What is controlled wood FSC®?

Controlled wood” means wood or timber products of known origin and not derived from sources considered unacceptable by the Forest Stewardship Council ® (FSC®).

The wood categories regarded as unacceptable sources are:

  • wood from illegal harvesting;
  • wood harvested in violation of civil or traditional rights;
  • wood from forests where high conservation values ​​are threatened by management activities;
  • wood from natural forests transformed by conversion into plantations or lands for other uses;
  • wood coming from forests where genetically modified trees are planted.

The necessary requirements to avoid the inclusion of wood materials from sources considered unacceptable in the chain of custody of certified products are regulated by the new Controlled Wood Standard FSC-STD-40-005, which entered into force on 1 July 2016.
The latest version of the standard is FSC-STD-40-005 V3-1, approved in February and published in March, 2017.
This standard establishes the requirements for a due diligence system in assessing and mitigating the risk associated with the materials provided without FSC declaration.
The Controlled Wood Standard requires the use of risk assessments to identify and assess the supply risk from unacceptable sources. When identifying a specified or unspecified risk with regard to the origin of the material or the risk of mixing it in the supply chain, the organization will implement risk mitigation measures.

The concept of controlled wood has emerged as a market need generated by the fact that certified sources cannot provide enough wood material to meet the needs of the wood processing industry that wants to sell FSC certified products.

In case of certification of forest districts or forestry departments according to the controlled wood standard, the provisions of the FSC-STD-30-010 V2-0 standard shall be implemented (FSC Controlled Wood Standard for forest districts).


The Due Diligence System (DDS) in acceptance of the FSC Controlled Wood Standard is a system of measures and procedures to reduce the risk of material supplied from unacceptable sources. A Due Diligence System usually includes the following three elements: obtaining information, assessing risk, reducing risk (when necessary).

Under the FSC Controlled Wood Standard, the Due Diligence system represents an adaptation of the due diligence system described in EU Timber Regulation No. 995/2010 (EUTR).

According to the FSC-STD-40-005 V3-1 standard, any company wishing to acquire controlled material, process or market timber or timber products with the “FSC Controlled Wood statement” must have implement and maintain a due diligence system (DDS) documented for material purchases without FSC declaration to be used as controlled material or sold with the FSC Controlled Wood declaration “.

The main requirements for the development and implementation of a due diligence system by an economic operator are:

  • The organization may choose to develop its own DDS or apply one developed by an external party;
  • The organization must include in its own DDS all suppliers and sub-suppliers of material evaluated in accordance with this standard.
  • The organization must provide access to evidence of compliance with the applicable requirements of this standard, including access to documents, harvesting sites, suppliers’ and sub-suppliers’ premises, where relevant.
  • The organization must review and, if necessary, revise its DDS system at least annually and whenever changes occur that affect its relevance, effectiveness, or suitability.
  • The organization must conduct internal audits of its own DDS system at least once a year to ensure it is implemented correctly.
  • The organization must document the scope, source of material, supply chain and staff involved in internal audits.


Risk assessment

The organization must use the applicable FSC risk assessment (NRA or CNRA) to determine the material risk for each category of controlled timber.

Centralized National Risk Assessment

Centralized National Risk Assessment (CNRA) represents the national risk assessment developed by the FSC International Center. CNRA is an instrument developed by the FSC to cover globally Risk Assessments on “Controlled Wood” where there is no National Risk Assessment (NRA).
The objective of the CNRA is to identify areas of low risk or specific risks for each of the five categories and, where appropriate, the measures taken to mitigate identified risks.
This approach supports companies (taking over some of their obligations) and at the same time ensures objective and harmonized risk determination in a transparent and participatory process.

The CNRA process in Romania

The CNRA process in Romania was supervised by the Policies and Standards Unit within the FSC International. The identification and assessment of the risks was outsourced to independent experts (selected by FSC®) with specific relevant experience for each category:

  • Category 1 – NEPCon;
  • Category 2 – Wolfgang Richert Consulting and Leo van der Vlist;
  • Category 3 – NEPCon;
  • Category 4 – NEPCon;
  • Category 5 – NEPCon;

As a FSC® partner in this process, WWF-Romania supported the development of CNRA by facilitating a participatory and transparent process so that stakeholders can be involved in determining the risks for Romania.
WWF organized two seminars with the participation of NEPCon representatives and national level key stakeholders (representing the three areas: economic, social and environmental), in terms of identifying the needed elements for assessing the adaptation to national conditions.
The CNRA Report (FSC-CNRA-RO version V1-0 EN) was developed by the CNRA experts mentioned above.


Through an appropriate implementation of this certification system, the operators in the wood industry not only follow and comply with the legal provisions, thus contributing to the promotion of a responsible forest management, but also generate other benefits that contribute to the sustainable development of local communities:

  • offers the opportunity to express views by stakeholders through a transparent and participatory process (through public consultations and intimation and complaint procedures);
  • promotes, as a whole, responsible forest management alongside the ecological, social and cultural benefits arising of it, and in particular the identification, the protection and the monitoring of High Conservation Values;
  • direct economic benefits and/or access on the certified wood market;
  • instrument for compliance with the legal provisions imposed on “operators” in the wood industry by the European Regulation (Reg. 995/2010);


The specified risks and mitigation measures provided in the CNRA will have to be taken into account by organizations whose timber chain of custody is certified by FSC, (i) which is supplied with uncertified wood (without FSC declaration) but which does not originate from unacceptable sources and (ii) wanting to sell FSC controlled wood and / or FSC Mix.

Centralized National Risk Assessment for Controlled Wood (CNRA) becomes applicable to all companies that want to sell FSC® Mix certified products – which contains controlled wood. Compliance with CNRA provisions will be assessed by Certification Bodies during the audit process.


CNRA and Controlled Wood certification represent an effective tool to combat illegal logging and promoting sustainable management for the identification, management and monitoring of High Conservation Values.

CNRA can also be used by operators to develop their own due diligence system (DDS), to implement the provisions of EU Regulation concerning the obligations of operators who place timber and timber products on the market (EU Timber Regulation no. 995/2010).

The organization needs to adapt its DDS and using FSC risk assessments within six months of their FSC approval.

The organization must assess and document the risk of mixing material with purchases of ineligible material in its supply chains during transportation, processing and storage.

Whenever a specified or unspecified risk is identified regarding the origin and / or risk of entry of ineligible material into the supply chain, the organization must implement risk mitigation measures.


Risk mitigation

The organization must maintain and implement appropriate control measures to avoid or reduce the specified or unspecified risk with respect to the origin and / or risk of mixing with non-eligible material in the supply chain.

If the legal requirements could be in conflict with appropriate control measures, the control measures must be approved by the certification body prior to their implementation.

Public consultation can be used both as a control measure (mandatory for categories 2 and 3 with unspecified risk) and as a tool to verify that control measures are appropriate.

For CW categories 2 and 3, the organization must use the opinion of at least one expert to justify the adequacy of the control measures. The experts used must meet the minimum requirements set out in Annex C.

More information on the requirements to be met by an economic operator wishing to implement Due Diligence can be found in Section I of the FSC-STD-40-005 V3-1 Requirements for Sourcing Controlled Wood standard.

Quality Management System

1. Competence, documentation and records
The organization shall appoint a management representative to be responsible for the organization’s conformity with all applicable requirements of this standard.

All relevant staff shall demonstrate awareness of the organization’s procedures, and competence in implementing the applicable requirements of this standard.

The organization shall implement documented procedures covering all applicable requirements of this standard.

The organization shall maintain records and documentation demonstrating its conformity with this standard, and ensure that they are readily available to the certification body.
The organization shall retain all relevant records for a minimum of five (5) years.

2. Publicly available information
The organization shall provide a written summary of its DDS to the certification body.

3. Stakeholder input and complaints
The organization shall develop and implement a documented procedure to handle comments and complaints from stakeholders that are related to its DDS.
The procedure shall include mechanisms for:

  • Acknowledging receipt of complaints;
  • Informing stakeholders of the complaint procedure, and providing an initial response to complainants within a time period of two (2) weeks;
  • Dialogue with complainants that aims to solve complaints assessed as substantial before further actions are taken;
  • Forwarding substantial complaints to the certification body and relevant FSC National Office for the supply area within two (2) weeks of receipt of the complaint;
  • Employing a precautionary approach towards the continued sourcing of the relevant material while a complaint is pending;
  • Determining the corrective action to be taken by suppliers and the means to enforce its implementation by a supplier if a complaint has been assessed and verified as substantial;
  • Excluding the relevant material and suppliers from the organization’s supply chain if no corrective action is taken;
  • Recording and filing all complaints received and actions taken.

NOTE: The minimum requirements to be observed for stakeholder consultation can be found in ANNEX B.
More information on the quality management system can be found in Section II of the FSC-STD-40-005 V3-1 Requirements for sourcing Controlled Wood standard.