This position paper, published by the CoC Group Network (CGN), addresses the ongoing revision of the FSC Chain of Custody standard (FSC-STD-40-004 V4-0 D2-0). CGN represents experienced group managers from Europe and North America who together support thousands of small enterprises certified under FSC group Chain of Custody certificates. Written from that frontline perspective, the paper sets out CGN’s positions on the draft standard for FSC, Certification Bodies, FSC members, and the wider public.

Summary

The paper argues that group certification is the key mechanism enabling small and medium-sized enterprises to access FSC certification, and warns that increasing complexity or tightening eligibility could push these companies out of the FSC system entirely rather than toward individual certification. CGN sets out detailed positions across several areas of the draft standard, including: supporting the proposed company-size eligibility thresholds while preferring forest-based turnover as the relevant metric; opposing restrictions that would limit groups to a single country; favoring management-capacity and risk-based criteria over arbitrary group-size limits (while accepting a 1,000-site cap as a reasonable safeguard); endorsing the risk-based sampling approach and continued use of remote and hybrid audits; supporting impartiality safeguards for internal auditors without curtailing the technical support Central Offices provide; backing the phased introduction of FSC Check; and calling for a simpler, more transparent Annual Administration Fee structure that preserves the fee differential making group certification affordable. The paper concludes that FSC should fully support and promote CoC group certification, favoring proportionate, evidence-based requirements over further complexity.

Download position paper: Position paper FSC CoC Group Cert from CGN (pdf)

The AI generated illustration shows how FSC Chain of Custody group certification works: a central office oversees and connects a diverse range of small enterprises — producers and traders — highlighting how group certification gives smaller, otherwise disconnected businesses centralized support, shared oversight, and streamlined access to certification, making FSC certification achievable and affordable for enterprises that couldn’t manage it individually.