COC updates for certificate holders 2021


We have an update for Forest Stewardship Council (FSC™) and Programme for the Endorsement of Forest Certification (PEFC) Chain of Custody (COC) certificate holders about actual developments and trends.

Frequent nonconformities raised by SGS auditors 2021

This analysis is based on 2,817 nonconformities raised by SGS auditors against the FSC COC standard (FSC-STD-40-004 V3-0).

2021’s top-five nonconformities are:

  1. FSC Labeling Requirements (#2 in 2020 and #9 in 2019)
  2. Management System (#3 in 2020 and #1 in 2019)
  3. Sales Documents and FSC Claims (#1 in 2020 and #2 in 2019)
  4. Supplier’s Sale and/or Delivery Documentation (#4 in 2020 and #3 in 2019)
  5. Product Groups (#9 in 2020 and #11 in 2019)


We also saw List of Suppliers named number 9 for 2021, moving from 6th and 7th place in 2020 and 2019 respectively. Meanwhile, Subcontracting, Information of the CB and Delivery Documents now features in the top 15.

Changes to FSC core labor requirements

FSC COC certification (FSC-STD-40-004 V3-1) has seen updates to Section 7: FSC core labor requirements and Annex D: FSC core labor requirements, self-assessment (normative). COC evaluations (FSC-STD-20-011 V4.2) has also been revised.

What are the FSC core labor requirements?

An organization shall:

  • Not use child labor
  • Eliminate all forms of forced and compulsory labor
  • Ensure there is no discrimination in employment and occupation
  • Respect freedom of association and the effective right to collective


Timelines for implementation

The effective date was September 2021 while the transition period runs until December 31, 2022. After this, all certificate holders must be assessed against the revised standard.

Global & local self-assessment templates

There are two key global self-assessment templates – GP4521B SGS and the FSC Template. Both templates can be used.

For local self-assessment templates, to ease the implementation of requirements, the FSC is providing national adaptations of their global self-assessment template.

Local self-assessments are already available for countries, including:

  • Australia
  • The Balkans (Bosnia and Herzegovina, Croatia, Serbia)
  • Belgium
  • Chile
  • Denmark
  • Germany
  • Indonesia
  • Italy
  • Japan
  • New Zealand
  • Portugal
  • South Africa
  • Spain
  • Sweden
  • Switzerland
  • The UK
  • The US


Local self-assessment is planned for Canada, China, France and the Netherlands.

Additional time for assessing FSC core labor requirements

The minimum time required for assessing the core labor requirements is based on the number of employees and country’s risk status.

The FSC AAF changes

The FSC has updated its annual administration fee (AAF). With the new system, the certificate holder’s exact forest product turnover (FPT) will be used to determine the fee.

The aim is to make the process more equitable, including avoiding sharp changes at class boundaries, as well as to provide the FSC with additional funding to:

  • Realize its ambitious 2021–2026 global strategy
  • Accelerate value chain development
  • Implement critical technology upgrades
  • Strengthen system integrity
  • Enhance stakeholder engagement


The FSC has made July 1, 2022, the implementation date.

SGS started to collect information on exact FPT during audits. Certificate holders need to complete and sign a self-declaration that includes details on FPT.

We cannot collect and verify FPT information from all certificate holders during the audits before the implementation date (July 1, 2022). Therefore, we will have to undertake extra exercises for some certificate holders to collect and verify FPT. We are informing certificate holders of any further information.

The PEFC COC revision process

PEFC ST 2002:2020: COC of forest and tree-based products, ST 2001:2020: PEFC logo usage rules and ST 2003:2020: Requirements for certification bodies operating certification against the PEFC international COC standard have the following timeline:

  • Issue: February 14, 2020
  • Effective: February 14, 2020
  • Transition: February 14, 2020–August 14, 2021 (extended to August 14, 2022)


Certificate holders must implement the new standard by August 14, 2022. SGS has until August 14, 2023, to assess all certificate holders against the new standard.

Key PEFC COC changes

The main changes concern:


4.1.1 – clarification that outsourced activities are covered by an organization’s management system.

4.6.1 – clarification on scope, i.e. inspection and control requirements applicable to the organization and outsourced activities.

Supplier certificate

4.4.1a) – the requirement that copies of certificates are kept has been replaced with the need for “evidence of certified status” and a clarifying note. – instead of copy/access to certificate of suppliers, verification of supplier’s certified status on the PEFC website is now required.


4.7.2a) – complaints now received in writing are to be formally acknowledged within 10 working days.

COC methods

6.1.1 – three COC methods, physical separation, percentage and credit, are now defined.

6.2.2 – a new requirement and an additional example clarify that materials with different certified content may be combined under the physical separation method.

6.4.3 – the validity of credits (credit method) has been extended from 12 to 24 months.

Due Diligence System (DDS) requirements (Section 7)

This chapter was added to the complete DDS in Appendix 1. The aim is to highlight product groups where organizations only use material that has PEFC claims from PEFC-certified suppliers. DDS requirements can be easily seen, without having to open all of Appendix 1.

Appendix 1: PEFC DDS for the avoidance of material from controversial sources & 3.7 controversial sources (definition)

The definition of “controversial sources” was extended from mainly covering legal compliance to the sustainability of production and harvest levels, biodiversity, ecologically important forest areas, fundamental principles and rights at work and of indigenous peoples.

There are also revisions to Table 1: List of indicators for negligible risk, Table 2: List of indicators for significant risk at origin level, and Table 3: List of indicators for significant risk at supply chain level.

How ISO 38200 can help

ISO 38200 audits demonstrate the effectiveness of your COC strategy in delivering safe, high-quality and compliant products around the world. This enables you to meet customer and regulatory demands.

The standard applies to materials originating from different input material categories. It includes wood, wood-based products, cork and lignified materials other than wood, such as bamboo, from the source to finished product.

ISO 38200 can support business-to-business communications and purchasers to evaluate supplier information to help identify suitable input material. This information can be used with specified criteria to determine whether a product/input material fulfills the conditions of its intended use.

Other standards and certification schemes can use ISO 38200 as a reference regarding COC systems.

How we can help

With our COC certification, anyone can quickly determine your wood products’ origins and the processes they have gone through. It helps to ensure the traceability of wood. Certification is also a guarantee increasingly sought by consumers.

We can perform integrated audits against different COC standards and forest management programs. We can certify forestry management programs and practice standards, as well as COC, all saving you time and money. For forestry management, we certify against many recognized programs.

Disclaimer: Information about our FSC™  and PEFC forestry accreditations and licenses are provided on the SGS website: www.sgs.com/forestryaccreditations.



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