09.22Chain of Custody Certification (CoC)
One of the hot topics for companies dealing with wood and paper products is Chain of Custody Certification (CoC). Initials like FSC, SFI, and PEFC are being discussed, but there’s not always a clear direction into what it is and what’s required.CoC is designed to provide an assurance that forest products and their bi-products originate from a sustainably managed forest. The Sustainable Forest Initiative® (SFI), Forest Stewardship Council (FSC), and Program for the Endorsement of Forest Certification Programs (PEFC) are the predominant industry standards. Is one better than the other? Not really. Are they really different? For primary manufacturers-yes, for everyone else-no. Is there a benefit to dual or triple certification? The costs should be very minimal to obtain all 3. If you’re implementing the system anyway, why not have the flexibility to meet all potential client requests, rather than just an immediate one?The question for companies that aren’t primary manufactures (paper mills, sawmills, etc.) is understanding what’s required when the standard covers all possible participants in the chain. What we want to discuss is what do these companies need to do?All companies wishing to achieve CoC certification are required to meet minimum requirements in product traceability, product storage, product handling, invoicing, and record keeping. The trick is to take what you’re already doing and make the necessary changes rather than create a whole new system. However, as this website has explained certification is a validation of an effective system rather than the end goal, the same is true with CoC. You need a solid system in place and if you’re putting forth the effort to pursue any kind of certification your better set for the long term taking a rationale approach that looks at the system in its entirety.
Now if you don’t have the basics of a management system in place, such as ISO 9000 or ISO 14000, you’ll have more work to do. Looking at the FSC standard (Part 1: Universal Requirements, Section 1 Quality Management) you need to have clearly defined responsibilities, procedures, training, and records in place. Just like with ISO 9000/14001 many companies have this but more as “tribal knowledge” rather than a formal system. I would strongly recommend looking at the same implementation group and same registrar for all your certifications if they are equipped to provide that.
If you have the basics in place the 10 things you need to look at are:
- Find sources for FSC, SFI, and/or PEFC certified material. (Records and Procedures)
- Request certification information from the supplier if applicable. (Records and Procedures)
- Track certified material purchased and sold and make sure you have the support documentation where necessary. (Records and Procedures)
- Make sure suppliers documentation and purchasing documentation references certified material information where applicable. (Records and Procedures)
- Identify areas within your process that have the possibility of certified material being mixed with non-certified paper. (Procedures and Responsibilities)
- CoC is looking for records that are identified, stored, protected, and retrieved, along with information on how long they are to be kept. (Records)
- Train staff on their roles and responsibilities within the Chain of Custody and keep records of the training. (Training)
- Implement system to report on the sale of certified materials by customer. (Responsibilities, Procedures, and Records)
- Complete round of internal audit. (Responsibilities, Procedures, and Records)
- Complete management review of system. (Responsibilities, Procedures, and Records)
A strong management system, regardless of whether it’s quality or environmental, can make for a much easier integration of CoC or any other standard you pursue.
Chris Carson

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