Four regulations. FSC Non-Conformance. Eleven suppliers. Certification & Compliance Achieved
How we closed every FSC non-conformance, strengthened UKTR and EUTR due diligence, and got a UK paper and board supplier ready for EUDR, in under three months.
CSR Consultants helped a UK paper and board supplier close every FSC non-conformance and retain its FSC certification in under three months. The project covered timber due diligence across 11 major suppliers under the UK Timber Regulations (UKTR), the EU Timber Regulation (EUTR) and FSC Chain of Custody requirements, alongside preparation for the EU Deforestation Regulation (EUDR).
The Challenge
The business buys finished paper and board from FSC-certified mills. It does not import timber directly.
Its FSC audit had raised non-conformances. At the heart of them was a risk assessment that leaned too heavily on supplier certificates to conclude “low risk”.
Several suppliers used plantation fibre from regions where conversion of natural forest is a recognised risk. Some had not provided full origin data.
The team had also begun EUDR work internally and needed its UKTR and EUTR position tightened at the same time.
Why it Mattered
For many packaging and print buyers, FSC claims are a condition of sale.
Leave non-conformances open and the certificate can be suspended. Lose the certificate and you lose the right to sell FSC-claimed product — and the customers who require it. This was very much the situation with our clients.
What's more, your weak records also make it harder to answer customer and regulator questions with confidence. All of this has a very quick negative impact on your bottom line.
What We Did
1. Researched 11 major suppliers. Country of harvest, species, supply chain complexity and certification status for each. Where a supplier held back information, engagement attempts were documented and objective evidence used in its place.
2. Rebuilt the risk methodology. One consistent approach across every supplier, based on FSC National Risk Assessments at country, species and supplier level. Conversion risk was classified correctly where it applied — not assumed away by a certificate.
3. Put controls in place. FSC claims verified at invoice level against the public FSC certificate database. Controlled Wood accepted only from certified operators with audited systems. Clear review triggers: annually, and whenever a supplier, product, origin or certificate changes.
4. Prepared the team for the auditor. A pre-emptive auditor Q&A covering the hard questions, from plantation risk to suppliers with incomplete data. The team could explain its system clearly and consistently.
5. Delivered the complete due diligence pack. Supplier risk assessments, species and origin records, and an evidence set ready for audit.
The Outcome
• Every FSC non-conformance closed.
• FSC certification retained.
• A consistent, defensible due diligence system across 11 major suppliers.
• Delivered in under three months.
The system does not pretend risk is zero. It shows risk is identified and controlled. That is what auditors want to see.
An FSC certificate is evidence. It is not a risk assessment.
"Jacqui offered a well-informed and helpful approach which we quickly realised was exactly what we required for our own compliance – needless to say, we had Jacqui signed up within the week! She's been and continues to be incredibly helpful, keeping us updated with changes even after the initial project was completed."
Discuss your due diligence requirements
Facing FSC non-conformances, a UKTR review or EUDR preparation?
Tell us about your products, suppliers and deadlines. We will scope a review and agree the support your business needs. Email info@csrconsultants.co.uk
FAQ's
What is an FSC non-conformance?
A finding by a certification body that a business isn't meeting part of the FSC standard. If it isn't closed within the required timeline, the certificate can be suspended.
Is FSC certification enough to show low risk under UKTR?
No. Certification is evidence that helps reduce risk. It is not a risk assessment. Risk still needs assessing by country, species and supplier.
What is conversion risk (CW4)?
It's the risk that wood comes from natural forest being converted to plantation or other use. FSC classifies it as a specified risk in some sourcing regions.
How long does it take to close FSC non-conformances?
It depends on scope. In this case, every non-conformance across 11 major suppliers was closed in under three months.
Does EUDR replace EUTR?
Yes. EUDR repeals EUTR once it applies, and EUTR continues to apply until then.
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