Understanding the New FSC Labels

The June PaperSpecs Webinar “Understanding the New FSC Labels” could have been called “Everything You Wanted to Know about the New FSC Labels But Were Afraid to Ask” except that attendees weren’t afraid to ask anything!

Guest speaker Monika Patel, FSC Canada’s program officer served up answers to your biggest concerns about the new labeling standards and graphic formats. And while you may see some of those new labels (FSC-STD-50-001) in use today right along with the original format (FSC-STD-40-201), the updated labels are not required until January 1, 2011.

Big Change 1: New Standard Much Simpler
Under the new FSC Labeling standard (FSC-STD-50-001), the on-product labels are much more concise. The original seven included FSC Pure, FSC Mixed Sources 1, FSC Mixed Sources 2, FSC Mixed Sources 3, FSC Mixed Sources 4, FSC Mixed Sources 5 and FSC Recycled. Come January 2011, there will be just three:

FSC 100%: Products manufactured with 100 percent FSC-certified virgin fiber from FSC-certified forests.

FSC MIX: Products manufactured with a combination of FSC-certified virgin fiber (from FSC-certified forests), controlled sources and/or recycled wood or fiber. This label can include the Mobius loop.

FSC Recycled: Products manufactured with 100 percent recycled fiber of which at least 85 percent is postconsumer (PCW) recycled material.

Big Change 2: Pre-consumer Waste Included
Papers that contain a minimum of 85 percent postconsumer (PCW) waste (with the balance being pre-consumer waste) are eligible to use the new FSC “Recycled” label.

So the Recycled Label could also be used for paper with 90 percent PCW and 10 percent pre-consumer waste, or 95 percent PCW and five percent pre-consumer waste or 100 percent PCW … you get the idea. It has to total 100 percent recycled fiber with at least 85 percent being PCW.

This change recognizes the importance of pre-consumer waste to the recycling function. Using both pre-consumer and postconsumer waste in the production of paper is environmentally beneficial because doing so diverts paper waste from landfills and reduces our need for virgin wood fiber. Some would say pre-consumer waste is also needed as the demand for PCW far exceeds what is available.

“The old on-product labeling standard (FSC-STD-40-201) only included the amount of postconsumer waste in the Mobius loop (the recycled symbol). The new FSC on-product labeling standard (FSC-STD-50-001) now includes both pre- and postconsumer waste in the Mobius loop,” said Patel.

One Webinar attendee asked if it was permissible to change the percentage of PCW content when using the new “Recycled” label. The answer is NO. Products with the FSC Recycled label must contain at least 85 percent postconsumer waste and the remaining percentage pre-consumer waste. So while the inclusion of the Mobius Loop on the label itself is optional. The percentage displayed underneath it will always be 100%.

That brings us to the new “Mix” Label
As another attendee put it, “What’s with the mixed sources logo? I thought it couldn’t have anything but 100 percent in that recycled triangle.”

According to Patel, the old “Mixed Sources” logo has always represented papers made with a combination of FSC-certified virgin fiber mixed with controlled virgin fiber and/or recycled fiber. That original standard only included the amount of postconsumer waste in the Mobius loop.

The new “MIX” label, as it is called, can contain anywhere from zero up to 84 percent recycled fiber in combination with FSC-certified virgin fiber (from FSC-certified forests) and fiber from controlled sources. Again, the “recycled” fiber in this label standard allows for the possibility of both pre-consumer and postconsumer waste.

Now, on to Patel’s answers to the specific questions asked during the Webinar.

So if you want to show exactly what percentage of fiber is recycled, can you do that on the new MIX label?
According to the new labeling standard, if you wish to communicate the percentage of recycled fiber, it must appear directly beneath the Mobius loop.  The Mobius loop is optional for both the MIX and Recycled labels. (But on the Recycled Label, it will always say 100%)

Why is that?  There are many FSC-certified stocks that are not 100 percent PCW.
Any paper that does not contain 100 percent recycled fiber (pre- and postconsumer waste) would then use the “MIX” label.

Are there any FSC Pure (the new standard is called FSC 100%) papers?  It was our impression that the paper is either mixed sources or recycled.
You’re right. Currently, FSC-certified PURE papers do not exist in the North American marketplace. The FSC papers that do currently exist in the marketplace carry either the FSC Mixed Sources label or the FSC Recycled label.

What’s the difference between FSC-certified virgin fiber and controlled virgin fiber?
FSC Virgin fiber is that which comes from an FSC-certified forest.

What is controlled fiber?
In many cases, wood and paper products use wood from a variety of sources, some FSC certified and some not. In these cases, companies applying the FSC Mixed Sources label must ensure that the non-FSC-certified component of the product avoids the most controversial sources.

The FSC Controlled Wood standards help FSC Chain-of-Custody (COC) certified companies avoid the use of unacceptable sources of wood in products carrying the FSC Mixed Sources Label.  Unacceptable sources include:

a) illegally harvested wood;
b) wood harvested in violation of traditional and civil rights;
c) wood harvested in forests in which high conservation values are threatened by management activities;
d) wood harvested in forests being converted to plantations or non-forest use; and
e) wood from forests in which genetically modified trees are planted.

Is that some kind of new FSC number on the label?
This is the Trademark License Code. FSC is introducing the license code as part of the overall unification of trademark use authorization. Eventually all trademark users will have a code in this format. The new license code is shorter and better linked to FSC. The format for the license Code is FSC® C######. The Chain of Custody codes should be used on invoices and sales documents to indicate that the company and product are FSC-certified.

Can we omit the trademark license outside the logo?  We would like to print it below the logo.
The FSC Trademark License Code is a required element of the FSC label and cannot be altered.

Does the license code have to be on ship tickets from a distributor as well as the CoC number?
In accordance with the FSC Chain-of-Custody Standard (FSC-STD-40-004), invoices and shipping documents must include the Chain-of-Custody certificate code. The license code will be used on product labels and for promotional uses.

What Web site is the trademark license code on?
FSC Trademark license codes and Chain-of-Custody codes can be found on the FSC International database available at www.info.fsc.org.

How do we check someone’s certification if we no longer receive their CoC number on the artwork?
Both Trademark License Codes and Chain-of-Custody numbers are traceable on the FSC International database (URL listed in the question above).

As a designer, if I am designing a brochure for a company, who has to become FSC certified and provide the logo? Me, the company I am working for or the printer I am using to print the brochure?
The FSC Chain-of-Custody (CoC) certification connects consumers to healthy forests by tracking products from forest to shelf.

All companies that process, transform, manufacture, convert or distribute forest products must be CoC certified in order to put the FSC label on products.

In your specific example, it would be the printer that would need to be FSC certified in order to be able to sell the product as an FSC-certified product and to be able to place the label on the product.

What are the changes to label sizes?
The minimum label is smaller in the new FSC on-product labeling standard.

New Standard:
Minimum size of the portrait mini label is 11mm in width.
Minimum size of the landscape mini label is 8mm in height.

Please note that the minimum-sized labels do not include the Mobius loop for any of the FSC labels.

Can these “minimum labels” be used on anything and not just on small pieces?
The mini label may be used when there is not sufficient clear, unprinted space for the standard label in the area where the label is to be placed. Approval for the use of mini label shall be at the discretion of the certification body.

I have had requests to make the FSC logo as large as possible. Can you go over the max size you have specified?
Currently the FSC Standards do not specify a maximum size for the logo. Send in your document to the certification body for final approval.

Can you also review the standards for self-promotional use of logos like on a business card or printer’s promotional materials?
The trademark standards for certificate holders have been restructured into one document. “Requirements for use of the FSC trademarks by certificate holders” (FSC-STD-50-001) covers requirements for on-product labeling, promotional use of the trademarks and graphical requirements. For information on the new promotional logo requirements, please refer to the new standard.

Do we have to include borders on the labels?
Yes, the new FSC Labeling Standard (FSC-STD-50-001) states that the label border is always required. The border is an important feature as it keeps all label elements together and separates the label from any other information on the product.

In addition, there should be enough clear space, termed the exclusion zone, surrounding the label to ensure that the label remains uncluttered. The minimum space is calculated by using the height of the FSC initials of the logo. Here is an example of the exclusion zone on a FSC 100% label:

Is the certified printer the only person able to place a high-res label on the artwork?
In general, FSC-certified companies are provided with the ability place the final high-res image of the FSC label onto a document or product. However, there can be cases where the certified company and its certification body may allow designers access to the high-res images for placement purposes.

What about in-house creative teams who are printing digitally on smaller production machines and are purchasing FSC-approved papers?  How do we label our materials?
The in-house print shop would need to attain FSC certification to label or claim the documents/products as FSC-certified. To become FSC certified, visit http://fsccanada.org/becomecertified.htm.

How much does it cost to be FSC certified?
The cost of certification will depend on the location and size of the company. Part of the fee is paid to the certifier for the auditor’s time and the application process, and a small program fee (starting at $10/yr) is paid to FSC’s International Centre. Typically, certification for a medium-sized business will range from $3,000 to $4,000. There are also costs associated with the annual surveillance audit that all certified companies must undergo. To receive a quote, contact a certification body. They can be found at www.fsccanada.org/FSCCertifiers.htm.

Are approvals required for each printed piece and what is approval turnaround time?
Generally, certified companies should submit artwork of all new reproductions of the FSC trademarks to their certification body. However, provided that the certified company establishes a good record of correct trademark use, and with approval from the certification body, it is not necessary to re-submit labels for the same product type or with the same placement on the product, or for repeated use of promotional artwork. Generally, the turnaround time for FSC label approvals is between 24-48 hours.

Does the United States follow the same graphical requirements as Canada?
Yes. The FSC Chain-of-Custody and Labeling standards are developed at the international level by FSC International. Working with environmental, social and industry stakeholders, the standards apply to all companies of the supply chain between the forest and the final consumer.

Are designers limited to black, white and/or Pantone 626 inks?
The new FSC labels are available in positive and negative FSC green, black and white. Exceptions can be made if the print job uses a limited number of colors (e.g. corporate colors) with approval from the certification body.

FSC Green: Pantone C 626

CMYK Build:
100% Cyan
60% Magenta
100% Yellow
20% Black

RGB:
50 Red
80 Green
60 Blue

Is there any watchdog for the improper use of the logo?
Yes, FSC takes the use of the FSC Trademarks quite seriously and does monitor the marketplace for any misuse. FSC then follows up on each case to resolve the misuse. If you see any misuses of the trademark, please let us know. Send all misuses to: Monika Patel [email protected] (Canada) or Emily Crumley [email protected] (USA).

Does a print broker need to be FSC certified in order to use the FSC logo on our print piece?
A print broker MUST be FSC certified if they purchase FSC-certified paper from the merchant directly and have it delivered to a printer and want the FSC label to be applied.

The broker is taking ownership of the FSC product and therefore considered within the chain of custody.  In this situation, it is the broker that places the FSC label (and their certification code) on the document. This also means that the broker can choose to work with any printer, certified or not, since they are verifying the paper’s authenticity and labeling it.

A print broker DOES NOT need to be FSC-certified if their printer is FSC-certified and the printer purchases the paper from the merchant directly.

The broker in this case is not taking ownership of the FSC product and therefore not within the chain of custody. In this situation, it is the printer that places the FSC label (and their certification code) on the document.

Will there be FPO labels available as before?
‘For Print Only’ or low-res image are available on the FSC Canada Web site: http://www.fsccanada.org/productlabel.htm#what.

Is there a package of ‘for placement only’ logos – on the link you sent in the presentation, it only shows Web images.
Currently such a ‘package’ does not exist. However, there are low-res images that can be copied and pasted from the FSC Canada Web site (URL shown in question above).

We are a book publisher and have been placing the FSC logo on the outside back cover of our books and also on the copyright page. Is this a correct procedure?
The FSC label can be placed in a variety of locations on a certified product as long as it is clearly visible. The placement of the FSC label is ultimately up to the approval of the certification body.

So do we need to toss products (e.g. notecards) because they have the old blue FSC logo?
No. All existing stocks may continue to be used and distributed.

Certified companies can transition to the new standard gradually, running some product lines with the new labels and some with the old label. Certificate holders do not need to transition to the new standard until January 2011. For more information, contact your certification body.

It seems that all a printer has to do to be certified is pay a bunch of money and pile their FSC papers in a separate area. What have you done to counteract this impression in the marketplace? Many printers still feel it’s a racket.
This may be a common misconception with non-certified companies. However, companies that are actually FSC certified are aware that there is more to certification than just that.

The FSC Chain-of-Custody process and audit aims to verify that FSC claims (e.g. labels) are made only on products that meet FSC’s rigorous standards.

To become FSC certified, companies are required to meet the Chain-of-Custody Standard:
1. Quality management: responsibilities, procedures and records
2. Product scope: definition of Product Group(s) and outsourcing agreements
3. Material sourcing: material specifications
4. Material receipt and storage: identification and segregation
5. Production control: control of quantities and determination of FSC Claims
6. Sales & Delivery: invoicing and transport documentation
7. Labeling: application of the FSC labels on product and labeling thresholds.

FSC North America provides learning resources and delivers training workshops to improve the understanding and implementation of FSC certification in North America. Resources are in the form of fact sheets, presentations and online information and can all be found in our Resources Centre.

It is also a matter of taking the initiative to communicate with your clients on the benefits of FSC and why choose it. Take a look at our top 12 reasons to choose FSC http://www.fsccanada.org/whyfsc.htm.

Can’t you make your life easy and have your printer (who is certified) get the certification for you?
Printers cannot attain certification for anyone. To become FSC-certified, companies are verified by third-party auditors to FSC’s rigorous standards. The certified company (e.g. the printer) should be the one to send in documents for approval to their certification body.

Is it standard for the printer to pass down the cost of using the FSC label to the designer?
Generally, designers do not purchase the paper so I’m not sure where they would be charged.

Do you see FSC-certified paper being sold at a higher price than non certified? I thought it was not supposed to be at a premium.  Do you see this?
When it comes to the pricing of FSC-certified products, in the past, most suppliers asked for a small premium for FSC-certified products. However, with the dramatic increase in types and variety of FSC-certified paper, there generally aren’t any premiums on types of paper.

What about printed materials that are converted to PDFs and are posted online and sent via e-mail? Should the FSC label be removed before the PDF is created?
The New FSC Labeling Standard does not address the use of labels on electronic documents. However, it is recommended that either the FSC label is removed before posting the file online or an additional statement is inserted under the label stating that “The original document was printed on FSC-certified paper.”

With a blanket approval for a continuing item, do we have to re-submit for approval with the new version?
Upon switching to the new FSC labeling standard, all major exceptions, special approvals etc. will be discussed between certification bodies and certified companies.

Generally, as long as the certified company has shown that they have established a record of correct label use, they only need approval for first use of a new label category (100%, MIX, Recycled) or label with new product type (e.g. paper, wood, etc).

Confused … Label approval by Certification Body or Web site?
All FSC-certified companies must submit label approvals to their certification bodies (CBs). The CB may have either a Web site or e-mail address indicating where the label approvals should be directed.

What does it mean a printer has switched to the new standard? Does it mean once a printer has started using the new label they cannot use the old one?
No. All existing stocks may continue to be used and distributed.

Certified companies can transition to the new standard gradually, running some product lines with the new labels and some with the old label. Certificate holders do not need to transition to the new standard until January 2011. For more information, contact your certification body.

New designs should be used with the new labeling standard requirements and the old designs should follow the old standard (FSC-STD-40-201) for on-product labeling and promotional uses.

I know you mentioned that an FSC-certified company should manage the placement of the FSC logo; however, as a broker we outsource the creative. Is it okay that we have our creative designers do this or the printer we are using at the time place it in for us?
In general, only FSC-certified companies are provided with the ability place the final high-res image of the FSC label onto a document or product. (Designers place a low-res “for position only” label on the artwork.)

However, there can be cases where the certified company and their certification body may allow designers access to the high-res images for placement purposes. Contact your certification body for approval.

On the FSC site, is there a resource to prepare for a Chain of Custody Audit?
FSC Canada does have an overview document of the Chain of Custody requirements.

I was under the impression that converters could get outsourced printers to sign an Outsourced Agreement, which indicates that they would not necessarily need to be FSC certified.
FSC-certified companies can send jobs to non-certified printers to complete as long as the certified company retains legal possession of the products; it is part of the scope of their certification; they have an Outsourcing Agreement in place; a procedure for outsourcing; and all with the approval of their Certification Body. The certified company would still be able to place the FSC label on the document with their Trademark License code.

Will the claim also be required on invoices and orders? Or just the FSC COC number?
The Chain-of-Custody Standard requires that invoices should have the chain-of-custody number. However, if you are using the promotional logo on the invoice document, you will need to include the license code. See the chart below on when to use License codes and Chain-of-Custody certificate numbers.

Case	License code	CoC Cert number
On-product label	X
Promotional panel	X
Other promotional use of the logo	X
Text reference to certification	X
Invoice: promotional logo for template	X
Invoice: identifying the FSC certified products		X
Other sales and shipping documents		X

Does FSC certify paper merchants that distribute paper? Is there a list of merchants that are FSC certified?
All companies that process, transform, manufacture, convert or distribute forest products must be FSC Chain of Custody certified in order to put the FSC label on products. For a list of FSC-certified merchants in the US, visit www.fscus.org/images/documents/FSC%20certified%20paper%20merchants.pdf. For a list of FSC-certified merchants in Canada, visit www.fsccanada.org/papermerchants.htm.

Wanted to be sure I understood process. Does every new publication printed need to be certified? Or is the printer/vendor certified once and then jobs printed for printer’s customers can apply FSC certification?
To clarify, companies that process, transform, manufacture, convert or distribute forest products must be Chain-of-Custody (CoC) certified in order to put the label on products.

The CoC certified companies verify that the paper they purchase comes from an FSC-certified source, which is then verified by their certification company. Upon doing so, they are able to place the FSC label onto the document as a ‘stamp’ of authenticity. Each document/product needs to be approved by the certified companies’ certification body.

Is data available on what constitutes recycled fiber as many alternate fibers now exist. Which are or are not included?
FSC only certifies wood-based products. Tree-free fibers may indeed be included in the recycled fiber, but we do not have statistics on that.

Is there a FSC Webinar that reviews the recordkeeping requirements, or an  Excel spreadsheet with all the column headings?
Currently neither a Webinar nor an excel spreadsheet exist. However, FSC Canada does have an overview document of the Chain of Custody requirements at http://www.fsccanada.org/docs/fsccertification_chainofcustody_explained.pdf.

I work for a large printer, and we are triple certified. I have been the person who has been handling the logo approvals by sending to our Bureau. Can our company get a blanket approval of the logo usage instead of having to send an e-mail on each job for approval on logo handling?
Generally, certified companies should submit artwork of all new reproductions of the FSC trademarks to their certification body. However, provided that the certified company establishes a good record of correct trademark use, and with approval from the certification body, it is not necessary to re-submit labels for the same product type or with the same placement on the product, or for repeated use of promotional artwork.