What is FSC-STD-40-004?
FSC-STD-40-004 is the foundational Forest Stewardship Council® (FSC) standard for Chain of Custody (CoC) certification.
This standard details the requirements for companies to control, identify, and sell forest-based products as FSC-certified, ensuring they come from responsibly managed sources from forest to market. FSC-STD-40-004 deals with sourcing, processing, and labeling, allowing businesses to use FSC trademarks on certified products and helping to ensure authenticity for consumers.
Why are there proposed revisions?
At the 2025 FSC General Assembly, FSC presented the upcoming revision of its CoC standard, which outlines key changes to strengthen credibility, improve usability, and streamline multiple related standards into a single framework.
Proposed revisions & Chris’ comments
All FSC members and stakeholders are invited to review and provide feedback on the proposed revisions via the FSC Consultation Platform between now and January 25, 2026.
We know reviewing these revisions can take time—perhaps more time than is available. With that in mind, American Green president Chris Gibbons has reviewed the proposed revisions in full and provided his comments below. Our hope is that this will provide additional background and rationale so that your own revision process is easier.
We’ve provided screenshots below of each section of the proposed revisions to FSC-STD-40-004. You can also download the entire PDF here, which also includes revisions for FSC-STD-20-011.
Scope
Background & questions
Chris’ comments
- Q1a – Neutral
- Q1b – no response
- Q2a – Neutral
- Q2b – I am uncertain of what is trying to be fixed here in NTFPs. Unless there is a specific issue that is in need of addressing, this seems an unnecessary and arbitrary line to draw.
- Q2c – Label only
Section 1
Background & questions
Chris’ comments
- Q3a – Neutral
- Q3b:
- 1.2 How specifically shall The Organization commit? Some clarity around whether this should be in writing or publicly done would be beneficial.
- 1.3.e I suggest you add xiii. “(if applicable) records related to group or multisite certification, including but not limited to internal audit reports”
- 1.4.b Why did you choose “responsible person” rather than “management representative”?
- 1.4.1 What is meant by “or employer(s)”? In what scenario would a non owner be exempt from clause 1.4?
- 1.5.2 What if state law is more restrictive than national law? Why not “applicable law and regulations” instead of “national”?
- 1.5.3 “or other” should have an (e.g. example) to help clarify
- Q4a – Agree
- Q4b:
- 1.5.a says “occupation” instead of “occupational”
- 1.5.d You should add a note to this clause defining whether outsourced workers are covered under this definition of worker, or only direct employees.
- Q5a – (a) – keep in section 1
- Q5b – no response
- Q6 – no response
Section 2
Background & questions
Chris’ comments
- Q7a – Neutral
- Q7b:
- Applicability Box 1 should be moved below 2.2 or it should be removed and added into the standard as a clause.
- Applicability Box 1 – The sentence “Organizations are required to include in their product groups only the products and species…” seems to imply that minimally an organization has these stated requirements for product groups, while I believe that the intent is to maximally allow these requirements for product groups. If that is the case, the sentence should read “Organizations are required to only include in their product groups the products and species…”. Note the movement of the word “only.”
- Applicability Box 1 – Why is this box using “organizations” plurally when the rest of the clauses use “The Organization” singularly?
- 2.4 Table 1 – Please make sure the page break happens before the Table, so the entire Table fits on a single page.
- 2.4 Table 1 Note – Isn’t a claim without “x% or credit” a valid output, but not a valid input? This seems like an unnecessarily confusing note, especially since Clause 6.2 does exist.
- Q8a – Agree
- Q8b – no response
- Q9a – Agree
- Q9b – no response
Section 3
Background & questions
Chris’ comments
- Q10a – Neutral
- Q10b – 3.3.c use of the word “quoted” instead of “provided” or “specified” seems odd
Section 4
Background & questions
Chris’ comments
- Q11a – Neutral
- Q11b:
- 4.2 Note – Please clarify that this list is a list of examples and not inclusive of all options
- 4.3.a Why not allow maintenance on a product? As long as it doesn’t transform or modify the product, maintenance should be allowed.
Section 5
Background & questions
Chris’ comments
- Q12a –Neutral
- Q12b – 5.5 Note 2 – What problem is this solving? Is it necessary to include this exception?
Section 6
Background & questions
Chris’ comments
- Q13a – Neutral
- Q13b – 6.6 is unclear about what is being required and should be reworded
- Q14a – no response
- Q14b – no response
Section 7
No major change in this section, reference to “timber” has been removed to make this section more exhaustive for all relevant legislation applicable to forest-based products.
Section 8
Background & questions
Chris’ comments
- Q15a – Neutral
- Q15b:
- 8.1.1 states “exceptions in clause 8.2.2…” I believe this should be “clause 8.1.2.”
- 8.1.2.c seems quite open to interpretation. Is it a necessary clause to include?
- 8.1.4 this seems unclear. Where are “the worst forms” defined? That should be linked if they are defined somewhere.
- 8.5.3 draw up whose constitution and rules? The workers organization’s or The Organization’s? This is unclear as written.
- Q16a – (a) allow prison labor under ILO
- Q16b – no response
- Q17 – no response
Section 9
Background & questions
Chris’ comments
- Q18a – Neutral
- Q18b – Table 3 – the light green of “FSC Recycled Credit” comes out almost white when printed, and is functionally indistinguishable from “No FSC Claims Allowed” on the printed page
Section 10 & 11
Background & questions
Chris’ comments
- Q19a – Agree
- Q19b – Since Table 7 is so far removed from these two sections, please make it more clear where Table 7 is located in the standard.
Section 12
FSC Small and Community Label has been removed due to the changes of new version of FSC-STD-50-001.
Section 13
Background & questions
Chris’ comments
- Q20a – Neutral
- Q20b – 13.2.3.b Why does The Organization need to reference a contractor CLR self-assessment in their own self-assessment? This seems an unnecessary step that will just contribute to unnecessary NCRs.
- Q21a – Neutral
- Q21b – no response
- Q22a – no response
- Q22b – no response
- Q23a – Yes
- Q23b – no response
- Q24 – no response
- Q25a – Feasible
- Q25b – no response
- Q26 – Feasible
- Q27a – Neutral
- Q27b – no response
Section 14
Background & questions
Chris’ comments
- Q28a – Agree
- Q28b:
- The exemption is appropriate because the suppliers of non-forest salvaged wood already operate in low-risk, high-documentation environments such as municipalities, utilities, and institutional campuses. These entities produce clear and verifiable removal records, including permits, work orders, and address-specific documentation. These evidence types meet the intent of FSC-STD-40-007 and reduce the need for additional supplier audits. The exemption allows FSC to focus audit resources where they are actually needed rather than applying the same burden to suppliers that already provide strong, objective evidence.
- To improve clarity, FSC should explicitly confirm that municipal and institutional documentation qualifies as sufficient evidence for exemption.
- Q29 – 14.1 NOTE states that you cannot buy certain inputs from non certified companies, but exactly what those inputs are is not clear by the language used, or perhaps it isn’t clear why those inputs are being singled out for exclusion.
- Q30a – Disagree
- Q30b:
- Non-forest (urban) salvaged wood should not be treated as neutral because it delivers measurable environmental benefits that align directly with FSC’s mission. Urban wood is diverted from chipping, landfilling, or incineration, which reduces emissions and stores carbon in long-lived products. It does not originate from traditional forests or harvesting operations and therefore carries none of the risks associated with forest management or forest-of-origin claims.
- Treating it as neutral undercuts or even eliminates its post-life climate value and discourages markets from recovering this material. Recognizing its contribution encourages responsible recovery, supports circular material flows and local economies. FSC should acknowledge these benefits and treat non-forest (urban) salvaged wood as eligible for claim contribution.
- Q31a – Agree
- Q31b:
- Non-forest (urban) salvaged wood fully meets the principles of reclaimed material and should be recognized for the significant climate and waste-reduction benefits it provides. It is diverted from disposal, recovered through documented municipal, institutional and utility operations, and transformed into long-lived products that store carbon. It creates no additional forest pressure and does not compete with certified forest products.
- Urban wood is one of the most transparent and easily verifiable material streams available. The existing -STD 40-007 mechanisms already provide a complete framework for evidence and oversight. Including this material as claim-contributing strengthens the credibility and relevance of the FSC system.
- Q31c – Additional benefits:
- Urban wood expands the supply of responsible, low-carbon wood products without increasing demand on forests. It supports municipal climate plans, institutional sustainability commitments, and local circular economy initiatives. It also gives FSC a more visible role in built-environment sustainability and aligns the system with emerging market demand for low-carbon materials.
- Q31d – Mitigation can rely entirely on existing 40-007 tools. Accept municipal permits, utility records, campus documentation, geotagged photos, stump photos, and yard-intake logs as objective evidence. Require visual confirmation at receipt and maintain records consistent with existing reclaimed-material expectations. Use sampling audits only when documentation is insufficient. Apply standard contingency procedures when material cannot be verified. These measures maintain credibility while keeping the system accessible for small urban mills and processors.
- Q32a – Agree
- Q32b:
- Proposal A accurately recognizes the environmental value of including reclaimed inputs that originate outside forest operations. This aligns with FSC goals and supports the use of materials that reduce waste and store carbon in long-lived products.
- To strengthen the proposal, FSC should clarify that non-forest (urban) salvaged wood is a distinct category that follows the same verification pathways as reclaimed material. Explicitly listing acceptable evidence will help certificate holders and auditors interpret the proposal consistently.
- Q32c – The primary additional benefit is that Proposal A enables FSC to demonstrate leadership in circular economy and climate-positive material recovery. It also enhances system relevance to cities, institutions, and design professionals who are seeking additional verified circular materials.
- Q32d – I don’t see a risk in this proposal, therefore no additional mitigation is needed.
- Q33a – Neutral
- Q33b – This is unnecessarily complex. Proposal A should be implemented.
Section 15 & 16
Background & questions
Chris’ comments
- Q34a – Agree
- Q34b – No response
- Q35a – Strongly Agree
- Q35b – If you are going to eliminate FSC-PRO-40-003 and FSC-PRO-40-003a, then the limitations have to cover the definition of a small business in all countries. This current proposal does that. It also has to be able to be modified in some way to account for inflation. This proposal does that too. Overall, a good change to the group certification standard.
- Q36a – Strongly Agree
- Q36b – Removing the group member limit is a positive step that can only help FSC gain participants. I strongly agree with this change. Removing the country limitation just makes sense. Business doesn’t stop at national boundaries. Neither should FSC. The auditor and central office requirements are enough to ensure that organizations capable of handling cross border groups will be effectively overseen.
- Q37a – Mildly disagree
- Q37b – I chose “mildly disagree” for Q37a because… why are common ownership sites excluded from this requirement? Doesn’t it make sense that every auditor should have to meet some basic minimum requirements? Same for the NOTE. Why grandfather in existing auditors? If there’s a basic minimum requirement, it should be for everyone. In general, I agree with the requirements of auditor certification.
- Q38 – 16.7.1.a states that the legal or managerial authority shall be the contact for the central office. In actuality, there are many instances where the contact for the central office is not the legal or managerial authority, but rather the person tasked by the legal or managerial authority with overseeing their certification internally. My experience has been that communication is more effective with this designee on a day to day basis, and that communication with the legal or managerial authority, in these sort of structures, is best saved for when there is a problem that the central office contact is unable to address. My suggestion would be to change that sentence to “…. this representative, or representative’s designee, shall be the contact for the central office”
Annex 1
This Annex incorporates the requirements established in ADVICE-40-004-25, with no major change from the advice note contents.
Annex 2
Background & questions
Chris’ comments
- 39a – Neutral
- 39b – No response
Annex 3
Background & questions
Chris’ comments
- 40a – Agree
- 40b – No response
Annex 4
Key changes (no questions)
- Amended timeline for Corrective Action Requests (CARs) closure to align with the changes in FSC-STD-20-001;
- Introduced Clause 16.4.6 and 16.4.7, together with Section 2 of Annex 4, to align with the introduction of remote audit in FSC-STD-20-011.
Annex 5
Background & questions
Chris’ comments
- Q41 – No response
Terms & Definitions
Background & questions
Chris’ comments
- Q42a – Neutral
- Q42b – No response
In summary
The ultimate goal of the proposed revisions to the FSC CoC Standards is to achieve a delicate yet important balance between the integrity of the system and a streamlined approach.
- This post provides Chris’ review and comments for the proposed revisions for FSC-STD-40-004 only.
- If you’re interested in his review and comments for FSC-STD-20-011, check out our second post in the FSC CoC Consultation series.
- FSC members and stakeholders can provide feedback on the proposed revisions via the FSC Consultation Platform between now and January 25, 2026.
We hope this review proves helpful to you as you consider how you feel about the proposed revisions to the FSC CoC Standards. If you have any questions, feel free to reach out to the American Green team.
Featured image credit: Olena Bohovyk on Unsplash
