PEFC Council PEFC UK

Conformity Assessment of the revised UK Forest Certification Scheme

Final Report

Indufor Oy Helsinki January 7, 2008

Copyright © 2008 by Indufor Oy All rights reserved. No part of this publication may be reproduced or transmitted in any form or by any means, electronic or mechanical, including, but not limited to, photocopying, recording or otherwise.

TABLE OF CONTENTS EXECUTIVE SUMMARY 1. INTRODUCTION 1.1 Development Process 1.2 Reporting RECOMMENDATION TO PEFCC BOARD OF DIRECTORS MATERIAL AND METHODS STRUCTURE OF THE UK FOREST CERTIFICATION SCHEME STANDARD SETTING FOR CERTIFICATION 5.1 Standards for Forest Management Certification 5.2 Standards for CoC Certification 5.3 Pilot Testing 5.4 Standard Review REQUIREMENTS FOR CERTIFICATION CRITERIA 6.1 General 6.2 Laws and Regulations 6.3 International Conventions 6.4 Level of Application 6.4.1 General 6.5 Group Certification 6.5.1 Individual Certification 6.6 Implementation of the Changes to Scheme 6.7 Appeals and Dispute Settlement PERFORMANCE REQUIREMENTS 7.1 Compatibility with Pan European Operational Level Guidelines REQUIREMENTS FOR CERTIFICATION BODIES AND PROCEDURES 8.1 Certification Bodies 8.2 Certification Procedures 8.3 Accreditation Procedures COMMENTS RECEIVED 1 4 4 4 5 6 8 9 9 14 14 15 17 17 18 19 19 19 20 22 22 23 24 24 26 26 28 30 32

2. 3. 4. 5.

6.

7. 8.

9.

LIST OF ANNEXES Annex 1 Annex 2 Annex 3 Annex 4 Annex 5 Annex 6 Minimum Requirements Checklist for Standard Setting Process Minimum Requirements Checklist for Scheme Compliance with the PEOLG Minimum Requirements Checklist for Certification Schemes and their Implementation Minimum Requirements Checklist for Scheme Specific CoC Standards Minimum Requirements Checklist for Certification and Accreditation Procedures Consultants response to Peer Review

LIST OF FIGURES Figure 1.1 Figure 4.1 Time Schedule on the Development of the UK PEFC Certification Scheme Structure of the PEFC UK Certification Scheme for SFM 4 8

LIST OF TABLES Table 5.1 Table 7.1 Interests Participating in the Steering Group Compliance of the Group/Individual Standard with PEOLG 10 24

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ABBREVIATIONS AND ACRONYMS AB CoC EA EMS EN ENGO FMU FSC GL GMO IAF ILO ISO NGO PEC PEFC PEFCC PEOLG QMS SFM TD UK UKAS UKWAS Accreditation Body Chain of Custody European Co-operation for Accreditation Environmental Management System European Standard Environmental Non-Governmental Organisation Forest Management Unit Forest Stewardship Council Guideline Genetically modified organism International Accreditation Forum International Labour Organization International Organization for Standardization Non-governmental Organization Pan-European Criteria Programme for the Endorsement of Forest Certification Schemes PEFC Council Pan-European Operational Level Guidelines Quality management system Sustainable Forest Management Technical Document United Kingdom United Kingdom Accreditation Service UK Woodland Assurance Standard

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EXECUTIVE SUMMARY RECOMMENDATIONS The United Kingdom (UK) Certification Scheme on Sustainable Forest Management (SFM) (Revision 2007) as documented in March 31, 2007 does not meet the Programme for the Endorsement of Forest Certification Schemes (PEFC) requirements due to the two non-conformities listed in points 2 and 8. The listed non-conformities are related to the Scheme documentation and do not hamper credible and reliable Scheme implementation according to the PEFC requirements. Therefore the Consultant requests that the PEFC Board discuss in this case the significance of fully conforming documentation against the credible and reliable Scheme implementation and considers the option for conditional endorsement. Justification for the recommendation for the conditional endorsement: 1. Independence of standard setting process conform to PEFC requirements The Steering Group, the stakeholder standard setting body and PEFC UK adopting the standard documents are independent from certification and accreditation processes. Certification and Accreditation Bodies (ABs) did not influence the decision-making or preparation of documents. 2. Documentation of standard setting process does not confirm to PEFC requirements The UK Certification Scheme does not have explicit rules that define the standard setting process. The UK Woodland Assurance Standard (UKWAS) Memorandum of Association, Articles of Association and Steering Group Rules describe the roles and positions of these bodies but do not set the basic rules for participatory standard setting process. However, the applied standard setting process is fully in conformance with the PEFC rules, which is proved by related minutes and other documentation. 3. Participatory process conforms to PEFC requirements The Steering Group consists of thirteen constituencies representing economic, social and environmental interests. The consultation as part of standard setting procedure ensured that all interested parties had the possibility to influence the development of the standard. The view of Steering Group and views of other interested parties presented in consultations were documented and considered as appropriate. The standard was agreed in consensus. UKWAS has procedures for establishment of an impartial dispute settlement body (the Interpretation Panel) that could address the grievances related to standard setting and standard interpretation. The Article of Association of the UKWAS and Steering Group Rules define the its own procedures, but not the procedures for standard setting or revision. However they require open access to all interested parties in the process. The Scheme contains an independent and impartial mechanism for dispute resolution during the standard setting process. The Interpretation Panel has its own rules and is an independent body, which contain equal representation of different interests. Interpretation Panel acts as a final stage of appeal in grievances related to standard setting.

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4.

Levels of implementation conform to PEFC requirements The Scheme includes options for group and individual certification. The resource manager certification is a modification of the group certification.

5.

Scheme and Performance requirements conform to PEFC requirements The performance requirements for group/individual certification establish together with relevant legislation compliance with the Pan-European Operational Level Guidelines (PEOLG). The Standard is applicable throughout the nation and in different types of forests. The performance requirements are in compliance with the PEFC Council (PEFCC) requirements.

6.

Compliance to legislation is required according to PEFC rules The standard rely on legislation and the target performance on forest certification is to achieve the conformity with normative level requirements. The national forest policy objectives set out in the UK Forestry Standard (the Government’s approach to Sustainable Forestry) are taken into consideration when developing the UK Assurance Standard. The UK has ratifies all international conventions referred to in PEFC Technical Document and therefore the respective requirements are incorporated into legislation. The Scheme requires that participants to individual and group certification comply with legislation and the compliance is verified in audits.

7.

Timber tracing is implemented according to PEFC rules The PEFC UK adopted the international PEFC standard for Chain of Custody (CoC) verification in December 2005. The Board of PEFC UK adopted at the meeting of the Directors on 28 March 2007 the following new Appendices to the CoC standard: • • • • • Appendice 1 (27 October 2006), Appendice 6 (27 October 2006), Appendice 7 (27 October 2006) and Appendice 8( 27 October 2006), as well as Guideline (GL) 6/2006 (Notification of the Certification bodies).

The PEFC Logo Use rules apply to the licensing and control of PEFC logo use rights within the Scheme. 8. Certification and accreditation processes do not fully comply with PEFC requirements The Scheme is in compliance with the PEFC requirements regarding the certification procedures. The Scheme sets requirements on the use of external information in audits, through stakeholder consultation, and on the public availability of summaries to certification reports. The Scheme provisions for accreditation conform to PEFC requirements. The ABs shall operate in accordance to the ISO 17011 standard and other relevant documents. The Scheme does not explicitly require that auditors and auditing procedures must comply with ISO 19011 Standard, which is not in the line with PEFCC requirements. However, accredited certification bodies must apply certification procedures and employ competent auditors as required in the accreditation standards (ISO Guides 62, 66, 65) and other provisions of AB (United Kingdom Accreditation Service UKAS).

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The Scheme documentation provides the participants in group certification with the attestation of participation from the certificate holder (the Group Manager). 9. PEFC notification of the Certification Bodies The PEFC UK complies with the PEFCC requirements on the notification of the certification bodies. According to the Scheme, also the certification bodies operating CoC certification against the PEFC international CoC standard in countries without a PEFC National Governing Body shall be notified by the PEFCC The final draft assessment report is submitted to the PEFC Council nominated peer review panel that verifies the consistency and reliability of the report. The peer reviewers’ comments and consultant replies are annexed (as Annex 6) to the assessment report. The Consultant duly took the peer reviewers’ appropriate comments into consideration.

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1.

INTRODUCTION 1.1 Development Process The PEFC UK Certification Scheme for SFM (The Scheme) was first adopted by PEFC UK Ltd in 2001 and endorsed by PEFCC in 2002 (Figure 1.1). Since 2002, PEFC UK has incorporated a number of amendments to the original Scheme. As the original Scheme expires in 2007, the Scheme has now been redrafted to meet current PEFCC requirements. The revised Scheme is based on two national UK published documents namely, the UK Forestry Standard (the Government’s Approach to Sustainable Forestry), which was revised in April 2004, and the Forest Management Certification Standards, which is known as the UK Woodland Assurance Standard (UKWAS; the Standard). UKWAS has undergone a review and public consultation exercise during 2005 and 2006. The revised document has been published on 1 November 2006. The board of PEFC UK Ltd. adopted the revision of the whole Scheme, on the 5 July 2006. The PEFCC appointed Indufor Oy to carry out the re-evaluation of the Scheme against the requirements of the PEFCC. The adoption of the Scheme by the PEFC UK Ltd. prior to publication of the UKWAS standard and the Scheme is not in conflict with the PEFCC requirements for revision procedures. This final re-assessment report is based on the documentation provided by the PEFC national governing body, the PEFC UK Ltd in December 2006 and March 2007 as well as additional clarifying information received from the PEFC UK Ltd. in February-March 2007. Figure 1.1 Time Schedule on the Development of the UK PEFC Certification Scheme
PEFC S chem e adopted by PEFC UK

U KW A S launched

PEFC UK Ltd established

P E FC U K S chem e endorsed by PEFC C ouncil

U KW A S C om pany established

U KW A S revised standard

1999

2000

2001

2002

2003

2006

1.2

Reporting The conformity assessment results are presented in this main report and the supporting Annexes, which give detailed conformity assessment on all the checklist questions and Pan European Operational Level Guidelines. The structure of the report follows the reporting guidelines given by the PEFCC, where conformity is reported to each key question presented in the PEFC Minimum Requirement Checklist. The number in parenthesis refers to the checklist question number. The results are reported separately (i) for the conformity of the Scheme documentation to the requirement, and (ii) for its practical implemented during the scheme development.

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2.

RECOMMENDATION TO PEFCC BOARD OF DIRECTORS The UK Certification Scheme on SFM (Revision 2007) as documented in March 31, 2007 does not meet the PEFC requirements due to the two non-conformities listed in Chapters 5.1 (checklist question 10), 8.1 (question 8) and 8.2 (question 13). The listed non-conformities are related to the Scheme documentation and do not hamper credible and reliable Scheme implementation according to the PEFC requirements. Therefore the Consultant requests that the PEFC Board discuss in this case the significance of fully conforming documentation against the credible and reliable Scheme implementation and considers the option for conditional endorsement. The justifications for the conclusion are presented in the Chapters 5-8.

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3.

MATERIAL AND METHODS The evaluation is based on the documentation of the PEFC UK Certification Scheme as it was originally submitted to the PEFCC in September 2006. The PEFC UK applied for the interruption of the Scheme re-evaluation process in 21 March 2007. This final report is based on the documentation submitted by the PEFC UK Ltd. on 4 April 2007 after the interruption process. The PEFC UK Certification Scheme includes the following documentation: 1. PEFC UK Certification Scheme for SFM (Revision March 2007) - hereafter Scheme 2. The UK Forestry standard “ The Government’s Approach to Sustainable Forestry (April 2004, Revision, Annex 1 to Scheme documentation) 3. UKWAS (August 2006, Revision, Annex 2) 4. PEFCC Annex 4 CoC of Forest Based Products: Requirements (Annex 3) (Amended on 17 June 2005) 5. PEFCC Guideline: GL2/2006 PEFCC Minimum Requirements Checklist (Annex 4) 6. Northern Ireland Forestry: A Strategy for Sustainability and Growth (Annex 5) 7. UK Indicators of Sustainable Forestry (Annex 6) 8. UKWAS Description of Standard Setting Process (Version 1:18.01.07) The following documentation of the Scheme is obligatory: • • • • PEFC UK Certification Scheme for SFM (Revision March 2007) UKWAS (2006, Revision, Annex 2) The UK Forestry standard “The Government’s Approach to Sustainable Forestry” (April 2004, Revision, Annex 1 to Scheme documentation) PEFCC Annex 4 CoC of Forest Based Products: Requirements (Annex 3)

The Articles of Association of UKWAS as well as Steering Group Rules were not included in the Scheme documentation. The Consultant was, however, compelled to include them into the assessment, as the Scheme documentation frequently refers to these documents. The Articles of Association of UKWAS as well as Steering Group Rules are accessible at UKWAS Internet web page. The Scheme includes also additional Supporting Reference Documentation referred to in the Scheme documentation: • • • • • • • • • • • • • • • PEFC UK Ltd: UK Certification Scheme for SFM (2001) PEFCC Statutes PEFCC Annexes 1-7 to the Technical Document (adopted by the General Assembly of the PEFCC on 22 November 2002 and revised on 28 October 2005) (Revisions of October 2006 not adopted during the assessment) Pan European Criteria and Indicators for SFM PEOLG: Pan European Operational Level Guidelines for SFM ISO 19011:2002 ISO Guide 61:1996 ISO Guide 62:1996 ISO Guide 65 ISO Guide 66:1999 Core International Labour Organization (ILO) Conventions Cartagena Protocol on Bio-Safety Convention on Biological Diversity Convention on International Trade in Endangered Species of Wild Flora and Fauna Kyoto Protocol to the United Nations Framework Convention on Climate Change

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The final draft assessment report is submitted to the PEFC Council nominated peer review panel that verifies the consistency and reliability of the report. The peer reviewers’ comments and consultant replies are annexed (as Annex 6) to the assessment report.

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4.

STRUCTURE OF THE UK FOREST CERTIFICATION SCHEME PEFC UK Ltd. is the national PEFC Governing Body. The PEFC UK SFM Standard is managed by an independent company - UKWAS, which has coordinated the standard development since its establishment in 2003. Before 2003, the standard development was coordinated by the Technical Working Group with the assistance of the UK Forestry Commission. The PEFC UK is also a member and consultee of the UKWAS Steering Group (Figure 4.1). The Scheme includes two forest management standards: the UKWAS and the UK forestry Standard - the Governments Approach to Sustainable Forestry. Certification audit is made against the UKWAS standard. Figure 4.1 Structure of the PEFC UK Certification Scheme for SFM
Act on the Establishment of the IFC

PEFC UK Ltd. Act of establishment Articles of Association

UKWAS Members

Steering Group

Forum Technical Working Group

Interpretation panel

Logo use licenses

Number of issued certificates Non-conformities in logo use

UKAS - United Kingdom Accreditation Service - national accreditation body for the UK

SFM certificate holder(s) CoC certificate holders

Certification bodies Issues certificates

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5.

STANDARD SETTING FOR CERTIFICATION 5.1 Standards for Forest Management Certification (1) Has the development of the certification standards been independent from the certification and accreditation process? Annex 2, 3.2 • Conclusion 1 Documentation Conforms to the PEFC requirements The UKWAS Company’s Memorandum and Articles of Association do not let the UKWAS to undertake certification or accreditation activities, nor let the certification bodies to influence the standard setting procedure. • Conclusion 1 Practice Conforms to the PEFC requirements The UK PEFC Certification Scheme has been developed independent from certification and accreditation processes as required by the PEFC. None of the 13 members of the Steering Group have vested interests with certification or ABs (Scheme 6.3). (6) Have all relevant interested parties representing the different aspects of SFM been invited to participate in the standard setting process and a created Forum? Annex 2, 3.4.1 • Conclusion 2 Documentation Conforms to the PEFC requirements The scheme documentation requires that the commencement of standard setting process and information on the development shall be communicated publicly (Description of standard setting process B3). Interested parties representing key constituencies: economic, social and environmental, including non-governmental organisations (NGOs) and environmental non-governmental organisations (ENGOs) shall be invited to participate in the standard setting process (Scheme 6.3). The Description of standard setting process document includes the description and time schedule for the standard setting procedures, and the Scheme description also provides indications of the standard revision process and schedule (Scheme 6.1; 6.5). • Conclusion 2 Practice Conforms to the PEFC requirements The documentation of the Scheme concerning the transparency and consultation comply with the requirement, for the part of the communication with the public. Appropriate records are available on the invitations (Description of standard setting process B3, B4). (7) Do consensus-building procedures of the Forum provide for balanced representation of interest categories? Annex 2, 3.4.1 • Conclusion 3 Documentation Conforms to the PEFC requirements Structure of the Steering Group provide for balanced representation of interests (Scheme 6.3). UKWAS Articles of Association require the Steering Group to adopt the Steering Group Rules, which define the Steering Group procedures. The Articles of Association (Scheme 6.1; Article 39 of Association) require that the Steering Group initiates the standard setting process. The Steering Group Rules define that it represents 13 constituencies (Scheme 6.3) (Table 5.1).

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Table 5.1

Interests Participating in the Steering Group Maximum representation of each constituency 2 6 5 4 6 2 3 2 2 2 2 3 1 1 41

Interest Chair and secretary Woodland owners Forest Managers State Forestry representation Environmental organizations Forest users Wood processing interests Wood products industry Forest workforce Countryside agencies Local government Standard setting bodies Other Unallocated (held by PEFC UK) Total

Source: Scheme 6.3 Current Membership Base

• Conclusion 3 Practice Conforms to the PEFC requirements Standard setting process and possibility to participate in it was publicly informed. Forum participants represented different interests in a way that ensures broad representation of interests and standard setting process was consultative and searched for different views of all interested parties. Extensive consultation procedures provide for balanced representation of interests (Scheme 6.7). Steering Group represents 13 constituencies. B 4 Consultations provided the possibilities for all parties to be involved in the standard setting process. (8) Have the views of all relevant interested parties been documented and considered in an open and transparent way? Annex 2, 3.4.1 • Conclusion 4 Documentation Non-conformance to the PEFC requirements Documentation of the Scheme (Standard setting process document) appropriately requires to communicate the information of the standards setting process to the public (B3), however the Articles of Association or the Steering Group Rules as standard setting documents do not require transparent documentation. • Conclusion 4 Practice Conforms to the PEFC requirements The Standard setting process is well documented and all minutes (Scheme 6.6) and records are documented and made public in Internet or on request (Description of standard setting process B3, B4). Decision-making procedures, publication of documentation and direct notification of stakeholders were common practices in the process (B 3, Scheme 6.7). The Description of standard setting process document includes the description and time schedule of the standard setting procedures, although the Scheme description also provides indications of the standard revision process and schedule (Scheme 6.1; 6.5).

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(9) Has the formal approval of standards been based on evidence of consensus? Annex 2, 3.4.1 • Conclusion 5 Documentation Conforms to the PEFC requirements According to Standard setting process documents all decision in the Steering Group are made in consensus (B2). The Articles of Association (40.2; 40.3) define the voting procedures and require the unanimous vote of those attending the meeting (C3). All documents related to the standard setting process shall be available to all interested parties (B3). • Conclusion 5 Practice Conforms to the PEFC requirements Voting procedures of the Steering Group ensure consensus (B5), and all decisions were made on the basis on consensus B 2, B4). (10) Has the Forum defined its own written procedures, which have been made available to interest parties upon request? Annex 2, 3.4.1 • Conclusion 6 Documentation Documentation does not conform to the PEFC requirements UKWAS Articles of Association and Steering Group Rules (B 2, Article of Association 40.1) define the roles and responsibilities in standard setting. The Steering Group has its own written procedures, but the procedures do not indicate any of the standard setting procedure requirements. The Articles of Association and Steering Group rules are available in the Internet. • Conclusion 6 Practice Conforms to the PEFC requirements The UKWAS Articles of Association and Steering Group Rules defining some guidance to standard setting were adopted in 25 November 2002 and 15 December 2003 respectively, prior to the Scheme revision. Despite the lack of explicit standard setting rules the procedure was implemented according to the PEFC rules (Standard setting process document). (11) Do the written procedures for standard setting contain an appeal mechanism for impartial handling of any substantive and procedural complaints? Annex 2, 3.4.1 • Conclusion 7 Documentation Conforms to the PEFC requirements The procedures of the Steering Group contain an appeal mechanism for dispute resolution related to the Standard interpretation and standard setting. The Interpretation panel, which is appointed by the Steering Group, provide Interpretation Notes for standard users. The Interpretation panel also acts as a final stage of appeal for procedural matters related to the standard setting. The interpretation panel decides on its own rules and procedures. The decisions of the Interpretation panel are documented and publicly available. • Conclusion 7 Practice Conforms to the PEFC requirements Substantive or procedural complaints related to the standard setting are considered and determined by the Steering Group. Appeals against Steering Group decisions are addressed to the Interpretation panel, which acts as a final stage of the appeal process. The independent chairman chairs the panel and the members of the panel equally represent social, economic and environmental interests.
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(12) Has the start of the standard setting process been communicated to the public? Annex 2, 3.4.2 • Conclusion 8 Documentation Non-conformity to the PEFC requirements The scheme documentation requires that the commencement of standard setting process and information on the development shall be communicated publicly (Description of standard setting process B3). Interested parties representing key constituencies: economic, social and environmental, including NGOs and ENGOs shall invited to participate in the standard setting process (Scheme 6.3). Documentation of the Scheme (Standard setting process document) appropriately requires to communicate the information of the standards setting process to the public (Scheme 6.5, 6.7) (B3), however the Articles of Association or the Steering Group Rules as standard setting documents do not address the issue of communicating the start of the standard setting to the public • Conclusion 8 Practice Conforms to the PEFC requirements Communication via e-mail, web page statements and in hard copy. Information on standard setting process available at UKWAS office and UKWAS web page (B 3, B 4). (13) Has the information on the development process been distributed and discussed? Annex 2, 3.4.2, • Conclusion 9 Documentation Conforms to the PEFC requirements The information on the development process has been distributed to the Steering Group members as well as to all interested parties. (B3) According to Standard setting process document, no information on the development of the standard shall be withheld unreasonably (B3). The information on the process has been distributed through UKWAS web sources to all interested parties as well as by hard copies to the steering Group members (B3). Information on the Steering Group meetings is available at UKWAS office and Internet pages. According to Standard setting process document summaries of comments on each draft as well as all correspondence in relation to development of the standard shall bee kept by the Steering Group (B7). • Conclusion 9 Practice Conforms to the PEFC requirements Scheme 6.5, 6.7, B 3, B 4 Distribution via e-mail, Internet and in hard copies. Information on standard development process available at UKWAS office and UKWAS web page. (14). Has the final draft standard been available to all interested parties, e.g. by posting it on the Internet? Annex 2, 3.4.2 The Scheme documentation requires that copies all draft shall be kept by the Steering Group (B7) and the information on the standard development information shall be communicated publicly (B3). • Conclusion 9 Practice Conforms to the PEFC requirements The draft standards have been distributed via e-mail, Internet and in hard copies (B 4).

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(15) Has the final draft standard been sent out for formal national consultation process? Annex 2, 3.4.3 • Conclusion 10 Documentation Conforms to the PEFC requirements The Scheme documentation requires that the final draft standard (”a pre-approval draft” as defined in the documentation) shall be submitted to the formal national consultation process (Standard setting process description B 4). • Conclusion 10 Practice Conforms to the PEFC requirements Formal national consultation took place between June 2003 and January 2006 (Scheme 6.7, B 4). (16) Have views of interested parties been discussed? Annex 2, 3.4.3 • Conclusion 11 Documentation Conforms to the PEFC requirements The Scheme documentation does not explicitly require that the views of all parties should be discussed, however the Standard setting process document requires that the formal responses to comments received (from the interested parties) shall be available to all interested parties (B3). • Conclusion 11 Practice Conforms to the PEFC requirements The Steering Group has documented and taken into consideration all the views presented during the consultation. All comments are recorded (B7; UKWAS Revision Consultation Returns and Steering Group Decision July 2004 as an example of the discussion of views of different interested parties). (17) Has the Forum given general information on the changes made as a result of a consultation process? Annex 2, 3.4.3 • Conclusion 12 Documentation Conforms to the PEFC requirements The Standard setting process document states that Steering Group shall keep records of each draft as well as consultation drafts (B7). The information on these should be publicly communicated (B7). • Conclusion 12 Practice Conforms to the PEFC requirements Information on draft standard was all the time available at UKWAS web site. Stakeholders notified directly on the consideration of their views (B3, B7). UKWAS had copies of all drafts (B 7). (18) Had the consultation been at least 60 days? Annex 2, 3.4.3 • Conclusion 13 Documentation Conforms to the PEFC requirements According to the Standards setting process document the minimum requirements for consultation periods should be as follows (B4): 1. Initial Stakeholder Consultation: 60 days 2. A “revision draft consultation”: 60 days 3. A “pre-approval draft consultation” 60 days
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• Conclusion 13 Practice Conforms to the PEFC requirements Consultation took place between June 2003 and January 2006, which exceeds 60 days (Scheme 6.7). The consultation periods were as follows: 1. Initial consultation: June - September 2003 2. Second round of consultation: April - June 2004 3. Third consultation: 16 December 2005 - 16 January 2006

5.2

Standards for CoC Certification The PEFC UK adopted in December 2005 the PEFCC International CoC Standard (Annex 4 of the PEFC Technical Document) as the standard for CoC verification and included it as Annex 3 to the Scheme documentation, which is in compliance with PEFCC requirements. The requirements for CoC verification are in the original form as presented in the PEFC TD Annex 4 but the Scheme has not yet adopted the amendments approved in October 2006 to the standard (Appendices 7 and 8 to the PEFC TD Annex 4). However the PEFCC allows the Schemes to adopt the changes to TD Annex 4 no later than 1.5.2007, which provided that if PEFC UK will adopt changes in the defined period, complies with PEFCC requirements. • Conclusion 14 Standard setting The Standard setting procedures on CoC verification are not applicable in the UKWAS Scheme. • Conclusion 15 Performance requirements CoC certification is carried against the PEFC TD Annex 4, and its Appendices as defined in October 2006.

5.3

Pilot Testing (33) Have the first results on the testing of the final drafts for national/subnational forest certification standards and their implementation arrangements been available prior to submission of the scheme for the PEFCC endorsement and mutual recognition? Annex 2, 5 • Conclusion 16 Documentation Conforms to the PEFC requirements The Scheme documentation does not explicitly require testing during the revision process, but the Description of standard setting process document addresses (as Chapter B8) the forest testing as a part of the revision process. • Conclusion 16 Practice Conforms to the PEFC requirements In revising the standards, pilot testing and/or experience gained from the scheme implementation was used to inform the revision process. PEFCC deems that in standard revisions separate pilot testing is not necessary if the extent of changes made do not justify it.

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(34) Has appropriate action been taken to incorporate improvements and recommendations prior to submission of the scheme for the PEFCC endorsement and mutual recognition process? Annex 2, 5 • Conclusion 17 Practice Conforms to the PEFC requirements All experiences gained in the Scheme implementation is taken into consideration in the revision.

5.4

Standard Review (35) Have the standards on forest and CoC certifications been reviewed at least every 5 years or is it foreseen to review these standards at least every 5 years? Annex 2, 6.1 • Conclusion 17 Documentation Conforms to the PEFC requirements The Steering Group of UKWAS is responsible for starting and coordinating the revision of the standard (Scheme 6.2 and Articles of Association). The standard is reviewed and revised as necessary on a five-year cycle. The revision of the standard shall include a broad consultation and participation of the stakeholders. The records of all documentation concerning the standard revision process should be available at UKWAS (Description of standard setting process D2; D3). The standard revision process should incorporate the following elements: (a) An Interpretation Review – a consideration of any advice developed by the Interpretation Panel. (b) A Technical Review – a consideration of any new scientific or technical knowledge. (c) An International Benchmarking Review – a comparison with any equivalent accredited standards of a similar geographical or ecological scope of application, and an evaluation of whether there are any substantial differences in the overall cost/benefit balance of compliance for similar types of enterprise with similar forest conditions (to be provided by the certification schemes.) (d) A Standard Users’ Feedback Review - a consideration of feedback from certificate holders and accredited certification authorities. (e) A Review of the Initial Stakeholders’ Consultation – a consideration of consultees’ comments and responses. (f) A Small and Low Intensity Managed Woodlands Review – a consideration of the impact and applicability of the standard for small and low intensity operations. (g) A Certification Schemes’ Requirements Review – a consideration of advice (to be provided by the certification schemes) on any new or revised policies, procedures or guidance that is relevant to the revision. National certification schemes should seek advice and guidance from their international body when compiling their advice. As a member of the UKWAS Steering Group, the PEFC UK participates in the development and reviewing of the standard. • Conclusion 17 Practice Conforms to the PEFC requirements The Standard revision process was carried out according to the Scheme guidelines and incorporated the required elements of the scheme revision. The revision fulfilled the participatory requirement providing all interest parties (Steering Group members and non-member) with possibility to participate in the revision process. The views of participants were appropriately documented. Transparency of the process was

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ensured by notifying the Steering Group members and publishing information on the revision process in the Internet. Revision lasted two years and the revised Standard was published 1 November 2006.

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6.

REQUIREMENTS FOR CERTIFICATION CRITERIA 6.1 General The performance requirements for group, individual and resource manager certification are stated in the document UKWAS standard. The standard follows the structure of Pan European Criteria defined in the MCPFE and cover all aspects of SFM. The UKWAS standard is developed on the basis of UK Forestry Commission standard for SFM that reflects the national policies in implementation of SFM in the country. The criteria are marked as the “Requirements” in the UKWAS so that they are the compulsory elements of the standard. The indicators are called the “Means of verification“ which act as a compulsory reference base for auditors. The “Guidance notes” are the tools for understanding how the requirements should be applied in practice. However the certification authorities shall take full account of the “Guidance notes” given for each ”requirement” when assessing conformance with the standard. The requirements are applicable at the Forest Management Unit (FMU) level. The requirements state the objectives of SFM and the Means of verification and Guidance notes clearly indicate the verification documentation or the procedures. (1) Are the criteria relevant to all types of forests and management systems, which exist in the nation/region they have been elaborated for? Annex 3, 3.5 • Conclusion 18 Documentation Conforms to the PEFC requirements The UKWAS is applicable to all types of forests independent from ownership or management system. • Conclusion 18 Practice Conforms to the PEFC requirements The UKWAS requirements are successfully implemented throughout the country in different forests of different ownership types. The revised set of requirements does not change or limit the applicability of the UKWAS standard. (2) Do the criteria clearly express the objectives for forest management that can be unambiguously verified by different auditors? Annex 3, 3.5 • Conclusion 19 Documentation Conforms to the PEFC requirements Criteria (requirements) state clear qualitative objectives, indicators (means of verification) present measures to achieve the objectives. Indicators do not always cover the scope of a criterion but guidelines presented in Guidance as well as references to normative plans (legislations) compensate the gaps. • Conclusion 19 Practice Conforms to the PEFC requirements The UKWAS requirements can be implemented and audited in practice. (3) Are management and performance requirements applicable at the level of a FMU? Annex 3, 3.5 • Conclusion 20 Practice Conforms to the PEFC requirements Performance requirements at group/individual level are applicable at FMU level

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(4) Are management and performance requirements applicable optionally also at group and regional levels? Annex 3, 3.5 • Conclusion 21 Practice Conforms to the PEFC requirements Management requirements are applicable at individual and group level.

6.2

Laws and Regulations (5) Are the national certification criteria in compliance with national laws programs and policies? Annex 3, 3.2, 3.5 • Conclusion 22 Documentation and Practice Conforms to the PEFC requirement The UKWAS standard is based on the national forest policy and legislation. The Scheme is based also on the UK Forestry Standard, which reflects the UK Governments approach to forest management and incorporate the national PanEuropean Criteria (PEC) commitments of the UK Government (Scheme 4.3, UKWAS 1.1.1). (6) Are the references to national laws, programs and policies indicated in the scheme documentation when relevant, e.g., if the requirement of the PEOLG is not addressed in the certification criteria but is included in normative regulations? Annex 3, 3.5 • Conclusion 22 Documentation Conforms to the PEFC requirement The UKWAS requirements refer to UK Forestry Standard and compulsory legislation in order to reach full compliance with PEOLG. (7) Does the scheme include the requirement that any apparent violation of the legislation shall be taken into consideration in internal and external audits Annex 3, 3.2 • Conclusion 21 Documentation Conforms to the PEFC requirement The scheme requires that the applicant shall conform to the relevant legislation and norms and this will be verified in audits (UKWAS 1.1.1). Certification body will verify that there is no evidence of non-compliance with relevant legal requirements (UKWAS 1.1.1). • Conclusion 21 Practice Conforms to the PEFC requirement Requirement to comply with legislation is included in the UKWAS standard and thus verified in the conformity audits in practice.

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6.3

International Conventions (8) Are the Core ILO Conventions ratified by the country and implemented through the legislative framework? Annex 3, 3.3 • Conclusion 22 Documentation Conforms to the PEFC requirement The UK has ratified the international conventions specified by the PEFC (Scheme, Appendix 4; ILO conventions referred within the structure of UKWAS) and the Convention requirements are taken into consideration in the relevant national laws (see Annex 3 of the assessment). • Conclusion 22 Practice Conforms to the PEFC requirement Requirement to comply with legislation is included in the UKWAS standard and thus verified in the conformity audits in practice. The requirements stated in the Conventions ratified by the UK are incorporated into the national legislation. (9) Do the national certification criteria address the core elements of those Core ILO Conventions, which have been not ratified by the country? Annex 3, 3.5 Not applicable because UK has ratified all the core Conventions and their requirements are incorporated into the national legislation.

6.4

Level of Application 6.4.1 General

The Scheme includes options for individual, group and resource manager certification. In resource manager certification an authorized manager is responsible for the management of forests belonging to various owners. It is a modification of the group certification. The Scheme presents the rules for individual, group and resource manager certification including the authorities and responsibilities (Scheme Chapter 7.3). The Chapter 7.3 defines the duties and tasks of applicant and participants in individual, group and resource manager certification. (13) Are the applicants, the certified areas and owners/managers/others actors clearly identified documentation? Annex 3, 4.1 • Conclusion 23 Documentation Conforms to the PEFC requirement Scheme documentation (Section 7.3) define that applicants are woodland owners or forest enterprises for individual, group or resource manager certification. (14) Does the scheme documentation require that all actors involved in or operating on the certified area comply with the certification requirements? Annex 3, 4.1 • Conclusion 24 Documentation Conforms to the PEFC requirement Scheme description (Scheme 7.3, 7.3.4, 7,3,8) requires that all actors participating in certification on individual or group level should comply with certification requirements. participating forest in the scheme

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• Conclusion 24 Practice Conforms to the PEFC requirement All the described implementation levels have been applied in UK. The certification bodies verify that the Scheme requirements have been implemented in the group and resources manager certification. (15) Does the scheme documentation require that all actors individually certified or participating in regional/group certification are responsible for ensuring that contractors’ activities and operations meet the respective forest management criteria? Annex 3, 4.1 • Conclusion 25 Documentation Conforms to the PEFC requirement Scheme documentation requires that employees and contractors activities meet the respective forest management criteria (Scheme 7.3.4, UKWAS 1.1.1, 4.1.1).

6.5

Group Certification The Scheme requires that all members of the group must formally commit to complying with all requirements of the standard in respect of all forests areas included in the scope of the particular group scheme concerned. The Group shall be formally identifiable Group entity and has a Group manager. The Group manager is responsible for administration of Group Entity’s activities, but not for the actual forest management activities. The Resource Manager certification is a modification of Group Certification. In Resource Manager certification the Group Entity delegate all day-to-day responsibilities for forest management, including management planning, forest operations, harvesting etc. to the Resource Manager. In Resource Manager certification, each woodland owner must make contractual commitment to have their forest areas managed in accordance with the requirements of UKWAS. The Resource Manager then implements the commitment on behalf of the Client group (Scheme 7.3.6). In order to be eligible to apply for group certification the Group entity must clearly define and document the respective responsibilities of the Group entity and the Group members. All members must accept contractual responsibility to the certification Body for ensuring that the requirements of UKWAS are implemented by all Group Members on the forest areas covered by the certificate. Members must set out clearly documented criteria for eligibility and on-going membership of the group (Scheme 7.3.7). (33) Does the scheme documentation clearly define who the applicant is for group certification? Annex 3, 4.1 b • Conclusion 26 Documentation Conforms to the PEFC requirement Scheme documentation (Section 7.3, 7.3.7) define that applicant in group certification is a Group Manager who acts on behalf of group members. The Group applying for Group certification has to be formally identifiable (Scheme 7.3.3; 7.3.7), which however does not imply that the group has to be a legal entity although it requires that it is independent organization/body or individual acting on behalf of the group.

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(34) Does the scheme documentation describe the applicant’s responsibility to assure the compliance of all participants with the certification requirements? Annex 3, 4.1 b • Conclusion 27 Documentation Conforms to the PEFC requirement All members of the group must formally commit to complying with all requirements of the standard in respect of all forests areas included in the scope of the particular group scheme concerned. Scheme 7.3.4 Basis of Group Certification (35) Does the scheme documentation describe the applicant’s responsibility to ensure that credible registers are kept of participants to certification and certified forest area? Annex 3, 4.1 b • Conclusion 28 Documentation Conforms to the PEFC requirement Group Members shall set out clearly documented criteria for eligibility and on-going membership of the group Scheme 7.3.7. The Scheme also requires the Group Entity to keep records of the group members (Scheme 7.3.7).

(37) Does the scheme documentation require that total forest area participating in group certification is recorded? Annex 3, 4.1 b • Conclusion 29 Documentation Conforms to the PEFC requirement The Scheme requires that all members of the group must formally commit to complying with all the requirements of UKWAS in respect to all forests areas included within the scope of the particular group Scheme concerned. The Scheme also requires that Group Entity must accept contractual responsibility to the Certification Body for ensuring that the requirements of UKWAS are implemented by all Group Members for forest areas covered by the certificate. (Scheme 7.3.4,7.3.7) The Scheme also requires the Group Entity to keep records of the group members (Scheme 7.3.7). (39) Does the scheme documentation define the responsibilities and authorities of the applicant and participating forest owners/managers for the inclusion of new participants and to inform the certification body thereof? Annex 3, 4.1 b • Conclusion 30 Documentation Conforms to the PEFC requirement The Scheme requires that Group Entity sets clearly documented criteria for eligibility and on-going membership of the group. The Scheme does not give guidance on the content of the criteria (Scheme 7.3.7). Although the Group manager develops the rules for inclusion and expulsion of participants the certification body is required to develop assessment procedure to verify the conformity to these rules. (40) Does the scheme documentation define the responsibilities and authorities of the applicant and participating forest owners/managers for the internal control of conformity and follow up corrective and/or preventive measures? Annex 3, 4.1 b

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• Conclusion 31 Documentation Conforms to the PEFC requirement Administrative and forest management policies that are relevant to the whole group (e.g. monitoring) shall be implemented by the Group Entity or by individual Group Member (Scheme 7.3.4). (41) Does the scheme documentation describe that the forest management certificate is issued to the applicant (certificate holder)? Annex 3, 4.1 b • Conclusion 32 Documentation Conforms to the PEFC requirement The Group certificate and Resource Manager certificate is issued to the applicant as required by the PEFC (Scheme 7.3.9; 7.3.13). (42) Does the scheme documentation describe that participants in group certification shall receive either a copy of the regional certificate including the appendix (when applicable) listing all participating forest owners or an individual attestation issued by the certification body or the applicant which refers to the main certificate? Annex 3, 4.1 b • Conclusion 33 Documentation Conforms to the PEFC requirement The group member will receive a Certificate of attestation from the Group manager to affirm the membership of the group (Scheme 7.3.9).

6.5.1

Individual Certification

(43) Does the scheme documentation describe that forest owner should submit all the forest area under his management in the catchment area of the certification scheme in the certification? • Conclusion 34 Documentation Non-conformity to the PEFC requirements Although according the scheme all members must formally commit to complying with all the requirements of UKWAS in respect of all forest areas included within the scope of the particular group Scheme concerned (Scheme 7.3.4), the scheme does not explicitly require the group members to submit all the forest area under his management in the catchment area.

6.6

Implementation of the Changes to Scheme (44) Does the scheme documentation define transition period(s) for implementation of changes to the endorsed scheme in compliance with chapter 5 of Annex 3? • Conclusion 35 Documentation Conforms to the PEFC requirements The Scheme documentation does not explicitly indicate the exact time period in which the any changes must be implemented. However, the scheme documentation states that PEFC UK adopts a policy for the implementation of Changes and/or revisions induced by PEFCC, which meet required implementation dates (Scheme 2.7).

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6.7

Appeals and Dispute Settlement (45) Has the PEFC National Governing Body set up or appointed an impartial and independent dispute settlement body on a permanent basis or does it have written procedures for the establishment of a dispute settlement body on an ad hoc basis? Annex 3, 5.1 • Conclusion 36 Documentation Conforms to the PEFC requirements Complaints arising from interpretation of the standard shall be remitted to the Interpretation Panel of the Steering Group of the UKWAS. The PEFC UK as a National Governing Body is a member of the Steering Group. Complaints arising from the standard setting are remitted to the Interpretation Panel of Steering Group of the UKWAS. The procedures are publicly available. The Interpretation panel is not independent to address disputes related to standard setting, because Steering Group guides the standard setting process. According to the Scheme, the certification authorities shall have a formal dispute management procedure, which is open to all parties at any time, to deal with noneconformance and challenges. All disputes between the applicant and certification body shall be resolved using certification body’s own procedure (Scheme 6.12). • Conclusion 36 Documentation Conforms to the PEFC requirements No grievance procedures on interpretation and implementation of the revised Scheme have been raised. The Interpretation Panel is summoned on ad hoc basis. (46) Has the PEFC National Governing Body established and have documented procedures for an independent dispute settlement body, either permanent or ad hoc, that takes care of those complaints arising from forest management or CoC scheme implementation that cannot be addressed in the dispute settlement procedures of the relevant certification or AB? Annex 3, 5.1 • Conclusion 36 Documentation and practice Conforms to the PEFC requirements Interpretation Panel of the Steering Group of the UKWAS discusses the appeals. Rules and procedures are publicly available.

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7.

PERFORMANCE REQUIREMENTS 7.1 Compatibility with Pan European Operational Level Guidelines The compliance of the group/individual standard (the UKWAS) with PEOLG is presented in Table 7.1. A detailed conformity assessment is presented in the Annex 2 to this report. Table 7.1 Compliance of the Group/Individual Standard with PEOLG
Compliance Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply Comply

PEOLG Forest Resources 1.1a) 1.1.b) 1.1.c) 1.1 d) 1.2 a) 1.2 b) 1.2 c) Forest Health 2.1 a) 2.1 b) 2.1 c) 2.2 a) 2.2 b) 2.2 c) 2.2 d) Productive Functions 3.1 a) 3.1 b) 3.1 c) 3.2 a) 3.2 b) 3.2 c) 3.2 d) Biological Diversity 4.1 a) 4.1 b) 4.2 a) 4.2 b) 4.2 c) 4.2 d) 4.2 e) 4.2 f) 4.2 g) 4.2 h) 4.2 i) Soil and Water Protection 5.1 a) 5.1 b) 5.2 a) 5.2 b) 5.2 c) Socio-economic Functions 6.1 a) 6.1 b) 6.1 c) 6.1 d) 6.1 e) 6.2 a) 6.2 b) 6.2 c)

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The UK Assurance Standard for SFM is in compliance with the PEOLG. The conversion of agricultural land is not explicitly addresses in the UKWAS. The standard states, “New woodland shall be located and designed in ways that will maintain or enhance the visual, cultural and ecological value and character of the wider landscape”. The national policy stated in UK Forestry Standard rejects the principle of afforestation of all agricultural land, due to different value of agricultural land in different parts of the UK (UK Forestry Standard p. 20). According to UK Forestry Standard the afforestation of agricultural land is possible, but requires consultation with the local stakeholders (UK Forestry Standard p. 20). The UKWAS requirement reflects the national policy on afforestation and is in line with the respective PEOLG. • Conclusion 37 Documentation The criteria and indicators for group/individual certification conform to the PEOLG

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8.

REQUIREMENTS FOR CERTIFICATION BODIES AND PROCEDURES 8.1 Certification Bodies (1) Does the scheme documentation require that certification shall be carried out by impartial, independent third parties that cannot be involved in the standard setting process as governing or decision making body, or in the forest management and are independent of the certified entity? Annex 6, 3.1 • Conclusion 38 Documentation Conforms to the PEFC requirement According to the Scheme the forest and CoC certification audits shall be carried out by independent third parties, accredited certification bodies (Scheme Sections 6.11 and 7.1). The UKWAS Company’s Memorandum and Articles of Association do not let certification bodies influence the standard setting procedure (Scheme 6.3). (2) Does the scheme documentation require that certification body for forest management certification or CoC certification against a scheme specific CoC standard shall fulfil requirements defined in ISO Guide 62, or ISO Guide 66, or ISO Guide 65? Annex 6, 3.1 • Conclusion 39 Documentation Conforms to the PEFC requirement The certification bodies doing forest management certification shall be accredited by ABs operating according to internationally accepted standards (ISO Guides 61, 62 and 65) (Scheme 7.1.1). Note that in CoC certification PEFC accepts only accreditation to ISO Guide 65. (3) Does the scheme documentation require that certification body CoC certification against Annex 4 shall fulfil requirements defined in ISO Guide 65? Annex 6, 3.1 • Conclusion 40 Documentation Conform to the PEFC requirement The Scheme description states that the certification body carrying out CoC certification against Annex 4 (CoC of forest Based products - Requirements) shall fulfil requirements defined in ISO Guide 65 (EN 45011) (Scheme 7.1.1). (4) Does the scheme documentation require that certification bodies carrying out forest certification shall have the technical competence in forest management on its economic, social and environmental impacts, and on the forest certification criteria? Annex 6, 3.1 • Conclusion 41 Documentation Conforms to the PEFC requirement The Scheme sets the requirements for certification bodies to demonstrate the ability to carry out certification audits (Scheme 7.1.1, 7.1.4). Scheme 7.1.2 defines formal criteria of competence for certification bodies. In addition any of the ISO Guides applied in accreditation require adequate competence from certification bodies.

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(5) Does the scheme documentation require that certification bodies carrying out CoC certifications shall have technical competence in forest based products procurement and processing and material flows in different stages of processing and trading? Annex 6, 3.1 • Conclusion 42 Documentation Conforms to the PEFC requirement Scheme 7.1.1, 7.1.4 requires demonstrating competence and thorough understanding of PEFC CoC Standards. In addition any of the ISO Guides applied in accreditation require adequate competence from certification bodies. (6) Does the scheme documentation require that certification bodies shall have a good understanding of the national PEFC system against which they carry out forest management or CoC certifications? Annex 6, 3.2 • Conclusion 43 Documentation Conforms to the PEFC requirement Scheme 7.1.1, 7.1.4 requires demonstrating competence and thorough understanding of UKWAS (7) Does the scheme documentation require that certification bodies have the responsibility to use competent auditors and who have adequate technical know-how on the certification process and issues related to forest management or CoC certification? Annex 6, 3.2 • Conclusion 44 Documentation Conforms the PEFC requirement Scheme 7.1.4 requires that auditors shall meet competence criteria developed by appropriate ABs. The Scheme does not detail the competence requirements. The respective requirement is documented in any of the ISO Guides applied in accreditation and in potential additional specifications issued by ABs. The competence of auditors is a core issue assessed in accreditation process for certifications against UKWAS standard or CoC standard. (8) Does the scheme documentation require that the auditors must fulfill the general criteria of ISO 19011 for Quality Management System (QMS) auditors or for Environmental Management System (EMS) auditors? Annex 6, 3.2 • Conclusion 45 Documentation Does not conform the PEFC requirement The Scheme documentation does not explicitly refer to the ISO 19011:2002 (Guidelines for quality and/or EMS auditing), although the Scheme indicated that certification procedures of the certification bodies must comply with the PEFC TD Annex 6 Ch. 4 (Scheme 7.1.1). Schemes 7.1.1 and 7.1.4 state in general that auditors shall meet competence criteria developed by appropriate ABs. ABs base their requirements on appropriate ISO standards; e.g. ISO 19011.

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8.2

Certification Procedures (11) Does the scheme documentation require that applied certification procedures for forest management certification or CoC certification against a scheme specific CoC standard shall fulfil or be compatible with the requirements defined in ISO Guide 62, or ISO Guide 66, or ISO Guide 65? Annex 6, 4 • Conclusion 46 Documentation Conforms the PEFC requirement The certification bodies doing forest management certification shall be accredited by ABs operating according to internationally accepted standards (ISO Guides 61, 62 and 65) (Scheme 7.1.1). Thus they shall also follow the certification procedures presented in the respective standards. Note that in CoC certification PEFC accepts only accreditation to ISO Guide 65. (12) Does the scheme documentation require that applied certification procedures for CoC certification against Annex 4 shall fulfil or be compatible with the requirements defined in ISO Guide 65? Annex 6, 4 • Conclusion 47 Documentation Conforms the PEFC requirement The Scheme documentation requires that the certification body carrying out CoC certification against Annex 4 (CoC of Forest Based Products - Requirements) shall fulfil requirements defined in ISO 65 (Scheme 7.1.1). (13) Does the scheme documentation require that applied auditing procedures shall fulfil or be compatible with the requirements of ISO 19011? Annex 6, 4 • Conclusion 48 Documentation Does not conform the PEFC requirement Scheme 7.1.6 states in general that auditors shall meet competence criteria developed by appropriate ABs. ABs base their requirements on appropriate ISO standards; e.g. ISO 19011. UKAS is signatory to the multilateral agreements of European Co-operation for Accreditation (EA)/International Accreditation Forum (IAF) and subject to the peer review of other ABs. The certification process and the competence of auditors are among the core accreditation requirements. This PEFCC requirement is respected in practice, although it is not explicitly required by the Scheme. (14) Does the scheme documentation require that certification body shall inform the relevant PEFC National Governing Body about all issued forest management and CoC certificates and changes concerning the validity and scope of these certificates? Annex 6, 4 • Conclusion 49 Documentation Conforms the PEFC requirement Scheme 7.1.5, 7.2.14 requires that certification bodies provide information on certificates issued to the National Governing Body. (15) Does the scheme documentation require that certification body shall carry out controls of PEFC logo usage if the certified entity is a PEFC logo user? Annex 6, 4

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• Conclusion 50 Documentation Conforms the PEFC requirement The Certification body shall monitor the use of the PEFC logo license use by their clients as set out by PEFC UK (Scheme 7.1.3). The Scheme requires that the rules and guidance set out in PEFC TD Annex 5: PEFC Logo Use Rules, will be followed by all certificate holders (Scheme 7.6.3). (16) Does a maximum period for surveillance audits defined by the scheme documentation not exceed more than one year? Annex 6 • Conclusion 51 Documentation Conforms the PEFC requirement The Scheme documentation requires that surveillance audits in certification are carried out at least annually. The Certification Body will identify any non-compliances and check that appropriate corrective actions are implemented (Scheme 7.2.11). (17) Does a maximum period for assessment audit not exceed five years for both forest management and CoC certifications? Annex 6, 4 • Conclusion 52 Documentation Conforms the PEFC requirement The Scheme requires that certificates can be valid for maximum period of five years from the date of issuance (Scheme 7.2.10). (18) Does the scheme documentation include requirements for public availability of certification report summaries? Annex 6, 4 • Conclusion 53 Documentation Conforms the PEFC requirement The Scheme requires that the Scheme Governing Body and the Certification Body conducting the audit shall make the Public Summary Report on the certification decision public (Scheme 7.2.13). Applicant must give his explicit written consent to publication of the public summary report (Scheme 7.2.13). (19) Does the scheme documentation include requirements for usage of information from external parties as the audit evidence? Annex 6, 4 • Conclusion 54 Documentation Conforms the PEFC requirement The information from external parties shall be used in audit as a part of Stakeholder Consultation. The Scheme states that it is a responsibility of the Certification Body to verify that an appropriate level of stakeholder consultations had been carried out by the auditee in accordance with the certification standard (Scheme 7.2.11). The Certification Body might initiate and take into account additional input from stakeholders during the course of the assessment, where it deems such actions is appropriate (Scheme 7.2.12).

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8.3

Accreditation Procedures (21) Does the scheme documentation require that certification bodies carrying out forest management and/or CoC certification shall be accredited by a national AB? Annex 6, 5 • Conclusion 55 Documentation Conforms the PEFC requirement The Scheme accepts the accreditation issued by an AB being a member of IAF and EA. In UK the UKAS is the national AB (Scheme 7.1.3, 7.1.4; 7.1.5). Accreditation specifically to certification against UKWAS standard or PEFC CoC standard is required. (22) Does the scheme documentation require that an accredited certificate shall bear an accreditation symbol of the relevant AB? Annex 6, 5 • Conclusion 56 Documentation Conforms the PEFC requirement Scheme documentation requires that the accreditation symbol is presented in all issued certificates (Scheme 7.1.5). (23) Does the scheme documentation require that the accreditation shall be issued by an AB which is a part of the IAF umbrella and which implement procedures described in ISO 17011 and other documents recognized by the above-mentioned organizations? Annex 6, 5 • Conclusion 57 Documentation Conforms the PEFC requirement The Scheme accepts the accreditation issued by an AB being a member of IAF and EA (Scheme 7.1.3; 7.1.4). The Scheme does not set additional requirements to the procedures implemented by national ABs. Standard ISO 17011 and other documents recognized by the above-mentioned organizations are not specifically referred to in the Scheme. Note: ABs being members of EA and IAF and signatory to the multilateral agreements are obliged to operate according to the ISO 17011 and other commonly agreed accreditation rules. (24) Does the scheme documentation require that certification body undertake forest management or/and CoC certification against a scheme specific CoC standard as “accredited certification” using one of two options recognised by the PEFCC? Annex 6, 5 • Conclusion 58 Documentation Conforms the PEFC requirement Certification bodies shall be accredited by IAF member AB specifically to the UKWAS Scheme or respective CoC system. (25) Does the scheme documentation require that certification body undertake CoC certification against Annex 4 as “accredited certification” based on ISO Guide 65? Annex 6, 5 • Conclusion 59 Documentation Conforms the PEFC requirement The Scheme requires the certification body carrying out CoC certification against Annex 4 to fulfill requirements defined in ISO Guide 65 (EN 45011).

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(26) Does the scheme documentation include a mechanism for PEFC notification of certification bodies? • Conclusion 60 Documentation Conforms the PEFC requirement The Scheme requires, that the certification bodies shall by notified by the PEFC National Governing Bodies of the relevant country (Scheme 7.1.8). (27) Are the procedures for PEFC notification of certification bodies nondiscriminatory? • Conclusion 61 Documentation Conforms the PEFC requirement The Scheme requires that, the PEFC notification conditions shall not discriminated against certification bodies or create trade obstacles (Scheme 7.1.8). The Scheme describes the minimum notification conditions, which the National Governing Body should meet.

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9.

COMMENTS RECEIVED Valuable comments from Australian Forestry Standard Limited were received during the assessment period. Most comments focused on PEFC UK Certification Scheme document and UKWAS specifically references (to the Scheme and other sources), terminology and consistency in description of the Scheme. Comments related to the content of the Scheme document focused on the following issues: • • • • • • • • • • • • Correct references to Annexes of the Scheme documentation The mechanism of Interpretation Panel, as it is described in Chapter 6.2 of the Scheme Credibility of the Steering Group meetings based on the number of participants (Scheme 6.5) Use of terminology in description of normative requirements of the standard (Scheme 6.10) Reference to ISEAL in dispute resolution procedures (Scheme 6.12) Reference to ISO Guide 65 for the Forest Management Standard and recommendation for reference to ISO Guides 62 and 66 (or replacement ISO 17021) (Scheme 6.14) Role of certification bodies in Peer review (Scheme 6.16) Flexibility in meeting requirements of the Standard as a disputable nonconformity and the role of certification body dealing with these nonconformities (Scheme 6.18) Decision procedures of the Certification Body unnecessary due to accreditation (Scheme7.2.8) Confusion in introduction of the new term “the label licensing body” (Scheme 7.5.1) Confusion in introduction of the new term “third party licensing body”(Scheme 7.6.2) Consistency in using terminology -“independent review group”/”independent review panel” (Scheme 7.7.2)

Comments related to the content of the UKWAS Standard document focused on the following issues: • • • • • • • • • • • The normative role of the Guidance notes and the Certification body’s assessment requirement (UKWAS p. 6) The Peer Review as a part of Certification body’s assessment (UKWAS p.7). Transparency in addressing non-conformities in certification process (UKWAS p.7). Confusion wording and definitions in “Application to different sizes of woodland” (UKWAS p. 8) Definition of the Interpretation Panel (UKWAS p.9). Legal requirement as basis for certification (UKWAS 1.1.1; 1.1.2; 1.1.3) Environmental assessment (UKWAS 3.1.3) Normative language in UKWAS 3.3.1 Reference to Forest Stewardship Council (FSC) requirements under the UKWAS 5.2.4 Genetically modified organism (GMO) requirement in UKWAS 5.3.1 FSC bias in the Internet sources (UKWAS p. 56)

The substantial comments were duly taken into consideration in the assessment and the editorial comments were informed to the PEFC UK to be considered in the improvement of the Scheme documentation.

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ANNEXES

ANNEX 1
Minimum Requirements Checklist for Standard Setting Process

Annex 1 Guidelines PEFC Council Minimum Requirements Checklist

Revised on 26 January 2006

GL 2/2006

MINIMUM REQUIREMENTS CHECKLIST FOR STANDARD SETTING PROCESS Ver. 1.1 (March 2007) Part I: Minimum requirements checklist for standard setting process (Annex 2)
No. Reference to Yes/ Reference to application PEFC Council No* documents doc. Standard setting for forest certification Yes Documentation Has the development of the certification - A1 First edition in May 1999. standards been independent from the Revision process in 2006 and certification and accreditation process? [*1] development of the certification standard has been independent. - A1 UKWAS Company’s Memorandum and Articles of Annex 2, 3.2 Association do not provide for the Company to undertake certification or accreditation. Yes Practice - Scheme 6.3 None of the 13 members of the Steering Group have vested interests with certification or accreditation bodies. Has the standard setting process been Yes A2 At national level, carried out at national and/or subStakeholders and Steering national levels? Group members are national Annex 2, 3.3 level organizations and Scheme and standards apply throughout the UK. Yes - The standard has been Has the standard setting process been developed by the Steering co-ordinated by the PEFC National Governing Body? [*1] Group through a formal revision process in which Annex 2, 3.3 PEFC UK has participated. PEFC UK is a member and consultee of the UKWAS Steering Group. - Scheme 6.1 Has the certification standard been Yes Scheme 7.3 UKWAS can be drafted to be applied at individual and/or applied at individual and group group and/or regional level? level. The Scheme permits so Annex 2, 3.3 called Resource Manager Certification where one party manages the forests of several owners. Question

1

2

3.

4.

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Annex 1
No. Question Has the development of certification criteria been initiated by national forest owners’ organisations or national forestry sector organisations having support of the major forest owners’ organisations in that country? [*1] Reference to PEFC Council doc. Yes/ No* Yes Reference to application documents - Scheme 6.1 Development initially facilitated by the UK Forestry Commission. - B2 Developed by the Technical Steering Group, which incorporated interests of the major forest owner’s and national forestry sector organizations. Revision of Standard initiated by Steering Group. Documentation - Scheme 6.3 Interest parties representing key constituencies: economic, social and environmental, including NGOs and ENGOs were invited to participate in the standard setting process. Steering Group represents 13 constituencies. Practice - B 4 Consultations provided the possibilities for all parties to be involved in the standard setting process. Documentation - Scheme 6.3 Structure of the Steering Group provide for balanced representation of interests. Practice - Scheme 6.7 Extensive consultation procedures provide for balanced representation of interests - B4 Decision of the Steering Group made in consensus Documentation - Articles of Association or the Steering Group Rules as standard setting documents do not require transparent documentation Practice - Scheme 6.6 Minutes of all meetings are available at UKWAS. - B 3, Scheme 6.7 Openness and transparency ensured by decision making procedures and publication of documentation in the web (UKWAS web site) and direct notification of stakeholders

5.

Annex 2, 3.4.1

Have all relevant interested parties representing the different aspects of sustainable forest management been invited to participate in the standard setting process and a created Forum? [*1] 6. Annex 2, 3.4.1

Yes

Yes

Do consensus-building procedures of the Forum provide for balanced representation of interest categories? [*2]

Yes

7.

Annex 2, 3.4.1

Yes

Have the views of all relevant interested parties been documented and considered in an open and transparent way? [*3]

No

Yes 8. Annex 2, 3.4.1

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No. Question Has the formal approval of standards been based on evidence of consensus?
[*3]

Reference to PEFC Council doc.

Yes/ No* Yes

Reference to application documents Documentation - The Articles of Association (40.2; 40.3) define the voting procedures and require the unanimous vote of those attending the meeting (C3) Practice - B 2 All decisions made on the basis on consensus. - B5 Voting procedures of the Steering Group ensure consensus Documentation - UKWAS Articles of Association and Steering Group Rules (B 2, Article of Association 40.1) define the roles and responsibilities in standard setting. The Steering Group has its own written procedures, but the procedures do not indicate any of the standard setting procedure requirements Practice - Despite the lack of explicit standard setting rules the procedure was implemented according to the PEFC rules (Standard setting process document

9.

Annex 2, 3.4.1

Yes

Has the Forum defined its own written procedures which have been made available to interest parties upon request? [*2]

No

10.

Annex 2, 3.4.1 Yes

11.

Do the written procedures for standard setting contain an appeal mechanism for impartial handling of any substantive and procedural complaints? [*2]

Yes

Annex2, 3.4.1

Yes

Documentation - Scheme 6.2 Interpretation Panel of the Steering Group as dispute handling body. Practice - Interpretation panel sufficiently independent to provide impartial handling of complaints.

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No. Question Has the start of the standard setting process been communicated to the public? [*3] Reference to PEFC Council doc. Yes/ No* No Reference to application documents Documentation Documentation of the Scheme (Standard setting process document) appropriately requires to communicate the information of the standards setting process to the public (Scheme 6.5, 6.7) (B3), however the Articles of Association or the Steering Group Rules as standard setting documents do not address the issue of communicating the start of the standard setting to the public Practice - Scheme 6.5, 6.7, B 3, B 4 - Communication via e-mail, web page statements and in hard copy. Information on standard setting process available at UKWAS office and UKWAS web page Documentation - No information on the development of the standard shall be withheld unreasonably (B3). Practice - Scheme 6.5, 6.7, B 3, B 4 - Distribution via e-mail, internet and in hard copies. Information on standard development process available at UKWAS office and UKWAS web page Scheme 6.5, 6.7, B 4 Distribution via e-mail, internet and in hard copies. Documentation - Final draft standard shall be submitted to the formal national consultation process (Standard setting process description B 4) Practice - Scheme 6.7, B 4 Formal national consultation took place between June 2003 and January 2006. Documentation - Formal responses to comments received (from the interested parties) shall be available to all interested parties (B3). Practice - B 7 Records of all comments submitted by interest parties are kept by UKWAS

12.

Annex 2, 3.4.2

Yes

Has the information on the development process been distributed and discussed?
[*3]

Yes

13.

Annex 2, 3.4.2

Yes

14.

Has the final draft standard been available to all interested parties, e.g. by posting it on the Internet? [*3] Has the final draft standard been sent out for formal national consultation process? [*3]

Yes Annex 2, 3.4.2 Yes

15.

Annex 2, 3.4.3

Yes

Have views of interested parties been discussed? [*3]

Yes

16.

Annex 2, 3.4.3 Yes

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No. Question Has the Forum given general information on the changes made as a result of a consultation process? [*3] Reference to PEFC Council doc. Yes/ No* Yes Reference to application documents

Documentation - Steering Group shall keep records of each draft as well as consultation drafts (B7). The information on these should be publicly communicated (B7). Annex 2, 3.4.3 17. Yes Practice - B 3 Information on draft standard available at UKWAS web site. Stakeholders notified directly - B 7 Copies of all draft are kept by UKWAS Yes Documentation Had the consultation been at least 60 days? [*3] The minimum requirements for consultation periods should be as follows (B4) Yes Practice - Scheme 6.7 Consultation took place between June 2003 and Annex 2, 3.4.3 18. January 2006, which exceeds 60 days - Initial consultation - JuneSeptember 2003, Second round of consultation April June 2004. Third consultation 16th December 2005 - 16th January 2006 Standards for chain of custody certification (only if the scheme includes a scheme specific CoC standard) Yes The Schemes adopts the PEFC Has the development of certification Council Annex 4: Chain of standards been independent from the Custody of Forest based certification and accreditation process? [*4] Annex 2, 4.1 Products: Requirements on 14th 19. December 2005 and adopts changes of PEFC TD Annex 4 on 5th July 2006 Questions 20-32 not relevant. Has the process of development of PEFC UK adopted Annex 4 in national or sub-national chain of custody 20. Annex 2, 4.2.1 December 2005 requirements been supported by the PEFC National Governing Body? [*4] Have all relevant interested parties representing different aspects of sustainable forest management, wood 21. Annex 2, 4.2.1 procurement, processing and retailing been invited to participate in the standard setting process? [*4] Do consensus-building procedures of the Annex 2, 4.2.1 22. Forum provide for balance representation of interest categories? [*6] Have the views of all relevant interested Annex 2, 4.2.1, parties been documented and 23. 4.2.3 considered in an open and transparent way? [*5] Has the formal approval of standards Annex 2, 4.2.1 24. been based on evidence of consensus?
[*5]

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No. Question Has the Forum defined its own written procedures which have been made available to interest parties upon request? [*6] Do the written procedures for standard setting contain an appeal mechanism for impartial handling of any substantive and procedural complaints? [*6] Has the start of the standard setting process been communicated to the public? [*5] Has the information on the development process been distributed and discussed?
[*5]

Reference to PEFC Council doc. Annex 2, 4.2.1

Yes/ No*

Reference to application documents

25.

26.

Annex2, 4.2.1

27.

Annex 2, 4.2.2

28.

Annex 2, 4.2.2

29.

30.

31. 32.

Has the final draft standard been available to all interested parties, e.g. by posting it on the Internet? [*5] Has the final draft standard been sent out for a formal national consultation process? [*5] Has the Forum given general information on the changes made as a result of a consultation process? [*5] Had the consultation period been at least 60 days long? [*5] Have the first results on the testing of the final drafts for national/sub-national forest certification standards and their implementation arrangements been available prior to submission of the scheme for the PEFC Council endorsement and mutual recognition? [*7]

Annex 2, 4.2.2

Annex 2, 4.2.3

Annex 2, 4.2.3 Annex 2, 4.2.3 Pilot testing Yes Documentation B 8 The drafting of the first edition of the standard was informed by the results of testing the standard in the forest. In Practice Scheme revision experience from the scheme implementation provides adequate testing information. All experiences gained in the Scheme implementation is taken into consideration in the revision.

33.

Annex 2, 5

Yes

34.

Has appropriate action been taken to incorporate improvements and recommendations prior to submission of the scheme for the PEFC Council endorsement and mutual recognition process? [*7]

Yes Annex 2, 5

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No. Reference to PEFC Council doc. Review of standards Have the standards on forest and chain of custody certifications been reviewed at least every 5 years or is it foreseen to review these standards at least every 5 years? Question Yes/ No* Yes Reference to application documents Documentation - The standard is reviewed and revised as necessary on a five-year cycle. The revision of the standard shall include a broad consultation and participation of the stakeholders. The records of all documentation concerning the standard revision process should be available at UKWAS (Description of standard setting process D2; D3). Practice - Scheme 6.1, 6.4, 6.5, 6.7. UKWAS original version launched 1999. UKWAS revision started 2003. Revision lasted two years and the revised Standard was published 1st November 2006. - D 1 Revision of the standards should take place every five years Scheme 6.21 UKWAS members appoint Steering Group to initiate the revision of the standard - Scheme 6.4, 6.5, 6.6, 6.7, 6.21. Procedures have been participatory due to extensive consultations. Procedures were fair and transparent due to balanced representation of the interests in Steering Group and available documentation of the revision process. - Articles of association define the standard setting rules and procedures for participation that comply with PEFC requirements. PEFC UK Board of Directors has adopted on 28th March 2007 all revised (October 27th, 2006) standard setting documentation. Standard setting procedures conform to PEFC requirements PEFC UK Board of Directors has adopted on 28th March 2007 that it will adopt all PEFCC documentation and updates.

35.

Annex 2, 6.1 Yes

36.

Does the scheme documentation indicate which organisation is responsible to initiate the revision work? Has the revision procedures been participatory, fair and transparent? [*8]

Yes Annex 2, 6.1 Yes

37.

Annex 2, 6.1

38.

Has the PEFC National Governing Body appropriately considered the revisions of the general PEFC requirements for standard setting and implementation in the national standards? [*8]

Yes

Annex 2, 6.2

39.

Has the PEFC National Governing Body indicated to the PEFC Council the appropriate considerations of the revisions induced by the PEFC Council in national standards? [*8]

Yes Annex 2, 6.2

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ANNEX 2
Minimum Requirements Checklist for Scheme Compliance with the PEOLG

Annex 2 MINIMUM REQUIREMENTS CHECKLIST FOR SCHEME COMPLIANCE WITH THE PEOLG (Ver.1.1 March 2007) The UK Woodland Assurance Standard (Annex 2), revised in November 2006 sets the minimum requirements for forest management.
Reference to Yes / Reference to scheme PEFC Council No* documentation doc. Basis for criteria development (only for schemes based on MCPFE) Scheme 4.3, 4.4, 4.7, 4.8 Criteria used in the Scheme are Are certification criteria used in the national based on PEC & I for SFM as a or sub-national scheme based on Pan common framework. PEC & I Annex 3, 3.1.1 Yes European Criteria and Indicators for SFM incorporated in UK Forestry as a common framework? Standard and developed UK indicators of Sustainable Forestry. Scheme 4.3, 4.4, 4.7, 4.8 Criteria used in the Scheme are based on PEC & I for SFM as a Have the PEOLG formed the reference common framework. PEC & I base when the national and regional criteria Annex 3, 3.1.2 Yes incorporated in UK Forestry were elaborated, amended or revised? Standard and developed UK indicators of Sustainable Forestry. Question

No.

1

2

1.

MAINTENANCE AND APPROPRIATE ENHANCEMENT OF FOREST RESOURCES AND THEIR CONTRIBUTION TO GLOBAL CARBON CYCLES
Conformity - UKWAS 2.1 Maintenance or increase of woodland is done through woodland management planning. Appropriate planning documentation including maps and records. - UKWAS 1.1.1 Specifically requires compliance with the law. - Conforms to PEOLG - UKWAS 2.1.1 All woodlands shall be covered by management planning documentation, which shall incorporate, appropriate maps. - UKWAS 2.3.2 Inventory of woodlands ensured through periodic monitoring forest resources including economic, environmental and social aspects e.g. harvest yield, flora and fauna. - Conforms to PEOLG - UKWAS 2.1.1; 2.1.3 Woodland management planning requirement as well as requirement for periodic revision of planning documentation - UKWAS 1.1.1 Specifically requires compliance with the law. - Conforms to PEOLG

1.1 Guidelines for Forest management planning 1.1 a) Forest management planning should aim to maintain or increase forest and other wooded area, and enhance the quality of the economic, ecological, cultural and social values of forest resources, including soil and water. This should be done by making full use of related services such as land-use planning and nature conservation. 1.1 b) Inventory and mapping of forest resources should be established and maintained, adequate to the local and national conditions, and in correspondence with the topics described in these Guidelines.

1.1 c) Management plans or their equivalents, appropriate to the size and use of the forest area, should be elaborated and periodically updated. They should be based on legislation as well as existing land use plans, and adequately cover the forest resources.

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1.1 Guidelines for Forest management planning 1.1 d) Monitoring of the forest resources and evaluation of their management should be periodically performed, and their results should be fed back into the planning process. Conformity - UKWAS 2.1.1; 2.1.3 Woodland management planning requirement as well as requirement for periodic revision of planning documentation - UKWAS 2.3.4 Monitoring data shall be analyzed and the findings taken into account by management during revision of the management planning documentation - Conforms to PEOLG - UKWAS 2.1.1. Requirement for management planning, which should incorporate a longterm policy for the woodland. - UKWAS 2.2.2 Requirement for harvesting and restocking not to jeopardize the long term productive potential - UKWAS 3.1.1. Environmental impacts of the management planning of the woodland shall be assessed - UKWAS 3.4.2 Felling and restocking shall be in accordance with the principles and guidance set out in the UK Forestry Standard and supporting guideline publications, including whose on soil and conservation and water. - Confirms to PEOLG - UKWAS 3.4.1 An appropriate silvicultural system shall be adopted which is designed to meet management objectives and which stipulates soundly based planting, establishment, thinning, felling and regenerations plans. - UKWAS 2.2.1 Planning of woodland management operations shall take fully into account the environmental, social and economic impacts of the proposed operations - UKWAS 2.2.2 Requirement for harvesting and restocking not to jeopardize the long term productive potential - Conforms to PEOLG - UKWAS 3.2.1 New woodland shall be located and designed in ways that will maintain or enhance the visual, cultural and ecological value and character of the wider landscape. - Conversion of agricultural land not explicitly addressed, but the aim of the planting and afforestation guidelines of the standard is to create balanced and diverse woodland. - Conforms to PEOLG

1.2. a) Forest management practices should safeguard the quantity and quality of the forest resources in the medium and long term by balancing harvesting and growth rates, and by preferring techniques that minimize direct or indirect damage to forest, soil or water resources.

1.2 b) Appropriate silvicultural measures should be taken to maintain the growing stock of resources at - or bring to - a level that is economically, ecologically and socially desirable.

1.2 c) Conversion of abandoned agricultural and treeless land into forest land should be taken into consideration, whenever it can add economic, ecological, social and/or cultural value.

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Annex 2 2. MAINTENANCE OF FOREST ECOSYSTEM HEALTH AND VITALITY
Remarks - UKWAS 3.2.2 New planning shall be designed in such a way as to ensure the creation over time of a diverse woodland - UKWAS 3.2.1 Woodlands shall be located and designed in ways that will maintain or enhance the visual, cultural and ecological value and character of the wider landscape - UKWAS 6.1.1 The areas and features of particular significance for biodiversity shall be identified. Identified special areas, species and features shall be maintained and, where possible, enhanced. - Conforms to PEOLG - UKWAS 5.1.1 Planning and restructuring plans shall be designed to minimize the risk of damage from wind, pests and diseases - UKWAS 5.1.2 Tree health and grazing impacts shall be monitored and results shall be incorporated into management planning. - UKWAS 6.1.1 The areas and features of particular significance for biodiversity shall be identified. Identified special areas, species and features shall be maintained and, where possible, enhanced. - Conforms to PEOLG - UKWAS 5.1.1 Planning and restructuring plans shall be designed to minimize the risk of damage from wind, pests and diseases - UKWAS 5.1.2 Tree health and grazing impacts shall be monitored and results shall be incorporated into management planning together with guidance arising from national monitoring on plant health. - Conforms to PEOLG - UKWAS 3.2.2 New planning shall be designed in such a way as to ensure the creation over time of a diverse woodland - UKWAS 3.2.3 Even-aged woodland shall be gradually restructured to diversify ages and habitats - UKWAS 5.2.1 The owner/manger shall prepare and implement an effective strategy for minimizing the use of pesticides and biological control agents. - UKWAS 5.3.1 Genetically modified organisms shall not be used - Conforms to PEOLG - UKWAS 3.3.1 Species selected for new woodlands, natural regeneration and restocking shall be suited to the site and matched to the objectives. For new woodlands, native species shall be preferred to non-native. - UKWAS 4.2.2 Timber shall be harvested efficiently and with minimum loss or damage. - UKWAS 4.3.2 Roads and timber extraction tracks and associated drainage shall be designed, created and used and maintained in a manner that minimizes their environmental impact. - UKWAS 5.5.1, 5.5.3 Waste disposal shall be in accordance with current waste management legislation and regulations. Plans end equipment shall be in place to deal with accidental spillage - Conforms to PEOLG

2.1 Guidelines for Forest management planning 2.1 a). Forest management planning should aim to maintain and increase the health and vitality of forest ecosystems and to rehabilitate degraded forest ecosystems, whenever this is possible by silvicultural means.

2.1 b) Health and vitality of forests should be periodically monitored, especially key biotic and abiotic factors that potentially affect health and vitality of forest ecosystems, such as pests, diseases, overgrazing and overstocking, fire, and damage caused by climatic factors, air pollutants or by forest management operations.

2.1 c) Forest management plans or their equivalents should specify ways and means to minimise the risk of degradation of and damages to forest ecosystems. Forest management planning should make use of those policy instruments set up to support these activities.

2.2

Guidelines for Forest Management Practices 2.2 a) Forest management practices should make best use of natural structures and processes and use preventive biological measures wherever and as far as economically feasible to maintain and enhance the health and vitality of forests. Adequate genetic, species and structural diversity should be encouraged and/or maintained to enhance stability, vitality and resistance capacity of the forests to adverse environmental factors and strengthen natural regulation mechanisms. 2.2 b) Appropriate forest management practices such as reforestation and afforestation with tree species and provenances that are suited to the site conditions or the use of tending, harvesting and transport techniques that minimize tree and/or soil damages should be applied. The spillage of oil through forest management operations or the indiscriminate disposal of waste on forestland should be strictly avoided.

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2.2 Guidelines for Forest Management Practices 2.2 c) The use of pesticides and herbicides should be minimized, taking into account appropriate silvicultural alternatives and other biological measures.

2.2 d) In case fertilizers are used they should be applied in a controlled manner and with due consideration to the environment.

- UKWAS 5.2.1 The owner/manger shall prepare and implement an effective strategy for minimizing the use of pesticides and biological control agents. - UKWAS 5.2.2 Where pesticides and biological control agents are to be used: the owner/manager shall justified the usage; shall be aware of and implement legal requirements and non-legislative guidance; shall keep records of usage as required by legislation - Conforms to PEOLG - UKWAS 5.2.5 Fertilizers (inorganic & organic) shall only be used where they are necessary. Where fertilizers are to be used the owner/manager, staff and contractors shall be aware of and shall be implementing legal requirements and best practice guidance for their use in forestry. - Conforms to PEOLG

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Annex 2 3. MAINTENANCE AND ENCOURAGEMENT OF PRODUCTIVE FUNCTIONS OF FORESTS (WOOD AND NON-WOOD)

3.1

Guidelines for Forest Management Planning 3.1 a) Forest management planning should aim to maintain the capability of forests to produce a range of wood and non-wood forest products and services on a sustainable basis.

3.1 b) Forest management planning should aim to achieve sound economic performance taking into account possibilities for new markets and economic activities in connection with all relevant goods and services of forests.

3.1 c) Forest management plans or their equivalents should take into account the different uses or functions of the managed forest area. Forest management planning should make use of those policy instruments set up to support the production of merchantable and non-merchantable forest goods and services. 3.2 Guidelines for Forest Management Practices 3.2 a) Forest management practices should be ensured in quality with a view to maintain and improve the forest resources and to encourage a diversified output of goods and services over the long term.

- UKWAS 2.1.1. Requirement for management planning, which should incorporate a long-term policy for the woodland. - UKWAS 2.2.2 Requirement for harvesting and restocking not to jeopardize the long term productive potential - UKWAS 2.2.3 Authorized harvesting of non-timber woodland products shall not permanently exceed, or diminish, the long-term productive potential of the woodland - UKWAS 3.2.2 New planning shall be designed in such a was as to ensure the creation over time of a diverse woodland - UKWAS 3.2.1 Woodlands shall be located and designed in ways that will maintain or enhance the visual, cultural and ecological value and character of the wider landscape - Conforms to PEOLG - UKWAS 2.2.1 The planning of woodland management operations shall take fully into account the environmental, social and economic impacts of proposed operations. - UKWAS 2.2.2 Requirement for harvesting and restocking not to jeopardize the long term productive potential - UKWAS 3.2.1 Woodlands shall be located and designed in ways that will maintain or enhance the visual, cultural and ecological value and character - of the wider landscape - UKWAS 7.3.1 Management and marketing operations shall encourage making the best use of the woodland’s potential products consistent with other objectives - Conforms to PEOLG - UKWAS 2.2.1 The planning of woodland management operations shall take fully into account the environmental, social and economic impacts of proposed operations. - UKWAS 6.4 Game management requirements aimed at balanced used of forest resources for hunting, game rearing and fishing. - Conforms to PEOLG

3.2 b) Regeneration, tending and harvesting operations should be carried out in time, and in a way that do not reduce the productive capacity of the site, for example by avoiding damage to retained stands and trees as well as to the forest soil, and by using appropriate systems.

- UKWAS 2.2.2 Requirement for harvesting and restocking not to jeopardize the long term productive potential. - The owner/manager should have production records or appropriate standing sale volume assessments and reconciliation with estimates; demonstrated control of thinning intensity. - UKWAS 2.2.3 Authorized harvesting of non-timber woodland products shall not permanently exceed, or diminish, the long-term productive potential of the woodland - Evidence of that harvested quantities are in line with sustainable growth rate. - Conforms to PEOLG - UKWAS 4.2.2 Timber shall be harvested efficiently and with minimum loss or damage. - Guidance: Harvesting should particularly seek to avoid: damage to soil and water resources during felling, extractions and burning; damage to standing trees during felling extraction and burning - Conforms to PEOLG

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3.2 Guidelines for Forest Management Practices 3.2 c) Harvesting levels of both wood and non-wood forest products should not exceed a rate that can be sustained in the long term, and optimum use should be made of the harvested forest products, with due regard to nutrient off take. 3.2 d) Adequate infrastructure, such as roads, skid tracks or bridges should be planned, established and maintained to ensure efficient delivery of goods and services while at the same time minimising negative impacts on the environment.

- UKWAS 4.2.4 Whole tree harvesting shall not be practiced where it is likely to have significant negative effects. - Significant negative impacts to consider include nutrient loss. - Conforms to PEOLG - UKWAS 4.3.1 For new roads, all necessary consents shall be obtained. - UKWAS 4.3.2 Roads and timber extraction tracks and associated drainage shall be designed, created, used and maintained in a manner that minimizes their environmental impact. - Conforms to PEOLG

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Annex 2 4.
4.1

MAINTENANCE, CONSERVATION AND APPROPRIATE ENHANCEMENT OF BIOLOGICAL DIVERSITY IN FOREST ECOSYSTEMS

Guidelines for Forest Management Planning 4.1a) Forest management planning should aim to maintain, conserve and enhance biodiversity on ecosystem, species and genetic level and, where appropriate, diversity at landscape level.

4.1 b) Forest management planning and terrestrial inventory and mapping of forest resources should include ecologically important forest biotopes, taking into account protected, rare, sensitive or representative forest ecosystems such as riparian areas and wetland biotopes, areas containing endemic species and habitats of threatened species, as defined in recognised reference lists, as well as endangered or protected genetic in site resources. 4.2 Guidelines for Forest Management Practices 4.2 a) Natural regeneration should be preferred, provided that the conditions are adequate to ensure the quantity and quality of the forests resources and that the existing provenance is of sufficient quality for the site.

- UKWAS 3.1.2 The impacts of woodland plans shall be considered at a landscape level, taking due account of the interaction with adjoining land and other nearby habitats - UKWAS 6.1.1 The areas and features of particular significance for biodiversity shall be identified. The identified special areas, species and features shall be maintained and, where possible, enhanced. - Conforms to PEOLG - UKWAS 6.1.1 The areas and features of particular significance for biodiversity shall be identified. The identified special areas, species and features shall be maintained and, where possible, enhanced. - UKWAS 6.1.2 Areas designated as protection or conservation areas should be manages in accordance with plans agreed with nature conservation agencies, and shall be marked on the maps - UKWAS 6.1.3 Valuable woodland and other semi-natural habitats shall be identified and restored or treated in a manner that does not lead to further loss of biodiversity. - Confirms to PEOLG - UKWAS 6.3.3 Where appropriate and possible, owners/managers shall use natural regeneration or planting stock from parental material growing in the local native seed zone. - In ancient and other semi-natural woodland, where natural regeneration is insufficient, planning stock from “ source-identified” stands in the local seed zone shall be used wherever it is available - Conforms to PEOLG - UKWAS 3.3.1 Species selected for new woodland, natural regeneration and restocking shall be suited to the site and matched to the objectives. For new woodlands, native species shall be preferred to non- native. - UKWAS 3.3.2 Requirements on proportions of different species in new planting, or planned for the next rotation of an exiting plantation shall be followed - Conforms to PEOLG - UKWAS 3.2.2 New planting shall be designed in such a was as to ensure the creation over time of diverse woodland - UKWAS 3.2.3 Even-aged woodlands shall be gradually restructured to diversify ages and habitats - UKWAS 3.1.2 The impacts of woodland plans shall be considered at a landscape level, taking due account of the interaction with adjoining land and other nearby habitats - Conforms to PEOLG - UKWAS 6.1.3 Valuable woodland and other semi-natural habitats (e.g. moorland, heathland, wood pasture and grassland) which have been colonized, planted, or incorporated into plantations, but which have retained their ecological characteristics (or have high potential to be restored)m shall be identified and restored or treated in a manner that does not lead to further loss of biodiversity or cultural value. - Conforms to PEOLG

4.2 b) For reforestation and afforestation, origins of native species and local provenances that are well adapted to site conditions should be preferred, where appropriate. Only those introduced species, provenances or varieties should be used whose impacts on the ecosystem and on the genetic integrity of native species and local provenances have been evaluated, and if negative impacts can be avoided or minimised. 4.2 c) Forest management practices should, where appropriate, promote a diversity of both horizontal and vertical structures such as uneven-aged stands and the diversity of species such as mixed stands. Where appropriate, the practices should also aim to maintain and restore landscape diversity. 4.2 d) Traditional management systems that have created valuable ecosystems, such as coppice, on appropriate sites should be supported, when economically feasible.

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4.2 Guidelines for Forest Management Practices 4.2 e) Tending and harvesting operations should be conducted in a way that does not cause lasting damage to ecosystems. Wherever possible, practical measures should be taken to improve or maintain biological diversity.

4.2 f) Infrastructure should be planned and constructed in a way that minimises damage to ecosystems, especially to rare, sensitive or representative ecosystems and genetic reserves, and that takes threatened or other key species - in particular their migration patterns - into consideration. 4.2 g) With due regard to management objectives, measures should be taken to balance the pressure of animal populations and grazing on forest regeneration and growth as well as on biodiversity. 4.2 h) Standing and fallen dead wood, hollow trees, old groves and special rare tree species should be left in quantities and distribution necessary to safeguard biological diversity, taking into account the potential effect on health and stability of forests and on surrounding ecosystems. 4.2 i) Special key biotopes in the forest such as water sources, wetlands, rocky outcrops and ravines should be protected or, where appropriate, restored when damaged by forest practices.

- UKWAS 4.2.2 Timber shall be harvested efficiently and with minimum loss or damage. Guidance: Harvesting should particularly seek to avoid: damage to soil and water resources during felling, extractions and burning; damage to standing trees during felling extraction and burning - UKWAS 6.2.2 Owner/managers shall take action to provide both standing and fallen deadwood habitats throughout the woodland. - Conforms to PEOLG - UKWAS 4.3.2 Roads and timber extraction tracks and associated drainage shall be designed, created, used and maintained in a manner that minimizes their environmental impact. - UKWAS 5.4.2 Where fences are used, alignment shall be designed to minimize impacts on access, landscape, wildlife and archaeological sites. - Conforms to PEOLG - UKWAS 6.4.3 Game management shall not be sufficiently intense to cause long-term or widespread negative impacts on the woodland ecosystem. - Guidance: Feeding and rearing areas should be located in areas where there will be low impact on ground flora. - Conforms to PEOLG - UKWAS 6.2.2 Owner/managers shall take action to provide both standing and fallen deadwood habitats throughout the woodland. - Actions to provide deadwood habitats shall include e.g.: keeping all standing dead trees, snags and veteran trees; keeping naturally fallen trees or major branches - Conforms to PEOLG - UKWAS 6.1.1 The areas and features of particular significance for biodiversity and natural processes in critical situations shall be identified. The identified special areas, species and features shall be maintained and, where possible, enhanced. - Guidance: Identification and mapping of these features any be carried out on an ongoing basis, provided that is has been completed for area prior significant woodland management operations taking place. - UKWAS 4.2.1 Harvesting operations shall conform to all relevant guidelines - Comply to PEOLG through legislation

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Annex 2 5.
5.1

MAINTENANCE AND APPROPRIATE ENHANCEMENT OF PROTECTIVE FUNCTIONS IN FOREST MANAGEMENT (NOTABLY SOIL AND WATER)

Guidelines for Forest Management Planning 5.1 a) Forest management planning should aim to maintain and enhance protective functions of forests for society, such as protection of infrastructure, protection from soil erosion, protection of water resources and from adverse impacts of water such as floods or avalanches.

5.1 b) Areas that fulfill specific and recognized protective functions for society should be registered and mapped, and forest management plans or their equivalents should take full account of these areas.

- UKWAS 6.1.1 The areas and features of particular significance for biodiversity and natural processes in critical situations shall be identified. The identified special areas, species and features shall be maintained and, where possible, enhanced. - Guidance: Examples of where woodland areas affect natural processes include watershed management and erosion control. Guidance on where these may be critical should be sought through reference to Forestry Commission’s Forest and Water Guidelines and environmental protection agencies - Comply to PEOLG though governmental guidelines - UKWAS 6.1.1 The areas and features of particular significance for biodiversity and natural processes in critical situations shall be identified. The identified special areas, species and features shall be maintained and, where possible, enhanced. - Guidance: Identification and mapping of these features any be carried out on an ongoing basis, provided that is has been completed for area prior significant woodland management operations taking place. - All known area and features should be mapped - Conforms to PEOLG - UKWAS 6.1.1 The areas and features of particular significance for biodiversity and natural processes in critical situations shall be identified. The identified special areas, species and features shall be maintained and, where possible, enhanced. - Guidance: Examples of where woodland areas affect natural processes include watershed management and erosion control. Guidance on where these may be critical should be sought through reference to Forestry Commission’s Forest and Water Guidelines and environmental protection agencies - Forestry Commission Forest and water guidelines require to minimize the effects of cultivation and drainage on critical base and peak stream flows - The UK Forestry Standard requires to plan carry out antierosion precautions in vulnerable situations - Comply to PEOLG through UK Forestry Standard and Forestry Commission Forest and water guidelines - UKWAS 6.1.1 The areas and features of particular significance for biodiversity and natural processes in critical situations shall be identified. The identified special areas, species and features shall be maintained and, where possible, enhanced. - Guidance: Examples of where woodland areas affect natural processes include watershed management and erosion control. Guidance on where these may be critical should be sought through reference to Forestry Commission’s Forest and Water Guidelines and environmental protection agencies - Forestry Commission Forest and water guidelines require to minimize the effects of cultivation and drainage on critical base and peak stream flows - The UK Forestry Standard requires to plan carry out antierosion precautions in vulnerable situations - Comply to PEOLG through UK Forestry Standard and Forestry Commission Forest and water guidelines

5.2

Guidelines for Forest Management Practices 5.2 a) Special care should be given to silvicultural operations on sensitive soils and erosion-prone areas as well as on areas where operations might lead to excessive erosion of soil into watercourses. Inappropriate techniques such as deep soil tillage and use of unsuitable machinery should be avoided on such areas. Special measures to minimize the pressure of animal population on forests should be taken.

5.2 b) Special care should be given to forest management practices on forest areas with water protection function to avoid adverse effects on the quality and quantity of water resources. Inappropriate use of chemicals or other harmful substances or inappropriate silvicultural practices influencing water quality in a harmful way should be avoided.

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Annex 2
5.2 Guidelines for Forest Management Practices 5.2 c) Construction of roads, bridges and other infrastructure should be carried out in a manner that minimizes bare soil exposure, avoids the introduction of soil into watercourses that preserve the natural level and function of water courses and river beds. Proper road drainage facilities should be installed and maintained.

- UKWAS 4.3.2 Roads and timber extraction tracks and associated drainage shall be designed, created, used and maintained in a manner that minimizes their environmental impact. - Protection of water resources ensured through Forestry Commission’s Forest and water guidelines - Comply to PEOLG thorough compulsory guidelines of Forestry Commission

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Annex 2 6.
6.1

MAINTENANCE OF OTHER SOCIO-ECONOMIC FUNCTIONS AND CONDITIONS

Guidelines for Forest Management Planning 6.1 a) Forest management planning should aim to respect the multiple functions of forests to society, have due regard to the role of forestry in rural development, and especially consider new opportunities for employment in connection with the socioeconomic functions of forests. 6.1 b) Property rights and land tenure arrangements should be clearly defined, documented and established for the relevant forest area. Likewise, legal, customary and traditional rights related to the forestland should be clarified, recognized and respected.

6.1 c) Adequate public access to forests for the purpose of recreation should be provided taking into account the respect for ownership rights and the rights of others, the effects on forest resources and ecosystems, as well as the compatibility with other functions of the forest. 6.1 Guidelines for Forest Management Planning 6.1 d) Sites with recognised specific historical, cultural or spiritual significance should be protected or managed in a way that takes due regard of the significance of the site. 6.1 e) Forest managers, contractors, employees and forest owners should be provided with sufficient information and encouraged to keep up to date through continuous training in relation to sustainable forest management.

- UKWAS 7.3.1 Owners/mangers shall promote the integration of woodlands into the local economy. Management and marketing operations shall encourage making the best use of the woodland’s potential products consistent with other objectives. - Guidance: making reasonable provision for local employment for contractors and suppliers to provide services and supplies. - Conforms to PEOLG - UKWAS 1.1.3 Legal ownership or tenure can be proved. - Guidance: legal ownership may be demonstrated by title deeds or solicitor’s letter or long term unchallenged use. - UKWAS 7.2.1 All existing permissive or traditional uses of the woodland shall be sustained except when such uses can be shown to threaten the integrity of the woodland or the achievement of the objectives of management. - Documentation or maps of all existing permissive and traditional uses of the woodland. - Conforms to PEOLG - UKWAS 7.2.2 There shall be provision for some public access to the woodland subject only to specific exemptions. - UKWAS 7.2.3 Where there is a specific demand for further public access, particularly for the purpose of environmental education, the owner/manager shall make reasonable efforts to try to meet this demand or to help locate an alternative site. - Conforms to PEOLG - UKWAS 7.4.1 sites and features of special cultural significance shall be identified and discussed with interested local people, the relevant authorities and interest groups and measures shall be taken to protect them. - Conforms to PEOLG - UKWAS 8.2.1 Only those with relevant qualifications, training and/or experience shall be engaged to carry out any work unless working under proper supervision if they are currently undergoing training. - UKWAS 8.2.2 The owner/manager of large enterprise shall promote training, and encourage and support new recruits to the industry. - Guidance: promotion of training may be achieved through providing sites for training courses; offering subsidies for training coursed - Restrictions to employ only skilled workforce and providing means for training comply with PEOLG. - UKWAS 7.1.1 The owner/manager shall ensure that there is a full co-operation with FC or DARD consultation process. The owner/manager shall consult adequately with local people and relevant organizations and make a reasonable response to issues raised or requests for ongoing dialogue and engagement. - Cooperation with local communities and NGOs ensures making use of outside knowledge and experience - Conforms to PEOLG

6.2

Guidelines for Forest Management Practices 6.2 a) Forest management practices should make the best use of local forest related experience and knowledge, such as of local communities, forest owners, NGOs and local people.

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Annex 2
6.2 Guidelines for Forest Management Practices 6.2 b) Working conditions should be safe, and guidance and training in safe working practice should be provided.

6.2 c) Forest management operations should take into account all socio-economic functions, especially the recreational function and aesthetic values of forests by maintaining for example varied forest structures, and by encouraging attractive trees, groves and other features such as colours, flowers and fruits. This should be done, however, in a way and to an extent that does not lead to serious negative effects on forest resources, and forestland.

- UKWAS 8.1.1 There shall be compliance with health and safety legislation, conformance with associated codes of practice, contingency plan for any accidents - UKWAS 8.1.2 The owner/manager shall meet all applicable requirements of health and safety legislation, ensuring that all workers have had relevant instructions in safe working practice and first aid procedures - Comply with PEOLG through legislation - UKWAS 3.1.2 The impacts of woodland plans shall be considered at a landscape level, taking due account of the interaction with adjoining land and other nearby habitats - UKWAS 3.2.3 Even-aged woodland shall be gradually restructured to diversify ages and habitats - UKWAS 7.2.1 All existing permissive or traditional uses of the woodland shall be sustained except when such uses can be shown to threaten the integrity of the woodland or the achievement of the objectives of management. - UKWAS 7.3.1 Management and marketing operations shall encourage making the best use of the woodland’s potential products consistent with other objectives - Biodiversity, varied forest structure and recreational activities encouraged on FMU level and taken into account in planning - Conforms to PEOLG

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ANNEX 3
Minimum Requirements Checklist for Certification Schemes and Their Implementation

Annex 3 MINIMUM REQUIREMENTS CHECKLIST FOR CERTIFICATION SCHEMES AND THEIR IMPLEMENTATION
No. Reference to Yes/ Reference to scheme PEFC Council No* documentation doc. General requirements for certification criteria Are the criteria relevant to all types of Annex 3, 3.5 Yes The criteria apply to all forest forests and management systems, types in the country and to all which exist in the nation/region they types of management units have been elaborated for? Do the criteria clearly express the Annex 3, 3.5 Yes Criteria (requirements) state clear objectives for forest management that qualitative objectives, indicators can be unambiguously verified by (means of verification) present different auditors? measures to achieve the objectives. Indicators (means of verification) do not always cover the scope of a criterion (requirement) but guidelines presented in Guidance as well as references to normative plans (legislations) compensate the gaps. Are management and performance Annex 3, 3.5 Yes Performance requirements at requirements applicable at the level of a group/individual level are forest management unit? applicable at FMU level Annex 3, 3.5 Yes - Management requirements are Are management and performance applicable at individual and requirements applicable optionally also at group and regional levels? [*5] group level. - Annex 2 Laws and regulations Are the national certification criteria in Annex 3, 3.2, 3.5 Yes - The C&I at group/individual compliance with national laws level rely on UK Forestry programmes and policies? Standard as well as relevant legislation and compulsory guidance - Scheme 4.3, UKWAS 1.1.1 Are the references to national laws, Annex 3, 3.5 Yes The C&I refer to UK Forestry programs and policies indicated in the Standard and other compulsory scheme documentation when relevant, legislation in order to reach full e.g., if the requirement of the PEOLG is compliance with PEOLG. The not addressed in the certification criteria Scheme requires that participants but is included in normative regulations? follow legislation (UKWAS 1.1.1). Certification body will verify that there no evidence of noncompliance with relevant legal requirements (UKWAS 1.1.1) Does the scheme include the Annex 3, 3.2 Yes - Participant of certification are requirement that any apparent violation required to follow the legislation of the legislation shall be taken into (UKWAS 1.1.1) consideration in internal and external - Certification body will verify that audits? there no evidence of noncompliance with relevant legal requirements (UKWAS 1.1.1) Question

1

2

3

4

5

6

7

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Annex 3
No. Reference to PEFC Council doc. ILO Conventions Are the Core ILO Conventions ratified Annex 3, 3.3 by the country and implemented through the legislative framework? Question Yes/ No* Reference to scheme documentation

8

Yes

9

10

11

Do the national certification criteria Annex 3, 3.5 N/A address the core elements of those Core ILO Conventions, which have been not ratified by the country? Has the ILO Code of Practise on Safety Annex 3, 3.3 Yes and Health in Forestry Work been considered in development of national and regional certification criteria? Other international conventions Are the international conventions Annex 3, 3.4 Yes relevant to forest management and ratified by the country and respected through the legislative framework? Are the requirements agreed upon in Annex 3, 3.4 N/A the conventions, even if they are not ratified by the country, respected in the certification criteria to the degree that they are covered in PEOLG or other reference documents basis approved by the PEFC Council? Level of application – general Are the applicants, the certified areas Annex 3, 4.1 Yes and participating forest owners/managers/others actors clearly identified in the scheme documentation? Does the scheme documentation Annex 3, 4.1 Yes require that all actors involved in or operating on the certified area comply with the certification requirements?

All core ILO conventions ratified by the UK Government. See the respective Table in the Assessment Report Not applicable

ILO Code of Practice on Safety and Health in Forestry Work is in reference base of the UKWAS

12

- CITES 8/2/1976, Convention on Biological Diversity 19/11/2003 - Biosafety Protocol 19/11/2004 are ratified by the UK Not applicable

13

14

15

Does the scheme documentation Annex 3, 4.1 Yes require that all actors individually certified or participating in regional/group certification are responsible for ensuring that contractors’ activities and operations meet the respective forest management criteria? Level of application – regional certification (only for schemes which include regional certification) 16 Does the national definition of regional Annex 3, 4.1, a N/A The Scheme does not include an certification comply with the PEFC option for regional certification. Council definition? Therefore questions 16 to 31 are not applicable

- Applicants are woodland owners or forest enterprises for individual, group or resource manager certification. - Scheme 7.3 - All actors of certification on individual or group level should comply with certification requirements - Scheme 7.3, 7.3.4, 7,3,8 Scheme documentation requires that employees and contractors activities meet the respective forest management criteria (requirements) Scheme 7.3.4, UKWAS 1.1.1, 4.1.1

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Annex 3
No. Reference to Yes/ Reference to scheme PEFC Council No* documentation doc. Level of application – group certification (only for schemes which include group certification) Does the national definition for group Annex 3, 4.1 b Yes - Forest owners must form a certification comply with the PEFC formally identifiable group, Council definition? which can seek a certificate - Scheme 7.3.3 - Group Entity must obtain contractual commitment from each Group member - Scheme 7.3.7 Does the scheme documentation clearly Annex 3, 4.1 b Yes - Group Manager who act on define who the applicant is for group behalf of group members certification? - Scheme 7.3.7 Does the scheme documentation Annex 3, 4.1 b Yes All members of the group must describe the applicant’s responsibility to formally commit to complying assure the compliance of all participants with all requirements of the with the certification requirements? standard in respect of all forests areas included in the scope of the particular group scheme concerned. Scheme 7.3.4 Basis of Group Certification Does the scheme documentation Annex 3, 4.1 b Yes Group Members shall set out describe the applicant’s responsibility to clearly documented criteria for ensure that credible registers are kept eligibility and on-going of participants to certification and membership of the group certified forest area? Scheme 7.3.7 Does the scheme documentation Annex 3, 4.1 b Yes - Applicant must commit to follow describe the applicant’s responsibility to standards and rules implement the rules for group - Scheme 7.3.7 certification? Does the scheme documentation Annex 3, 4.1 b Yes The Scheme requires that all require that total forest area members of the group must participating in group certification is formally commit to complying recorded? with all the requirements of UKWAS in respect to all forests areas included within the scope of the particular group Scheme concerned. The Scheme also requires that Group Entity must accept contractual responsibility to the Certification Body for ensuring that the requirements of UKWAS are implemented by all Group Members for forest areas covered by the certificate. (Scheme 7.3.4,7.3.7) The Scheme also requires the Group Entity to keep records of the group members ( Scheme 7.3.7) Does the scheme documentation Annex 3, 4.1 b Yes - All members must formally describe that forest owners should commit to complying with all submit all the forest area under his the requirements of UKWAS in management in the catchment area for respect of all forest areas the group certification? (not obligatory to included within the scope of the be met but should be aimed at) particular group Scheme concerned. - Scheme 7.3.4 Question

32

33

34

35

36

37

38

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Annex 3
No. Reference to PEFC Council doc. Does the scheme documentation define Annex 3, 4.1 b the responsibilities and authorities of the applicant and participating forest owners/managers for the inclusion of new participants and to inform the certification body thereof? Question Yes/ No* Yes Reference to scheme documentation - The Scheme requires that Group Entity set clearly documented criteria for eligibility and on-going membership of the group. The Scheme does not give guidance on the content of the criteria. - Scheme 7.3.7 - Under group certification body is required to develop assessment procedure to verify membership base. - Administrative and forest management policies that are relevant to the whole group (e.g. monitoring) shall be implemented by the Group Entity or by individual Group Member. - Scheme 7.3.4 The Group certificate and Resource Manager certificate is issued to the applicant as required by the PEFC (Scheme 7.3.9; 7.3.13). Scheme 7.3.9 The group member will receive a Certificate of attestation from the Group manager to affirm the membership of the group

39

40

Does the scheme documentation define Annex 3, 4.1 b the responsibilities and authorities of the applicant and participating forest owners/managers for the internal control of conformity and follow up corrective and/or preventive measures?

Yes

41

Does the scheme documentation describe that the forest management certificate is issued to the applicant (certificate holder)?

Annex 3, 4.1 b

Yes

42

Does the scheme documentation Annex 3, 4.1 b Yes describe that participants in group certification shall receive either a copy of the regional certificate including the appendix (when applicable) listing all participating forest owners or an individual attestation issued by the certification body or the applicant which refers to the main certificate? Level of application – individual certification (only for schemes which include individual certification) 43 Does the scheme documentation Annex 3, 4.1 b Yes - All members must formally describe that forest owner should commit to complying with all submit all the forest area under his the requirements of UKWAS in respect of all forest areas management in the catchment area of the certification scheme in the included within the scope of the certification? (not obligatory to be met particular group Scheme but should be aimed at) concerned. - Scheme 7.3.4 Implementation of changes to the scheme 44 Does the scheme documentation define Annex 3, 5 Yes Scheme 2.7 transition period(s) for implementation PEFC UK adopts policy for of changes to the endorsed scheme in implementation of compliance with chapter 5 of Annex 3. Changes/Revisions induced by (This is not applicable to the initial PEFC Council, which meet endorsement of a scheme) required implementation dates. Changes to the scheme will be implemented similarly.

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Annex 3
No. Reference to Yes/ Reference to scheme PEFC Council No* documentation doc. Appeals, complaints and dispute procedures Has the PEFC National Governing Body Annex 3, 5.1 Yes Queries related to the standard set up or appointed an impartial and interpretation are remitted to the independent dispute settlement body on Interpretation Panel of the a permanent basis or does it have Steering Group. Rules and written procedures for the establishment procedures are publicly available. of a dispute settlement body on an ad hoc basis? Has the PEFC National Governing Body Annex 3, 5.1 Yes Queries related to the standard interpretation are remitted to the established and have documented procedures for an independent dispute Interpretation Panel of the settlement body, either permanent or ad Steering Group. Rules and hoc, that takes care of those complaints procedures are publicly available. arising from forest management or chain of custody scheme implementation that cannot be addressed in the dispute settlement procedures of the relevant certification or accreditation body? Can the dispute settlement body also Annex 3, 5.1 Yes Queries related to the standard resolve possible grievances in chain of interpretation are remitted to the custody certification that do not Interpretation Panel of the exclusively concern an applicant and a Steering Group. Rules and certification body? procedures are publicly available. Does the scheme documentation Annex 3, 5.2 Yes Certification authorities shall require that the accredited certification have a formal dispute body has procedures for dispute management procedure Scheme settlement for all grievances between 6.12 the applicant and the certification body? Does the scheme documentation Annex 3, 5.2 Yes The accreditation authority shall require that the relevant accreditation ensure that the certification body, whose accreditation covers the authority meets all the certification, deals with disputes and requirements of ISO/IEC Guides complaints concerning observance of 62 and 65 as well as all the the accreditation requirements? criteria which are explicitly part of the UK Woodland Assurance Standard. Scheme 6.11 Question

45

46

47

48

49

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ANNEX 4
Minimum Requirements Checklist for Scheme Specific CoC Standards

Annex 4 MINIMUM REQUIREMENTS CHECKLIST FOR SCHEME SPECIFIC CoC STANDARDS NOTE: PEFC UK Ltd. At the Board meeting held on 14 December 2005 adopted the following resolution: The UK Certification Scheme for Sustainable Forest Management adopts the PEFC Council international Chain of Custody Standard (Annex 4 to the PEFC Technical Document) and this is in compliance with PEFC Council requirements (Annex 3, Chapter 4.2). The Board of PEFC UK Ltd adopted at a meeting of the Directors on the 28 March 2007, as part of the PEFC UK Certification Scheme, that it would be referenced by and adopt all required implementation dates of PEFC Council documentation including Technical, Annexes and supporting Appendices and Guidelines, as currently approved and including all updates endorsed by the PEFC General Assembly on the 26 October 2006 (Scheme, Introduction).
No. Reference to Reference to Yes / PEFC application No* Council doc. documents Requirements for chain of custody process – physical separation method Does the national CoC standard require identification Yes Annex 3 and verification of the category of origin for all Annex 4, procured products in compliance with chapter 2.2.1 2.2.1, 2.2.2 and 2.2.2? Does the national CoC standard require separation of Yes Annex 3 the certified raw material in compliance with chapter Annex 4, 2.3 2.3? Does the national CoC standard require information Yes Annex 3 Annex 4, delivered to customer at the point of sale of certified 2.4.1, 2.4.2 products in compliance with chapter 2.4.1 and 2.4.2? Does the national standard require that usage of the Yes Annex 3 logo or label shall be carried out according to the Annex 4, terms and conditions of the logo / label copyright 2.4.3 owner? Requirements for the chain of custody process – percentage based methods Does the national standard require that the Yes Annex 3 requirements for CoC process shall be implemented Annex 4, for the production batch defined in compliance with 3.1.1, 3.1.2 chapters 3.1.2 Does the national CoC standard require identification Yes Annex 3 and verification of the category of origin for all Annex 4, procured products in compliance with chapter 3.2.1 3.2.1, 3.2.2 and 3.2.2? Does the national standard include a calculation Yes Annex 3 formula for the certification percentage, which is Annex 4, 3.3 compatible with the formula of chapter 3.3? Does the national standard include an average Annex 4, Yes Annex 3 percentage method in compliance with chapter 3.4.1? 3.4.1 Does the national standard include a volume credit Annex 4, Yes Annex 3 method in compliance with chapter 3.4.2? 3.4.2 Does the national CoC standard require information Yes Annex 3 Annex 4, delivered to customer at the point of sale of certified 3.5.1, 3.5.2 products in compliance with chapter 3.5.1 and 3.5.2? Does the national standard require that usage of the Yes Annex 3 logo or label shall be carried out according to the Annex 4, terms and conditions of the logo / label copyright 3.5.3 owner? Does the national standard include measures to Yes Annex 3 Annex 4, 3.6; ensure that the certified products do not include raw material from controversial sources in compliance with Appendix 7 chapter 3.6 and Appendix 7 to Annex 4? Question

1.

2.

3.

4.

5.

6.

7. 8. 9. 10.

11.

12.

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Annex 4
Reference to Reference to Yes / PEFC application No* Council doc. documents Minimum management system requirements Does the national standard require management Yes Annex 3 Annex 4, 13. responsibilities for the organisation’s top management 4.2.1 in compliance with chapter 4.2.1? Does the national standard include requirements for Yes Annex 3 Annex 4, 14. responsibilities and authorities for CoC in compliance 4.2.2 with chapter 4.2.2? Does the national standard include requirements for Yes Annex 3 15. documented procedures in compliance with chapter Annex 4, 4.3 4.3? Does the national standard include requirements for Yes Annex 3 16. Annex 4, 4.4 record keeping in compliance with chapter 4.4? Does the national standard include requirements for Yes Annex 3 17. human resources management and technical facilities Annex 4, 4.5 in compliance with chapter 4.5? Does the national standard include requirements for Yes Annex 3 18. Annex 4, 4.6 inspection and control in compliance with chapter 4.6? PEFC specification for the origin for the purposes of PEFC label and declaration Does the national standard include definition of Yes Annex 3 certified raw material, neutral and other raw material Annex 4, 19. (for the purposes of PEFC claims / labelling) in Appendix 1 compliance with Appendix 1? Implementation of chain of custody in multi-site organisation (only for standards which include rules for multi-site or group certification) Does the national standard include requirements for Yes Annex 3 Annex 4, 20. function and responsibilities of the central office in Appendix 4 compliance with Appendix 4? Does the national standard include requirements for Yes Annex 3 Annex 4, 21. function and responsibilities of the central office in Appendix 4 compliance with Appendix 4? PEFC specification of the origin for the purposes of PEFC label and declarations covering recycled raw material (only for standards which allow claims to be made on recycled raw material) Does the national standard include definition of Yes Annex 3 certified raw material, neutral and other raw material Annex 4, 22. for certified and recycled raw material (for the Appendix 6 purposes of PEFC claims / labelling) in compliance with Appendix 6? PEFC specification of the origin for the purposes of PEFC label and declarations on non wood forest products (only for standards which are applicable to non wood forest products) Yes Annex 3 Does the national standard include definition of certified raw material, neutral and other raw material Annex 4, 23. for non wood forest products (for the purposes of Appendix 8 PEFC claims / labelling) in compliance with Appendix 8? No. Question

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ANNEX 5
Minimum Requirements Checklist for Certification and Accreditation Procedures

Annex 5 MINIMUM REQUIREMENTS CHECKLIST FOR CERTIFICATION AND ACCREDITATION PROCEDURES
No. Reference to Yes / PEFC Council No* doc. Certification Bodies Does the scheme documentation require that Yes certification shall be carried out by impartial, independent third parties that cannot be involved in the standard setting process as governing or decision making body, or in the forest management and are independent of the certified entity? Annex 6, 3.1 Question Reference to scheme documentation Certification authorities shall be accredited to undertake independent woodland management certification using the UK Woodland Assurance Standard by a national or international accreditation authority that operates in accordance with ISO/IEC 17011:2004 Scheme Sections 6.11 and 7.1 Scheme 7.1.1 Requirement for certification bodies shall fulfil internationally accepted standards (ISO Guides 61, 62, & 65) Scheme 7.1.1 Certification body carrying out CoC certification against Annex 4 shall fufill requirements defined in ISO 65 Scheme 7.1.2 Defines formal criteria of competence for certification bodies

1.

2.

Does the scheme documentation require that certification body for forest management certification or CoC certification against a scheme specific CoC standard shall fulfil requirements defined in ISO Guide 62, or ISO Guide 66, or ISO Guide 65? Does the scheme documentation require that certification body CoC certification against Annex 4 shall fulfil requirements defined in ISO Guide 65?

Yes

Annex 6, 3.1

Yes

3.

Annex 6, 3.1

4.

5.

6.

7.

Does the scheme documentation require that certification bodies carrying out forest certification shall have the technical competence in forest management on its economic, social and environmental impacts, and on the forest certification criteria? Does the scheme documentation require that certification bodies carrying out CoC certifications shall have technical competence in forest based products procurement and processing and material flows in different stages of processing and trading? Does the scheme documentation require that certification bodies shall have a good understanding of the national PEFC system against which they carry out forest management or CoC certifications? Does the scheme documentation require that certification bodies have the responsibility to use competent auditors and who have adequate technical know-how on the certification process and issues related to forest management or CoC certification?

Yes Annex 6, 3.1

Yes Annex 6, 3.1

Yes Annex 6, 3.2

Yes Annex 6, 3.2

Scheme 7.1.1, 7.1.4 requires demonstrating competence and thorough understanding of PEFC CoC Standards. Scheme 7.1.1, 7.1.4 requires demonstrating competence and thorough understanding of UKWAS Scheme 7.1.4 auditors shall meet competence criteria developed by appropriate Accreditation Bodies (ABs)

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Annex 5
No. Question Does the scheme documentation require that the auditors must fulfil the general criteria of ISO 19011 for QMS auditors or for EMS auditors? 8. Reference to Yes / Reference to scheme PEFC Council No* documentation doc. No Scheme 7.1.1, 7.1.4 states in general that auditors shall meet competence criteria developed by Annex 6, 3.2 appropriate ABs. ABs base their requirements on appropriate ISO standards; e.g. ISO 19011 Yes Scheme 7.1.4 Competence criteria for Annex 6, 3.2 auditors

9.

Does the scheme documentation include additional qualification requirements for auditors carrying out forest management or CoC audits?
[*1]

Certification procedures Yes Does the scheme documentation require that certification bodies shall have established internal procedures for forest management and/or CoC certification? Does the scheme documentation require that applied certification procedures for forest management certification or CoC certification against a scheme specific CoC standard shall fulfil or be compatible with the requirements defined in ISO Guide 62, or ISO Guide 66, or ISO Guide 65? Does the scheme documentation require that applied certification procedures for CoC certification against Annex 4 shall fulfil or be compatible with the requirements defined in ISO Guide 65? Scheme 7.1 requires that certification bodies are required to maintain documented procedures for auditor competence and scheme specific procedures Scheme 7.1.1 Requirement for certification bodies shall fulfil internationally accepted standards (ISO Guides 61, 62 and 65) Scheme 7.1.1 Certification body carrying out CoC certification against Annex 4 shall fufill requirements defined in ISO 65 Scheme 7.1.1, 7.1.4 states in general that auditors shall meet competence criteria developed by appropriate ABs. ABs base their requirements on appropriate ISO standards; e.g. ISO 19011. Scheme 7.1.5, 7.2.14 Certification bodies provide information on certificates issued to the National Governing Body Scheme 7.6.3 followed according to the PEFCC Annex 5: PEFC Logo Use Rules

10.

Annex 6, 4

Yes

11.

Annex 6, 4

Yes

12.

Annex 6, 4

No

13.

Does the scheme documentation require that applied auditing procedures shall fulfil or be compatible with the requirements of ISO 19011?

Annex 6, 4

14.

15.

Does the scheme documentation require that certification body shall inform the relevant PEFC National Governing Body about all issued forest management and CoC certificates and changes concerning the validity and scope of these certificates? Does the scheme documentation require that certification body shall carry out controls of PEFC logo usage if the certified entity is a PEFC logo user?

Yes Annex 6, 4

Yes Annex 6, 4

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Annex 5
No. Question Reference to Yes / Reference to scheme PEFC Council No* documentation doc. Yes Scheme 7.2.11 Regular monitoring of the certificate holder will be Annex 6, 4 carried out by the Certification Body at regular intervals (at least annually). Yes Scheme 7.2.10 Certificates can only remain valid for a Annex 6, 4 maximum period of five years from the date of issue. Yes 7.2.13 Public Summary Report shall be provided by the National governing body/ certification body. Applicant shall give a written consent to certification body and allow them to publish a public summary report. 7.2.12 Stakeholder consultation as an integral component of Scheme’s forest certification management Scheme 7.1 Certificate shall include the content described in the ISO Guide 62, 65 or 66. Additional requirements e.g. notification of the CBs. Scheme 7.1.5. Certification bodies shall be accredited by IAF member accreditation body. Scheme does not specifically state that accreditation shall be to UKWAS standard and/or CoC standard. The Scheme require the CB to issue certificates which shall bear an accreditation symbol (Scheme 7.1.5) Scheme 7.1.1 Bodies operating according to ISO Guides (62, 65, 66) and members of IAF.

16.

Does a maximum period for surveillance audits defined by the scheme documentation not exceed more than one year?

17

Does a maximum period for assessment audit not exceed five years for both forest management and CoC certifications?

18

Does the scheme documentation include requirements for public availability of certification report summaries?

Annex 6, 4

Yes 19 Does the scheme documentation include requirements for usage of information from external parties as the audit evidence? Annex 6, 4

Yes Does the scheme documentation include additional requirements for certification procedures? [*1]

20.

Annex 6, 4

Accreditation procedures Yes Does the scheme documentation require that certification bodies carrying out forest management and/or CoC certification shall be accredited by a national accreditation body?

21.

Annex 6, 5

Yes 22. Does the scheme documentation require that an accredited certificate shall bear an accreditation symbol of the relevant accreditation body? Does the scheme documentation require that the accreditation shall be issued by an accreditation body which is a part of the International Accreditation Forum (IAF) umbrella and which implement procedures described in ISO 17011 and other documents recognized by the abovementioned organizations? Annex 6, 5

Yes

23.

Annex 6, 5

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Annex 5
No. Question Does the scheme documentation require that certification body undertake forest management or/and CoC certification against a scheme specific CoC standard as “accredited certification” using one of two options recognised by the PEFC Council? Does the scheme documentation require that certification body undertake CoC certification against Annex 4 as “accredited certification” based on ISO Guide 65? Does the scheme documentation include a mechanism for PEFC notification of certification bodies? Reference to Yes / Reference to scheme PEFC Council No* documentation doc. Yes Certification bodies shall be accredited by IAF member Annex 6, 5 accreditation body

24.

Yes 25. Annex 6, 5

Yes

26.

Yes 27. Are the procedures for PEFC notification of certification bodies non-discriminatory?

Scheme has adopted the PEFC TD Annex 4 as the CoC standard. The document includes the accreditation requirement. Scheme 7.1.8 The CBs shall be notified by the PEFC national GBs of the relevant countries Scheme 7.1.8 The PEFC notification conditions shall not discriminated against certification bodies or create trade obstacles.

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ANNEX 6
Consultants response to Peer Review

Annex 6 INDUFOR OY REPLIES TO THE EXPERT REVIEW REPORT 01 ON PEFC UK CERTIFICATION SCHEME November 28, 2007 1. BACKGROUND Indufor Oy, the consultant responsible for the conformity assessment of the PEFC UK Certification Scheme, submitted the first assessment report in March 2007. The PEFC Expert Review Panel [hereafter Expert Panel] evaluated the report and reported in the Draft Expert Panel Report v.01 issued in November 2007 a number of issues needing further clarifications. Indufor responded to all the 16 issues and made relevant corrections to the main assessment report, which was re-submitted to PEFC Council in mid-August 2007. Expert Panel considered the Indufor responses and came out with a final Expert review report (v. 1.1) in October 2007. The Panel had accepted a number of Indufor clarifications as such but required further justifications to others. In this paper Indufor Oy [Consultant] gives further reasoning for its conclusions and accepts to revise the assessment report if it considers it necessary in view of the issue raised by the Expert Panel. Consultant maintains the independence in drawing the conclusions and can defend them even if they are contradictory to the views of the Expert Panel.

2.

ISSUES NEEDING FURTHER CLARIFICATION (by Edwin Aalders) 2.1 Assessment Report Issue 1 Inconsistency between Annex and the Report. Panel of Experts Conclusion v. 01 The assessment findings in the report appear not to be in line with those that are provided in the Checklists in Conclusions 4, 6, 8, 34, 43, the report states that there is a non-conformity to the PEFC requirements were annex I & III to the report states for those same points “Yes”. Indufor Response v.1.0 The inconsistency between the Report and the related Annexes is due to the reporting model required by the PEFC Council. The PEFCC has requested the Consultant to adhere to dual conclusions in reporting, which according to PEFCC, describes in a more illustrative way the conformance to PEFC requirements. The conformance or non-conformance is established based on the documentation of the scheme and practical performance declared by the scheme. The conclusions of the final report reflect the findings in the checklist (the Annexes 1 to 5), but due to the reporting technique the Conclusions in the report look contradictive to those in the Annexes. Finally the practice is only verified by the PEFC. This is also the reason why the other requirements than for standard setting are only assessed based on "documentation”. Indufor Action References to application documentation in the Annex 1 have been modified to dual conclusion form similar to that in the report text.

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Annex 6 Issue 2 Division of conclusions in Conclusion 11 to Practice and Documentation. Panel of Experts Conclusion v. 01 Page 12 – Conclusion 11: the supportive text seem to be contradictive in terms that on the one hand it indicates that the scheme does not require views of all parties to be discussed but on the other hands indicates that standard setting process of the scheme dictate that a formal response to all the comments received should be available to all interested parties. The “formal response” would indicate that inputs have been discussed before a response would be formalised. Indufor Response v.1.0 Conclusions of the Consultants report are divided into Documentation and Practice parts to verify the actual compliance of the scheme to the PEFCC requirements. The report technique required by the PEFCC allows the Consultant to present conclusions that may seem unambiguous, but still correctly describing the overall compliance of the scheme to the particular requirement. The division address specifically and separately compliance of documentation (written standard setting procedures) and practice (standard setting process itself). The Consultant presents its professional judgment of the scheme development process and in particular of the scheme compliance to the requirement presented in the chapter 3.4.3 of PEFCC TD Annex 2. The Chapter 3.4.3 and the corresponding Conclusion 11 in the Consultant’s report are related to the Consultation stage of the Standard development. The Consultant considers the practical implementation of the scheme development process in this matter sufficient (see B7; UKWAS Revision Consultation Returns and Steering Group Decision July 2004 as an example of the discussion of views of different interested parties) and in compliance to the PEFCC requirements. The implementation of the requirement in practice is considered by the Consultant to be sufficient ground for establishing compliance with the correspondent requirement. Indufor Action No action

Issue 3 Substitution of pilot testing Panel of Experts Conclusion v. 01 “PEFCC deems that in standards revisions separate pilot testing is not necessary if the extent of change made do not justify it” The consultant failed to indicate whether it the scheme has made its case that changes made in the scheme did not justify a new pilot test. Indufor Response v.1.0 The Consultant justifies its conclusions only based on the written PEFCC requirements (in this case Chapter 5 of PEFCC TD), which clearly states “in case of revision of the standards, experience gained from the application of the standards can substitute pilot testing”. The Chapter 5 of the PEFCC TD does not provide any means of verification for the nature of application of the scheme. Thus, the scheme under revision is eligible for pilot test substitution.

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Annex 6 Indufor Action No action

Issue 4 Inconsistency between the Report and respective Annex. Panel of Experts Conclusion v. 01 “Non-conformity to the PEFC requirement” The requirement indicates that all forest areas of the forest owners should be part of the certification scheme. In the supportive text the consultant writes: “All members must formally commit to complying with all the requirements of UKWAS….” It is unclear why the consultant indicates that there is a non-conformity whilst the supportive text and the control point 43 of Annex III seem to indicate that the scheme is in compliance. Indufor Response v.1.0 Although according the scheme all members must formally commit to complying with all the requirements of UKWAS in respect of all forest areas included within the scope of the particular group Scheme concerned (Scheme 7.3.4), the scheme does not explicitly require the group members to submit all the forest area under his management in the catchment area. (see Report Conclusion 34) Indufor Action Report text changed to explain conclusion in more specific way. Annex text changed to be consistent with report.

Issue 5 Auditing procedure requirements Panel of Experts Conclusion v. 01 Page 27 – Conclusion 48: “Does not conform” The explanation about why the Consultant considers that the scheme is not compliant does not really address the requirement of PEFC. The consultant talks about the way UKAS is being audited. It indicates that “Scheme 7.1.6 states in general that auditors shall meet competence criteria developed by appropriate ABs…” providing the indication that the requirements of ISO19011 are being met. Unlike Conclusion 45 the report does not specifically spell out that the scheme does not have any explicitly reference to ISO19011:2002. If the consultant feels that the requirements are met through the fact that UKAS is an IAF and EA member and as such bound to use ISO 19011 when looking at auditor competence then the consultant should conclude that requirements are being met. Indufor Response v.1.0 Scheme 7.1.6 states in general that auditors shall meet competence criteria developed by appropriate ABs. ABs base their requirements on appropriate ISO standards; e.g. ISO 19011. UKAS is signatory to the multilateral agreements of European Co-operation for Accreditation (EA)/International Accreditation Forum (IAF) and subject to the peer review of other ABs. The certification process and the competence of auditors are among the core accreditation requirements. This PEFCC requirement is respected in practice, although it is not explicitly required by the Scheme.

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Annex 6 The Consultant does not talk about UKWAS being audited like the peer review comment of Mr. Edwin Allders indicates. The question 13 “ Does the scheme documentation require that applied auditing procedures shall fulfil or be compatible with the requirements of ISO 19011?” refers a) to the documentation and b) to the auditing procedures of the certification bodies. The Consultant concludes nonconformance to PEFC requirements based on the absence of the appropriate ISO 19011 references in the scheme text. Auditing procedures in question are related to the auditing requirements of the ABs for the CBs. Indufor Action No action

Issue 6 Availability of public summary report Panel of Experts Conclusion v. 01 Page 28: Conclusion 53: “Applicant must give his explicitly written consent to publication of the public summary report…” The requirements state that the certification report summary should be publicly available. The question which is open with the findings of the consultant and its conclusion is “What will happen if the applicant does not give his written consent to the publication of the public summary report?” Indufor Response v.1.0 The Scheme requires that the Scheme Governing Body and the Certification Body conducting the audit shall make the Public Summary Report on the certification decision public (Scheme 7.2.13). Applicant must give his explicit written consent to publication of the public summary report (Scheme 7.2.13). The Consultant presents the above conclusion based on the scheme text. The Consultant gives an answer to the question “Does the scheme documentation include requirements for public availability of certification report summaries?” and will not speculate whether the applicant is willing to comply with the scheme requirements. The consultant assumes that an entity which does not meet scheme documentation would not qualify for obtaining or for maintenance of "certified" status. Indufor Action No action

Issue 7 UK national accreditation body Panel of Experts Conclusion v. 01 Page 28: Conclusion 55: “The scheme accepts the accreditation issued by an AB being a member of IAF and EA. In UK the UKAS is the national AB…”It seems to be unclear if any other AB can be used i.e. RvA, Belcert etc or that UKAS is the only AB that can be used. Since the Consultant seem to mix AB with UKAS. For example on page 2 of the report states “… and other provision of AB (United Kingdom Accreditation Services UKAS)”.

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Annex 6 Indufor Response v.1.0 The Consultant does not mix AB and UKAS since the UKAS is according to the scheme the national accreditation body. The question “Does the scheme documentation require that certification bodies carrying out forest management and/or CoC certification shall be accredited by a national AB?” refers to the accreditation by the national accreditation body and since the scheme states in the Chapter 7.1.3 that UKAS is the national AB the Conclusion 55 of the report still applies. UK scheme, by specifying the single accreditation body (member of IAF and EA), is more specific than the PEFCC documentation and thus complying with the PEFC requirement. Indufor Action No action

Issue 8 Consultant’s field visit Panel of Experts Conclusion v. 01 The report outlines that no field visit was done since the scheme considered the experience gained during the initial version of the scheme. However, the consultant does not clearly outline whether it considered that the changes to the scheme are such that no field visit is required. Indufor Response v.1.0 The PEFCC procedures related scheme revisions do not include field visits. Field visit was optional in the Indufor’s offer for the scheme assessment and was not included by the PEFCC in the assessment’s scope. Indufor Action No action

Issue 9 Comments from PEFC Council members and other stakeholders Panel of Experts Conclusion v. 01 The summary of the comments on the Scheme is rather minimalistic and not very clear what the intend of the comments were. Indufor Response v.1.0 The Comments to the scheme are presented to the Consultant according to the Chapter 6.2.1. of the Annex 7 of the PEFCC TD. The PEFC requirements of the corresponding chapter do not include any procedural requirements related to the handling of the presented comments. The Consultant has duly taken all comment into consideration and also indicated to what matters the comments were related. The Consultant is not in the position to disclose the original comments due to the confidentiality between the Consultant and the provider of the comments. Indufor Action No action

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Annex 6 Issue 10 Comments from PEFC Council members and other stakeholders. Panel of Experts Conclusion v. 01 The summary of the comments on the UKWAS Standard is rather minimalistic and not very clear what the intend of the comments were Indufor Response v.1.0 The Comments to the UKWAS standard are presented to the Consultant according to the Chapter 6.2.1. of the Annex 7 of the PEFCC TD. The PEFC requirements of the corresponding chapter do not include any procedural requirements related to the handling of the presented comments. The Consultant has duly taken all comment into consideration and also indicated to what matters the comments were related. The Consultant is not in the position to disclose the original comments due to the confidentiality between the Consultant and the provider of the comments. Indufor Action No action

Issue 11 Comments from PEFC Council members and other stakeholders Panel of Experts Conclusion v. 01 “Comments related to the content of the UKWA Standard” should read “Comments related to the content of the UKWAS Standard” Indufor Response v.1.0 Peer review comment considered Indufor Action Report text changed to “Comments related to the content of the UKWAS Standard”.

Issue 12 Comments from PEFC Council members and other stakeholders Panel of Experts Conclusion v. 01 “The Substantial comments were duly taken into consideration in the assessment and the editorial comments were informed to the PEFC UK”. It is not clear from the report what the Scheme has done with the comments that were received. Have they resulted to a change in the scheme requirements? Have some been considered not relevant or not acceptable? Indufor Response v.1.0 The Comments to the UKWAS standard are presented to the Consultant according to the Chapter 6.2.1. of the Annex 7 of the PEFCC TD. The PEFC requirements of the

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Annex 6 corresponding chapter do not include any procedural requirements related to the handling of the presented comments. The Consultant has duly taken all comment into consideration and also indicated to what matters the comments were related. The PEFC UK was informed about all editorial comments. After interruption the PEFC UK has made changes to the original scheme and included editorial comments in the final version of the scheme documentation. The Consultant is not in the position to disclose the original comments due to the confidentiality between the Consultant and the provider of the comments. Indufor Action No action

Issue 13 Inconsistency between the Annexes and the report. Checklist findings not in line with those in the report. Panel of Experts Conclusion v. 01 The checklist findings appear not to be in line with those that are summarised in the report. Checklists items 8, 10, 12 and 16 state that the requirements are met where the corresponding text in the report indicates that requirements are not met. Indufor Response v.1.0 See Indufor response to Issue 1 Indufor Action See Indufor action in Issue 1.

Issue 14 Have views of interested parties been discussed? Annex 2, 3.4.3 Panel of Experts Conclusion v. 01 Control point 16: The answer in the checklist does not seem to answer the requirement and in contradiction with statements in report. The fact that the comments from interested parties are kept by UKWAS does not necessarily mean that they have been discussed. In the report at the same time the report states “The Scheme documentation does not explicitly require that the views of all parties should be discussed…” This finding and consequent solution in the report are not at all reflected in the checklist. Indufor Response v.1.0 The control point 16 is related to the Consultation stage of the standard setting process. Chapter 3.4.3. of the Annex 2 of the PEFCC TD requires that the consultation shall ensure that the views of interested parties are discussed. The Chapter B7 point (h) of the Standard setting document states that “Summaries of comments on each draft, together with a brief explanation of the way in which those comments were responded to in the draft”. The Consultant has reason to assume this requirement answers the Control point question 16.

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Annex 6 Indufor Action No action

Issue 15 Typing error Panel of Experts Conclusion v. 01 Control point 6.1.e): “… training and/pr...” should be “…training and/or…” Indufor Response v.1.0 Correction should be made Indufor Action Annex 2 text changed in point 6.1e) to “training and/or…”

Issue 16 Report lay out Panel of Experts Conclusion v. 01 Respective Annex in twice in the report Indufor Response v.1.0 Unclear indication of the matter. Indufor Action No action

Issue 17 Insufficient justification Panel of Experts Conclusion v. 01 Control point 34: “Scheme 7.3.4 Basis of Group Certification”. Does not seem to answer the question of the requirement at other control points the consultant give clear explanation of what the scheme is requiring here only reference is given. Indufor Response v.1.0 Response expanded Indufor Action Response to question 34 in the Annex 3 of the report expanded to: All members of the group must formally commit to complying with all requirements of the standard in respect of all forests areas included in the scope of the particular group scheme concerned. Scheme 7.3.4 Basis of Group Certification

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Annex 6 Issue 18 Content of the Annex 3 response to question 35. Panel of Experts Conclusion v. 01 Control point 35: “Group Member shall set out clearly documentation criteria for eligibility and on-going membership of the group”. Does not seem to answer the question of the requirement. Indufor Response v.1.0 Inadequate formulation of the question by the peer reviewer. (“Does not seem to answer the question” could not be considered as an argument) Indufor Action No action

Issue 19 Insufficient justification Panel of Experts Conclusion v. 01 Control point 37: “Scheme 7.3.4, 7.3.7” Why does the consultant not give a short summary of the requirements as it does with the other control points now not clear what these points require. Indufor Response v.1.0 Response expanded. The consultant assumes the "records of the group members" would also cover the certified area. Indufor Action Response to question 37 in the Annex 3 of the report expanded to: The Scheme requires that all members of the group must formally commit to complying with all the requirements of UKWAS in respect to all forests areas included within the scope of the particular group Scheme concerned. The Scheme also requires that Group Entity must accept contractual responsibility to the Certification Body for ensuring that the requirements of UKWAS are implemented by all Group Members for forest areas covered by the certificate. (Scheme 7.3.4,7.3.7) The Scheme also requires the Group Entity to keep records of the group members (Scheme 7.3.7).

Issue 20 Insufficient justification Panel of Experts Conclusion v. 01 Control point 41: “Scheme Section 7” Why does the consultant not give a short summary of the requirements as it does with the other control points now not clear what these points require.

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Annex 6 Indufor Response v.1.0 Response expanded Indufor Action Response to question 41 in the Annex 3 of the report expanded to: The Group certificate and Resource Manager certificate is issued to the applicant as required by the PEFC (Scheme 7.3.9; 7.3.13).

Issue 21 Typing error Panel of Experts Conclusion v. 01 Control point 43: “Yes” The finding here is in contradiction with the comments in the report Page 21 Conclusion 34 “Non-conformity” Indufor Response v.1.0 Typing error to be changed to appropriate Indufor Action Answer “No” changed to “Yes” in Control point 43 of the Annex 3 of the report.

Issue 22 Insufficient justification Panel of Experts Conclusion v. 01 Control point 49: “Scheme 6.11” Why does the consultant not give a short summary of the requirements as it does with the other control points now not clear what these points require. Indufor Response v.1.0 Response expanded Indufor Action Response to question 49 in the Annex 3 of the report expanded to: The accreditation authority shall ensure that the certification authority meets all the requirements of ISO/IEC Guides 62 and 65 as well as all the criteria which are explicitly part of the UK Woodland Assurance Standard. Scheme 6.11.

Issue 23 Content of the mentioned requirements not defined

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Annex 6 Panel of Experts Conclusion v. 01 Control point 1: “Scheme Section 6.11 and 7.1” Why does the consultant not give a short summary of the requirements as it does with the other control points now not clear what these points require. Indufor Response v.1.0 Response expanded Indufor Action Response to question 1 in the Annex 5 of the report expanded to: Certification authorities shall be accredited to undertake independent woodland management certification using the UK Woodland Assurance Standard by a national or international accreditation authority that operates in accordance with ISO/IEC 17011:2004.

Issue 24 Inadequate justification Panel of Experts Conclusion v. 01 Control point 2: “Scheme 7.1.2 Defines formal criteria of competence for certification bodies”. Scheme point 7.1.2. does not define competence criteria it outlines the fact that “Scheme. All new entries to Forest Management Certification will adhere to the revision of UKWAS dated 1st November 2006…”. Indufor Response v.1.0 The response 2 of Annex 5 of the report states: Scheme 7.1.1 Requirement for certification bodies shall fulfil internationally accepted standards (ISO Guides 61, 62, & 65). The peer reviewer presents view that does not relate to the subject. Indufor Action No action

Issue 25 Content of the Annex 5 response to question 9. Panel of Experts Conclusion v. 01 Control point 9: “Scheme 7.1.4 Competence criteria for auditors” Does not seem to answer the question of the requirement Indufor Response v.1.0 Inadequate formulation of the question by the peer reviewer. (“Does not seem to answer the question” could not be considered as an argument) Indufor Action No action

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Annex 6 Issue 26 Insufficient justification Panel of Experts Conclusion v. 01 Control point 16; “Scheme 7.2.11” Why does the consultant not give a short summary of the requirements as it does with the other control points now not clear what these points require. Indufor Response v.1.0 Response expanded Indufor Action Response to question 16 in the Annex 5 of the report expanded to: Regular monitoring of the certificate holder will be carried out by the Certification Body at regular intervals (at least annually).

Issue 27 Insufficient justification Panel of Experts Conclusion v. 01 Control point 17; “Scheme 7.2.10” Why does the consultant not give a short summary of the requirements as it does with the other control points now not clear what these points require. Indufor Response v.1.0 Response expanded Indufor Action Response to question 17 in the Annex 5 of the report expanded to: Certificates can only remain valid for a maximum period of five years from the date of issue.

Issue 28 Adherence of the applicant to the PEFC UK scheme requirements Panel of Experts Conclusion v. 01 Control Point 18: “…Applicant shall give a written consent to...” No indication on what will happen if there is no written consent. Indufor Response v.1.0 The scope of the assignment does not include the assessment of the applicant’s possible non-conformity to the scheme requirements. The Consultant will speculate what may happen if the applicant choose not comply with the scheme requirements. Essence of the voluntary forest certification is adhering voluntary to the rules and requirements of the particular scheme. On the other hand the certification bodies will

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Annex 6 assess the compliance to the requirement in their certification audits. The consultant assumes that an entity, which does not meet scheme documentation, would not qualify for obtaining or for maintenance of "certified" status. Indufor Action No action

Issue 29 Insufficient justification Panel of Experts Conclusion v. 01 Control Point 20: “…described in the ISO Guide 65.” Why does the consultant only make reference to ISO Guide 65 the other ISO Guides (62 & 66) have similar requirements? Indufor Response v.1.0 The questions means: “ does the scheme include requirements other than general requirements presented in ISO Guide 62, 65 or 66 i.e. other matters than questions 119”. The additional requirements are e.g. notification of the certification bodies. Indufor Action Adding to the response to question 20 in Annex 5 of the report: “Certificate shall include the content described in the ISO Guide 62, 65 or 66” “Additional requirements e.g. notification of the certification bodies (Scheme 7.1.5)”.

3.

ISSUES NEEDING FURTHER CLARIFICATION (by Chris Yates-Smith) 3.1 Assessment Report Issue Panel of Experts Conclusion v. 01 Indufor Response v.1.0 Indufor Action

Issue 1 Formulation of the justification Panel of Experts Conclusion v. 01 There are a number of grammatical, typing and spelling errors throughout the report. For example the report states that ‘The UKWAS Company’s Memorandum and Articles of Association do not let the UKWAS to undertake certification or accreditation activities, nor let certification these bodies influence the standard setting procedure.’ (Paragraph 5.1(1)) It would be advisable for the report to be subject to a through editing to remove such errors prior to publication. Indufor Response v.1.0 Justification in the Paragraph 5.1. (1) re-formulated.

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Annex 6 Indufor Action The UKWAS Company’s Memorandum and Articles of Association do not let the UKWAS to undertake certification or accreditation activities, nor let the certification bodies to influence the standard setting procedure.

Issue 2 Unclear justification Panel of Experts Conclusion v. 01 Paragraph 5.1.(7) states thus: ‘The Steering Group Rules define that it represents 13 constituencies’ whereas later within the section it comments that the ‘Steering Group represents 11 constituencies’ and Table 5.1 appears to identify 14 constituent groups. Clarification would be useful. Indufor Response v.1.0 According to the Scheme Chapter 6.3 the Steering group comprise of 13 constituencies. The following is the structure of the steering group and the maximum representation for each of the 13 constituencies: Chair and Secretary (2), Woodland owners (6), Forest managers (5), State forestry representation (4), Environmental organisations (6), Forest users (2), Wood processing interests (3), Wood products industry (2), Forest workforce (2), Countryside agencies (2), Local government (2), Standard setting bodies (3), Other (1) and Unallocated (1). (PEFC UK Ltd holds the current unallocated position). One constituency is unallocated. Indufor Action No action

Issue 3 Reporting technique Panel of Experts Conclusion v. 01 The formatting of the report is muddled. The presentation of ‘Conclusions’ up to and including Conclusion Number 22 is fairly consistently presented in two sections, one for ‘Documents’ and the other for ‘Practice’. However, after Conclusion 22 the text is primarily contained solely within one heading of ‘Documents’ despite the contents often appearing to be describing practice issues Indufor Response v.1.0 The PEFCC has requested the Consultant to adhere to dual conclusions in reporting, which according to PEFCC, describes in a more illustrative way the conformance to PEFC requirements. The conformance or non-conformance is established based on the documentation of the scheme and practical performance declared by the scheme. The conclusions of the final report reflect the findings in the checklist (the Annexes 1 to 5), but due to the reporting technique the Conclusions in the report look contradictive to those in the Annexes. The Conclusions after Conclusion 22 reflect answers either for questions related to documentation or practice.

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Annex 6 Indufor Action No action

Issue 4 References to the Scheme Panel of Experts Conclusion v. 01 The format of referencing the scheme paragraphs rather than inserting clarifying text in support of the Consultants comments results in unnecessary additional research work for the Panel members. Indufor Response v.1.0 The Consultant assumes that anyone reading the assessment report also goes through Scheme documentation. The reference technique used by the consultant is widely used in PEFC evaluations and present no exception from the common practice. Indufor Action No action

Issue 5 Reference to UKAS as accreditation body Panel of Experts Conclusion v. 01 The use of AB and UKAS appears to be confused on occasion. Indufor Response v.1.0 The scheme states in the Chapter 7.1.3 that UKAS is the national AB. See also Indufor response to Ch. 2.1 Issue 7 Indufor Action No action

Issue 6 Inconsistency between Annex and the Report. Panel of Experts Conclusion v. 01 Annex I and III have ‘Yes’ detailed in the sections where the assessment states that the scheme does not comply with PEFC requirements, i.e. at Conclusions 4, 6, 8, 34, 43. Indufor Response v.1.0 The inconsistency between the Report and the related Annexes is due to the reporting model required by the PEFC Council. The PEFCC has requested the Consultant to adhere to dual conclusions in reporting, which according to PEFCC, describes in a more illustrative way the conformance to PEFC requirements. The conformance or non-conformance is established based on the documentation of the scheme and practical performance declared by the scheme.

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Annex 6 The conclusions of the final report reflect the findings in the checklist (the Annexes 1 to 5), but due to the reporting technique the Conclusions in the report look contradictive to those in the Annexes Indufor Action References to application documentation in the Annex 1 have been modified to dual conclusion form similar to that in the report text.

Issue 7 Dual conclusions (based on documentation and practice) in the report. Panel of Experts Conclusion v. 01 Pg 9 - Conclusion 4 states that the ‘Articles of Association or the Steering Group Rules as standard setting documents do not require transparent documentation’ and therefore do not meet PEFC requirements that the ‘views of all relevant interested parties been documented and considered in an open and transparent way?’ Any, even technical, questions of failures of transparency will be monopolised by the UK NGO community and used as an opportunity to criticise the scheme and legitimately raises the question of how, if passed, any breaches of transparency will be identified and resolved? Indufor Response v.1.0 Conclusions of the Consultants report are divided into Documentation and Practice parts to verify the actual compliance of the scheme to the PEFCC requirements. The report technique required by the PEFCC allows the Consultant to present conclusions that may seem unambiguous, but still correctly describing the overall compliance of the scheme to the particular requirement. Indufor Action No action

Issue 8 Contradictive conclusions in Conclusion 11 Practice and Documentation. Panel of Experts Conclusion v. 01 Pg 12 - Conclusion 11 appears confused. The text states that the ‘Scheme documentation does not explicitly require that the views of all parties should be discussed, however the Standard setting process document requires that the formal responses to comments received (from the interested parties) shall be available to all interested parties’ and continues to state that the scheme complies with PEFC requirements in this area. In addition to being confusing in nature, given the previous allegations that PEFC fails to incorporate the views of all stakeholders, any issues which may be used to support this allegation is unwelcome and PEFC should ensure immediate resolution. Indufor Response v.1.0 Conclusions of the Consultants report are divided into Documentation and Practice parts to verify the actual compliance of the scheme to the PEFCC requirements. The report technique required by the PEFCC allows the Consultant to present conclusions that may seem unambiguous, but still correctly describing the overall compliance of the scheme to the particular requirement.

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Annex 6 The Consultant presents its professional judgment of the scheme development process and in particular of the scheme compliance to the requirement presented in the chapter 3.4.3 of PEFCC TD Annex 2. The Chapter 3.4.3 and the corresponding Conclusion 11 in the Consultant’s report are related to the Consultation stage of the Standard development. The Consultant considers the practical implementation of the scheme development process in this matter sufficient (see B7; UKWAS Revision Consultation Returns and Steering Group Decision July 2004 as an example of the discussion of views of different interested parties) and in compliance to the PEFCC requirements. The implementation of the requirement in practice is considered by the Consultant to be sufficient ground for establishing compliance with the correspondent requirement. Indufor Action No action

Issue 9 Content of the public consultation Panel of Experts Conclusion v. 01 Pg 12 - Conclusion 13 might be open to criticism. Thus whilst the requirement is for the scheme to be open for consultation for 60 days and the consultation process took place from June 2003 until 16th Jan 2006, PEFC only received formal CPET confirmation of providing both legal and sustainable timber on 18th December 2006. Therefore the final stage of the consultation process could be argued to have in reality only been for a period of one month, that following the governmental announcement of unconditional legality and sustainability. Indufor Response v.1.0 The Consultant had no reason to question the adequacy of the content of the consultation stage of the scheme development since the issue is the duration of the consultation period. (Had the consultation been at least 60 days? Annex 2, 3.4.3) Indufor Action No action

Issue 10 Pilot testing Panel of Experts Conclusion v. 01 Pg 13 - Conclusion 16. There is no evidence included in the text to show whether the Scheme was correct in its view that a new pilot text was not required due to the extent of change made. Indufor Response v.1.0 The Consultant justifies its conclusions only based on the written PEFCC requirements (in this case Chapter 5 of PEFCC TD) which clearly states that “in case of revision of the standards, experience gained from the application of the standards can substitute pilot testing”. The Chapter 5 of the PEFCC TD does not provide any means of verification for the nature of application of the scheme. Thus, the scheme under revision is eligible for pilot test substitution.

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Annex 6 Indufor Action No action

Issue 11 Unclear justification Panel of Experts Conclusion v. 01 Pg 20 - Conclusion 29 is ambiguous. It is not clear, from the text, whether or not the scheme ‘documentation require that total forest area participating in group certification is recorded?’ Indufor Response v.1.0 Chapter 4.1 b) of Annex 3 of the PEFC TD requires that “ the total area participating in group certification shall be recorded”. The Scheme requires that Group Entity must accept contractual responsibility to the Certification Body for ensuring that the requirements of UKWAS are implemented by all Group Members for forest areas covered by the certificate. (Scheme 7.3.4,7.3.7) The Scheme also requires the Group Entity to keep records of the group members (Scheme 7.3.7). The PEFC TD does not specify how area participating in the group certification shall be recorded. Based on the requirements presented by the scheme in Chapters 7.3.4 and 7.3.7, the Consultant had found the scheme requirements sufficient and in compliance with PEFC requirements. Indufor Action No action

Issue 12 Availability of public summary report Panel of Experts Conclusion v. 01 Page 28 - Conclusion 53 concerns the question ‘Does the scheme documentation include requirements for public availability of certification report summaries?’ and the response is that the “Applicant must give his explicitly written consent to publication of the public summary report”. This issue of transparency may be improved by the detailing of a process which would be followed if and when the applicant refuses to do so. Indufor Response v.1.0 The Scheme requires that the Scheme Governing Body and the Certification Body conducting the audit shall make the Public Summary Report on the certification decision public (Scheme 7.2.13). Applicant must give his explicit written consent to publication of the public summary report (Scheme 7.2.13). The Consultant presents the above conclusion based on the scheme text. The Consultant gives an answer to the question “Does the scheme documentation include requirements for public availability of certification report summaries?” and will not speculate whether the applicant is willing to comply with the scheme requirements. Indufor Action No action

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Annex 6 Issue 13 Strictness of the requirements of the scheme Panel of Experts Conclusion v. 01 Pg 30 - Conclusion 61 states that ‘The Scheme requires that, the PEFC notification conditions shall not discriminate against certification bodies or create trade obstacles (Scheme 7.1.8). The Scheme describes the minimum notification conditions, which the National Governing Body should meet.’ Given that it is illegal to create trade obstacles, does PEFC leave itself vulnerable with a scheme that only identifies conditions which it ‘should’ meet and not those it ‘shall’ meet? Indufor Response v.1.0 The Consultant will not speculate about the sufficiency of the scheme requirements in relation to legislation and it is not in the scope of the assessment. The Consultant assumes that the scheme requirements correspond at adequate level to the legislation in force. The Scheme Ch. 7.1.8 p. 44 states, “the PEFC notification conditions shall not discriminate against certification bodies or create trade obstacles. Indufor Action No action

Issue 14 Field visit Panel of Experts Conclusion v. 01 The report states that other than when evaluating to initial version of the scheme, field visits have not been conducted. The report does not express a view as to the correctness of this decision. Given the likely intense scrutiny that the scheme will attract the decision not to conduct a further field visit may prove to be unwise. Indufor Response v.1.0 The PEFCC procedures related scheme revisions do not include field visits. Field visit was optional in the Indufor’s offer for the scheme assessment and was not included by the PEFCC in the assessment’s scope. The exclusion of the field trip has been decided by the Board of Directors and this decision is done individually for each scheme. Indufor Action No action

Issue 15 Comments from the stakeholders Panel of Experts Conclusion v. 01 Comments from PEFC Council members and other stakeholders: • On Pg 31 the report appears to only summarise the comments made by the Australian Forestry Standard Limited. The summary is very brief and uninformative and it is unclear how or if there have been any amendments to the scheme in response to their comments or even that their comments were

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Annex 6 discussed. This shows a lack of transparency which may leave the scheme open to criticism. Whilst obviously the thoughts of the Australian Forestry Standard Limited are of value to the evaluation of the scheme, given the level of anti AFS views held by the UK NGO’s, it may be been wiser for their comments to have been included within those of other commentators. There is not any reference to any further commentaries having been made on the scheme by stakeholders. If this was the case, PEFC would have to question the efficacy of the consultation process and if not, other commentaries should have been considered and detailed.

Indufor Response v.1.0 The Comments to the scheme are presented to the Consultant according to the Chapter 6.2.1. of the Annex 7 of the PEFCC TD. The PEFC requirements of the corresponding chapter do not include any procedural requirements related to the handling of the presented comments. The Consultant has duly taken all comment into consideration and also indicated to what matters the comments were related. The Consultant is not in the position to disclose the original comments due to the confidentiality between the Consultant and the provider of the comments. Indufor Action No action

Issue 16 Minimum requirement checklist Panel of Experts Conclusion v. 01 • Whilst clearly not an expert on the minimum requirements of the certification schemes provided by PEFC and FSC, examination of both lead to the following views. It would appear from documentation that FSC is less concerned than PEFC in the standard setting process but rather more concerned with both the consultation processes when obtaining certification and when making changes to the certification processes. The FSC scheme appears to be more demanding than the PEFC one, with the widespread use of ‘shall’ rather than ‘should’ for example, FSC states that ‘Clear evidence of long-term forest use rights to the land (e.g. land title, customary rights, or lease agreements) shall be demonstrated.’ Whereas PEFC states on Pg 52 ‘Property rights and land tenure arrangements should be clearly defined, documented and established for the relevant forest area. Likewise, legal, customary and traditional rights related to the forestland should be clarified, recognized and respected.’ A strong commitment to ensuring continued availability of customary or traditional rights to land use, for example, by the Ramblers Association, may prove to become a market access issue as the organization is a large, articulate group with considerable purchasing ability who may welcome the active support of a certification body in their current campaigns to make more land available to ramblers. FSC appears to be moving ahead of PEFC as in its principles it differentiates, in a fairly comprehensive manner, between the evidence required for verification into two types, ‘All Woodlands Criteria’ and ‘Woodlands over 100HA Criteria’, with the latter being more rigid. Whilst the PEFC minimum requirements checklist only appears to state: ‘1.1 c) Management plans or their equivalents, appropriate to the size and use of the forest area, should be elaborated and periodically updated.‘ (Pg 42)

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Annex 6 • It would appear that FSC continues to have more comprehensive provision for Indigenous peoples and their rights than PEFC. Whilst FSC in its UK scheme states that it does not consider there to be Indigenous peoples in the UK, this comment alone reinforces the belief that it promotes the rights of indigenous peoples elsewhere. The current PEFC assessment makes no reference to indigenous peoples.

Indufor Response v.1.0 The comparison between FSC and PEFC requirements is not in the scope of the assessment. The assessment is executed based on the PEFC minimum requirement checklist. Indufor Action No action

4.

ISSUES NEEDING FURTHER CLARIFICATION (by Hans Köpp) 4.1 Assessment Report Issue Panel of Experts Conclusion v. 01 Indufor Response v.1.0 Indufor Action

Issue 1 Incorrect definition Panel of Experts Conclusion v. 01 Conditional re-endorsement (not: endorsement) Indufor Response v.1.0 The PEFC TD does not include term re-endorsement. The PEFC TD Annex 2 and Annex 7 talk about endorsement of the revised schemes and standards. Indufor Action No action

Issue 2 Deadline for fulfilling the conditions = missing Panel of Experts Conclusion v. 01 Deadline for fulfilling the conditions = missing Indufor Response v.1.0 The statement could not be defined. The Consultant could not define what matter the issue presented by Mr. Hans Köpp is related to.

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Annex 6 Indufor Action No action

Issue 3 How was the situation (concerning points 2 + 8) at the first endorsement? Panel of Experts Conclusion v. 01 How was the situation (concerning points 2 + 8) at the first endorsement? Indufor Response v.1.0 The Consultant could not define to what matter the question presented by Mr. Hans Köpp is related. Indufor Action No action

Issue 4 Constituencies of the Steering Group Panel of Experts Conclusion v. 01 Steering group: a specification of the constituency is missing (ENGOs: national, regional or local level?, participation during the process as compared with first endorsement…) Indufor Response v.1.0 The Scheme Chapter 6.3 states: The following is the structure of the steering group and the maximum representation for each of the 13 constituencies: Chair and Secretary (2), Woodland owners (6), Forest managers (5), State forestry representation (4), Environmental organisations (6), Forest users (2), Wood processing interests (3), Wood products industry (2), Forest workforce (2), Countryside agencies (2), Local government (2), Standard setting bodies (3), Other (1) and Unallocated (1). (PEFC UK Ltd holds the current unallocated position). The Consultant does not see the need for further specification of the constituencies. The broadness of the representation is considered efficiently wide and in consistency with the Chapter 3.4.1. requirements of PEFC TD Annex 2. The comparison with the original endorsement is not in the scope of the assessment. Indufor Action No action

Issue 5 Transparency of the documentation required by the scheme Panel of Experts Conclusion v. 01 Transparency of documentation (conclusion 4, p. 9) should be strengthened

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Annex 6 Indufor Response v.1.0 The Conclusion 4 of the assessment report states: Documentation of the Scheme (Standard setting process document) appropriately requires to communicate the information of the standards setting process to the public (B3), however the Articles of Association or the Steering Group Rules as standard setting documents do not require transparent documentation. The peer reviewers comment does not provide any justification how the Consultant’s assessment should be different and why? Indufor Action No action

Issue 6 Appeal mechanism Panel of Experts Conclusion v. 01 Conclusion 7 (practice), p.10, needs specification / clarification Indufor Response v.1.0 The Conclusion 7 Practice of the Consultant’s report states: Substantive or procedural complaints related to the standard setting are considered and determined by the Steering Group. Appeals against Steering Group decisions are addressed to the Interpretation panel, which acts as a final stage of the appeal process. The independent chairman chairs the panel and the members of the panel equally represent social, economic and environmental interests. The conclusion is based on the description of the required process given by the scheme in Description of the standard setting document Chapter C5. Indufor Action No action

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