Companies in Europe and further afield welcomed the publication of the 2013 PEFC Chain of Custody standard in May 2013 as it adds an important benefit that even companies previously not interested in forest certification were keen on: alignment with the EU Timber Regulation (EUTR).

While today PEFC Chain of Custody certification appears to be one of the most efficient ways to comply with EUTR requirements, it is the result of three years of hard work with one objective in mind: building consensus among stakeholders for a new standard that goes beyond the fundamental premise of tracing certified timber through the value chain, a standard that additionally assists companies in addressing regulatory and legality requirements.

The development of the 2013 PEFC Chain of Custody standard was off to a rocky start when it was first envisaged in May 2010, just as PEFC was in the final phase of a comprehensive revision of the original PEFC Chain of Custody standard, which dated back to 2002. The revision work had incorporated the experiences of almost 10 years of certification by thousands of companies globally. Major changes included the recognition of recycled material within PEFC claims, and discussions on the inclusion of social requirements (which were eventually adopted, and are now widely acknowledged as moving forest certification to a new level) were in full swing. The PEFC Chain of Custody and Labelling Working Group (CoC WG), a multistakeholder process that led the revision work, agreed to first build consensus and get approval for the 2010 PEFC Chain of Custody standard, before engaging in further revision work. The PEFC board of directors then gave its approval for a further round of revision in February 2011, to cover issues such as the potential alignment with EUTR requirements.

One fundamental challenge that stakeholders had to grapple with throughout the process was that while the general framework of the forthcoming EUTR was known and available in Regulation EU No 995/2010 (published in October 2010), the exact details of the requirements only became known over time as the European Commission itself engaged in the development of the secondary legislation and guidance documentation. An initial gap analysis that provided a starting point for the CoC WG therefore had to consider a range of likely scenarios of what the final EUTR requirements might look like.

Developing solutions

Over the next 14 months, the CoC WG met eight times to consider and develop a variety of potential solutions to aligning the standard with the EUTR, always bearing in mind other processes such as the US Lacey Act and the Australian Illegal Logging Prohibition Act.

Of particular importance was the fact that the EUTR would not apply to all certified companies, but only to those trading with or located in the EU. While the Regulation requires companies placing timber or timber products on the European market (both imported and domestic) to implement a due diligence system (DDS) to minimise the risk of illegal timber being traded, companies trading wood products within the EU are only responsible for keeping records of their suppliers and customers to allow traceability.

To deal with this differentiated approach, stakeholders explored options such as a modular approach, with a voluntary module available for companies being subject to the EUTR. In light of global and complex timber flows and in order to address potential future legislator and regulatory demands, stakeholders agreed to an integrated approach that would apply to all certified companies to deliver a robust and credible mechanism. In addition, this would address the fact that the EUTR would also affect companies outside the EU as their products may be imported into the EU further down the supply chain.

After consensus was reached (no mean feat), the enquiry draft of the 2013 PEFC Chain of Custody standard was opened for a 60-day global public consultation, triggering over 300 comments from stakeholders worldwide. At the same time, five companies pilot tested the new requirements. This led to modifications of the standard, including the introduction of regionspecific risk assessments and the abolition of self-declaration, adding to both the usability and integrity of the standard.

The 2013 PEFC Chain of Custody standard was subsequently approved by the PEFC General Assembly in May 2013 after being considered and recommended by the PEFC board of directors.

Key changes to the 2013 Chain of Custody standard include:

  • Expanded definition of controversial sources to include EUTR-specific requirements such as compliance with trade and customs legislation in addition to international, national, or local legislation concerning forest-related activities.
  • Additional information requirements on tree species and origin to satisfy information needs of various legislative and regulatory processes such as the EUTR.
  • The PEFC Due Diligence System is now an integral element of the PEFC Chain of Custody standard and mandatory for all certified entities and all material, including certified material.
  • Enhanced scope of prohibited material to include conflict timber.

With the 2013 PEFC Chain of Custody standard companies now have a straightforward, tried-and-tested mechanism to demonstrate alignment with EUTR requirements. In addition, companies that do not yet have access to certified material consider PEFC as a viable option as they benefit from compliance with the EUTR while at the same time being well prepared for future business opportunities with customers requiring evidence of sustainable sourcing.