or contract must be signed by each
PS in the certificate scope and must include the following:
a. Acknowledgement and agreement to the general obligations and responsibilities for
participation in the Multi-site or Group COC certificate, as stipulated in the 40-003 standard, the
certification contract, and the documented procedures of the CO;
b. Agreement to conform to all applicable FSC certification requirements and the documented
contractual obligations, corrective action requests, and procedures of the CO;
c. Authorization of the CO to apply for and administer the FSC Chain of Custody certification on
behalf of the PS;
d. Acknowledgement of mutual responsibility for the maintenance of the certificate, where
nonconformities identified at the level of the PS or the CO may result in corrective action
requests, certificate suspension, and/or certificate withdrawal.
B. Training Program
The plan for the training program included in the CO procedures (see Section I above) must be
implemented and maintained such that all internal auditors and relevant PS staff are aware of the latest
FSC Policies and Standards and are equipped to meet the requirements. Initial training must be
completed prior to the first evaluation audit from SCS, and it must follow the training plan thereafter.
C. Trademarks Management
Requirements in FSC-STD-50-001, Annex 2, Section 1
In addition to the regular trademark requirements found in FSC-STD-40-004 and FSC-STD-50-001, the CO
is responsible for enforcing the additional Multi-site and Group certificate holders’ requirements found
in part 1 of FSC-STD-50-001, Annex 2. The CO must ensure that all uses of the FSC trademarks (i.e., the
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initials FSC, the name Forest Stewardship Council, and the FSC checkmark-and-tree logo) by any PS in
any application, such as an on-product stamp, a web site, on-site poster, or a print ad, is approved by
SCS. Although the Central Office / Certificate Manager is encouraged to seek the approval on behalf of
the PS, flexible arrangements can be made upon request. At minimum, the CO should have access to all
logo approval records. Sub-codes of Participating Sites cannot be added to the FSC trademark license
code.
For Group COC Certificates, the CO must not produce any document similar to an FSC certificate for the
Participating Sites. If individual membership documents are issued, no other forest certification
schemes’ marks or names can appear and these statements must be included:
a. “Managing the FSC certification program of [name of group]”
b. “Group certification by SCS”
III. Management of Participating Sites
A. Provision of Information and Documents
Requirement 5.4.1
It is the Central Office’s responsibility to:
a. Provide each PS with a copy of the FSC Chain of Custody standard (FSC-STD-40-004), the FSC
Trademarks standard (FSC-STD-50-001), and any other relevant certification standards (e.g., FSCSTD-40-005, FSC-STD-40-007), all available from SCS or for download at
https://ic.fsc.org/standards.340.htm;
b. Provide each PS with a copy of the documented (most up-to-date) CO procedures;
c. Ensure that all PS representatives understand that SCS and/or SCS’ accreditation body, ASI, has
the right to access any site covered under the certificate for the purposes of evaluating the
Chain of Custody program with or without advanced notice;
d. Ensure that all PS representatives understand which information SCS, ASI and/or FSC may collect
and publish for public viewing, including: PS name and address(es), email, phone, certificate
sub-code, certificate issuance and expiration dates, the standards against which PS is certified,
PS contact person, product groups (including product class, product type, species where
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applicable, material categories), and Controlled Wood Risk Assessment(s) and Controlled Wood
Summary Certification Report, where applicable1;
e. Ensure that all PS representatives understand which obligations must be met in order to
participate in the certificate, including which nonconforming actions may result in a site’s
exclusion from the certificate.
This information and documentation may be kept online or on an intra-organizational server in order to
ease the administrative burden, as long as it can be viewed at-will from every PS, and demonstrated
upon request of any auditor at each and every site audit.
B. Number and Increase of Participating Sites
Requirements 5.5.1 – 5.5.7
After each external audit (for example, initial evaluation, annual surveillance, or expansion of scope),
SCS will approve an annual growth rate for any Multi-site or Group certificate which maintains an
internal audit program. The growth rate will be indicated in the audit report from 0-100% based on SCS’
assessment of the ability of the CO to manage the number of PS. The factors considered to determine
the growth rate include the number of nonconformities issued, the past growth rate, the experience and
number of qualified auditors, and other risk factors. The growth rate is determined at SCS’ sole
discretion.
Keep in mind that Group COC certificates are limited to a maximum number of 500 Participating Sites.
Also, Multi-site and Group COC certificates without a Central Office Audit (internal audit) Program can
only add new Participating Sites to the scope of the certificate after all applicant sites have been audited
and approved by SCS.
For those certificates with an approved growth rate, the CO may add a new PS at any time until they
reach the annual growth limit approved by SCS. To add a new PS to the certificate, the CO must submit
the initial internal audit report for each applicant site to SCS (see Section IV below). New PS are
considered certified after the site information is published in the FSC database.
If the addition of PS exceeds the approved growth limit, then SCS must conduct a sample-based audit of
all of the new sites added since the previous external audit before the new sites which exceed the limit
can be added to the certificate. For example:
1
By signing the FSC Trademark License Agreement, the Licensee agrees that FSC Global Development as well as the FSC
Network may process and use the name and address as well as email address and telephone number for direct marketing
purposes, i.e. to promote the FSC Certification Scheme and FSC AC’s mission to promote responsible management of the
world’s forests. The Licensee may object to this use of the contact data at any time by sending an email to [email protected].
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A Multi-site certificate has 30 PS and a growth limit of 30% (10 additional PS). The CO conducts
initial internal audits of 10 new PS and those are added to the certificate, thus reaching the
growth limit. The CO then wishes to add 5 more new PS, so the first step is to conduct initial
internal audits of those 5 sites. However, at this point SCS is required to conduct a sample-based
external Expansion of Scope audit of all 15 new PS (and also audit the CO) before the second
group of 5 new sites can be added to the certificate.
To remove a PS from the certificate, the CO must notify SCS in writing within three working days of the
PS being considered removed by the CO. The PS will then be removed from the FSC database.
C. Requirements for Participating Sites
Requirements 6.1 and 6.2
Although the CO is responsible for ensuring that most of the requirements of the 40-003 standard are
met, PS also have some responsibilities. Each PS must:
a. Assign a representative who has authority to ensure that all applicable requirements are met
and procedures are followed, and who serves as the contact for the CO;
b. Conform to all applicable FSC Chain of Custody requirements;
c. Conform to all applicable participation requirements as specified by the CO;
d. Respond to all requests from the CO or SCS;
e. Inform the CO of all changes that may affect conformance to certification or participation
requirements (such as changes in ownership, staff, procedures, or processes);
f. Provide full cooperation and assistance with respect to the completion of audits performed by
the CO, SCS, or ASI;
g. Ensure that all CARs issued by the CO or SCS are addressed within their established timelines;
h. Use their assigned sub-code on sales and transport documents for FSC-certified products.
Details on the assigned sub-code to be used by each PS will be provided by FSC.
IV. Central Office Audit Program
A. The Central Office Audit Program (Internal Audit Program)
Requirements 5.3.1, 5.3.2, 5.3.3, and 5.3.5
The Central Office is responsible for ensuring that all sites included in their certificate meet all relevant
Chain of Custody requirements. There are two options for ensuring this: a) SCS can audit 100% of
Participating Sites each year; or b) the CO can implement an internal audit program for its PS, and SCS
will then audit only a sample of PS with each external audit. This section covers requirements for those
certificates which will implement an internal audit program.
The Central Office must conduct an audit prior to an applicant site’s inclusion as a Participating Site
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(initial internal audit). In the case of initial evaluation audits, the CO must complete initial internal audits
of all PS prior to SCS conducting our external sample-based audit. Central Office audits of each PS must
also be conducted at least annually. If a Participating Site also serves as the Central Office, then the
operational aspect of that site (e.g. those requirements specified in 40-004) do not need to be included
in the internal audit program. However, those operational aspects will be annually audited by SCS.
The CO may waive the annual internal audit for any PS under the following conditions:
a. The site has already been audited by SCS in the same calendar year; AND/OR
b. The site has submitted a signed declaration to the CO stating that no material has been FSC
labeled, sourced as controlled material, or sold as FSC certified or FSC Controlled Wood since
the last internal audit.
NOTE: The Central Office cannot waive more than two consecutive annual internal audits for any site.
The default for internal audits is that they are to be conducted on-site at each PS. However, internal
audits may be conducted remotely (“desk audit”) instead of on-site for any PS that is:
a. Trading in finished and labelled products (e.g. retailers);
b. Trading products without taking physical possession;
c. Exclusively handling certified products made of a single input material (e.g. the whole site
production is FSC 100%).
B. Qualifications of Central Office Auditors (Internal Auditors)
Requirement 5.2.2
The Central Office is responsible for ensuring that internal auditors are qualified and have the training
and experience required in order to conduct audits of Participating Sites. The following must be
considered in the selection of CO auditors:
a. The professional experience and ability to evaluate a Participating Site’s conformance with the
Chain of Custody standard, and other FSC standards as relevant (e.g., STD-40-005, STD-40-007);
b. Fluency in the language used at the site (or accompaniment by a translator);
c. Objectivity and impartiality: Auditors may not audit activities for which they are directly
responsible to handle or execute or participate in, or for which they have any other conflict of
interest. (For example, a person who is responsible for material handling at a facility on a day to
day or operational basis cannot be an internal auditor and audit their facility against the
material handling requirements in 40-004).
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C. Requirements for CAR Issuance by the Central Office
Requirements 5.3.6 and Annex B
The Central Office must have the formal authority to issue Corrective Action Requests (CARs) to
Participating Sites. The CO auditor must evaluate a nonconformity to determine if it constitutes a minor
or major CAR. The auditor must consider the impact of the nonconformity on the supply chain and the
credibility of the FSC system when evaluating it.
A nonconformity can be considered minor if:
a.
b.
c.
d.
It is a temporary lapse; or
It is unusual/non-systematic; or
The impacts of the nonconformity are limited in their temporal and organizational scale; and
It does not result in a fundamental failure to achieve the objective of the relevant requirement.
A nonconformity must be considered major if it results in, or is likely to result in, a fundamental failure
of the COC system at the Participating Site. Such fundamental failure is indicated by nonconformity(ies)
which:
a.
b.
c.
d.
Continue over a long period of time; or
Are repeated or systematic; or
Affect a wide range of the production or a large proportion of workers; or
Are not corrected or adequately addressed by the Participating Sites once it has been identified.
The CO may also issue observations to PS. An observation does not in itself constitute a nonconformity,
but the auditor has identified a potential problem which may lead to a future nonconformity if not
addressed by the PS.
CAR closure must be implemented within the following timelines:
a. Minor CARs – one year OR by the next annual Central Office audit (whichever happens first);
b. Major CARs – three months.
Minor CARs that are not closed within the established timelines must be upgraded to major CARs.
The decision regarding whether or not a site is eligible to be included or remain in the scope of the
certificate must be determined according to the outcomes of Central Office audits. If any of the
following occurs, then the site must be immediately removed from the Multi-site or Group COC
certificate:
a. Major CARs have not been addressed within established timelines;
b. Five (5) or more major CARs are issued for a single standard (e.g. 40-004 or 40-005) to a
Participating Site during a Central Office audit.
NOTE: If major CARs are issued during the initial audit by the Central Office, then the applicant site
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cannot be included in the scope of the Multi-site or Group COC Certificate until the major CARs are
closed.
D. Central Office Internal Audit Reporting Requirements and Annual Review
Requirements 5.3.7 and 5.3.8
The results of the internal audit of each Participating Site must be documented in a report that includes
(at a minimum) the following information:
a. Participating Site details (sufficient to identify the site);
b. Checklist covering all certification requirements applicable to the PS (at a minimum the COC
standard FSC-STD-40-004 and the trademark standard FSC-STD-50-001), providing a systematic
presentation of findings, and demonstrating conformity or nonconformity to each requirement;
c. Status of CARs issued by SCS and the CO, including CARs from both the previous and current
audit;
d. Verification of FSC material balance for each PS in accordance with the requirements of FSCSTD-40-004;
e. Summary of audit conclusions, including the decision on whether or not the site is eligible to be
included or remain in the scope of the certificate.
The CO must conduct an annual review of its internal audit program and procedures. This review
includes the results of each Participating Site’s internal audit in order to address any necessary changes
or identified issues.
If you have questions or concerns as you prepare for your upcoming SCS audit,
please feel free to contact any member of our staff.
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