Public Notification Letter FSC® Chain of Custody ... · FSC® Chain of Custody Controlled Wood...

Version 1-0 (January 2017) | © SCS Global Services of 2

Public Notification Letter

FSC® Chain of Custody Controlled Wood Stakeholder Consultation To: Interested Parties

From: SCS Global Services

Consultation period: 30-January 2017 to 13-March 2017

Re: Notification of intent to audit Sonoco Products Company (Hartsville, SC) against FSC Chain of Custody Controlled Wood standard FSC-STD-40-005 V3-0

The Forest Stewardship Council® (FSC) requires that a certification body conducting an audit of a certified organization or applicant must consult stakeholders whenever the audit includes intent to source and use uncertified material in an FSC Chain of Custody (CoC) program according to the requirements in FSC-STD-40-005 V3-0 “Requirements for Sourcing FSC Controlled Wood”. Therefore, SCS Global Services (SCS) is seeking input from interested and directly affected stakeholders regarding the relevance, effectiveness, and/or adequacy of Sonoco Products Company’s Due Diligence System (DDS).

An explanation of ‘FSC Controlled Wood’, as well as a copy of FSC-STD-40-005 V3-0, is available here: https://ic.fsc.org/en/certification/types-of-certification/controlled-wood-02 ; a copy of this standard is also available from SCS upon request. Due Diligence Systems are required for certified organizations in order to avoid the sourcing and use of material originating from unacceptable sources in their FSC CoC program.

Directly affected stakeholders include any person, group of persons, or entity that is, with high probability, subject to the effects of the activities related to an organization’s controlled wood sourcing program, including the activities of their suppliers and sub-suppliers, as well as those who influence risk identified through the organization’s Due Diligence System.

This letter serves as SCS’ invitation to directly affected stakeholders to participate in our consultation process. This letter also serves as SCS’ public notification for any interested stakeholders, who are also invited to participate in the consultation process. Participation in this stakeholder consultation process is voluntary; stakeholders are not required to submit comments. Scope of audit and audit details: The audit will assess the conformity of the organization’s controlled wood program – including Risk Assessment(s) and DDS – according to the certification requirements as per FSC-STD-40-005 V3-0. The company’s DDS Public Summary and Risk Assessment (excluding confidential information), as well as any other information or documents deemed relevant for the purpose of this stakeholder consultation, are included as appendices to this letter—see below. For a list of the information that is required to be publically available for stakeholder consultation by SCS, see FSC-STD-40-005 V3-0, Section 6. The audit will take place beginning March 13, 2017, at the company’s facility located at: 1 North Second Street, Hartsville, SC 29550

2000 Powell Street, Ste. 600 Emeryville, CA 94608 USA +1.510.452.8000 main +1.510.452.8001 fax

https://ic.fsc.org/en/certification/types-of-certification/controlled-wood-02

Version 1-0 (January 2017) | © SCS Global Services of 2

Additional certificate holder information: n/a, this applicant is not yet certified Options for participation and provision of comments: Please submit written comments and evidence (where appropriate) by mail, FAX or email to SCS: SCS Global Services Att’n: Julian Eldridge, Chain of Custody Certification Services 2000 Powell Street, Suite 600 Emeryville, CA 94608 Fax: 510-452-6882 Email: [email protected] A summary of the stakeholder consultation and comments received will be made publically available on the FSC certificate database, as per FSC-STD-20-011 V4-0. Verbatim comments will only by published with prior consent from the stakeholder and will not be associated with stakeholder names. Note that, while SCS is required to evaluate all information and comments objectively, SCS certification decisions are affected by stakeholder comments only insofar as the comments provide evidence of conformity or nonconformity to the applicable requirements. Within 30 days of making our certification decision, SCS will respond to all stakeholders who provided comments to explain how their comments were taken into account. More information about FSC and SCS can be found on our respective websites: www.fsc.org and www.scsglobalservices.com.

mailto:[email protected]

http://www.fsc.org/

http://www.scsglobalservices.com/

http://www.scsglobalservices.com/

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Summary of the FSC Controlled Wood & Due Diligence System Procedure

Document Owner: Global Sustainable Packaging Manager Document #: SPC-DP-10bsum Last Revised:

1/13/17 Page 1 of 3

This document is confidential and proprietary. Unauthorized use is prohibited.

Summary of DDS for Public Distribution This information will be included in the public summary of the certification report by the certification body on the FSC database. According to FSC STD-40-005 V3.1, Section 6 Publically available information: 6.1 The organization shall provide a written summary of its DDS to the certification body. The written summary shall include the following information: a) A description of the supply area(s) and respective risk designation(s); b) Reference to the applicable FSC risk assessment; c) The organization’s own risk assessment (excluding confidential information); d) The procedure for filing complaints; and e) Contact information of the person or position responsible for addressing complaints.

Program Scope Sonoco Products Company is implementing this Documented Procedure to achieve conformance with the Forest Stewardship Council® (FSC®) Standard for Company Evaluation of Controlled Wood in order to avoid material from unacceptable sources. This Documented Procedure is part of the Chain of Custody and Controlled Wood program addressing the corrugating paper portion of its Hartsville, South Carolina paper manufacturing facility. The virgin fiber, including hardwood pulpwood and residual chips, is covered here, and reclaimed/recycled material is not. Henceforth the fiber within scope will be called forest fiber.

Supply Area and Risk Designations All forest fiber sources are from within the U.S. States of North and South Carolina, 5 counties in Georgia (Franklin, Banks, Hart, Madison, and Stephens), and the southern portion of Virginia (south of the James River and east/south of Interstate 81; areas north of the James River or west of Interstate 81 are generally not included except the western tip of Virginia; see map). Within this supply area all sources were found to be low risk for the five unacceptable sources of wood:

1. Wood harvested illegally. 2. Wood harvested in violation of traditional and civil rights. 3. Wood harvested from forests with a high conservation value that is threatened by

management activities. 4. Wood harvested from forests being converted to plantations* or non-forest use. 5. Wood from forests in which genetically modified trees are planted.

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Further, Sonoco Products Company has identified all of its wood suppliers and their incoming material as coming from either “Certified” or “controlled material” sources. The Procurement Staff has notified all of its suppliers that it will not accept “uncontrolled/controversial” sources of wood. It has incorporated the controlled wood restrictions in its supplier agreements.

FSC Risk Assessment The US has a national risk assessment process which found “low risk” for Categories 1 and 5. Determinations for Categories 2, 3, and 4 within the framework of the FSC Risk Assessment are still underway (Centralized National Risk Assessment for The United States of America FSC-CNRA-USA V1-0 EN.) Changes to the revised controlled wood system decided at the July 2016 meeting of the FSC’s International Board of Directors include deciding that “where a national risk assessment process is taking place, companies will be able to use part of the assessment that was agreed through national consensus, even when only some, but not all, categories of the national risk assessment are nationally concluded”. (Source: FSC website “Newsroom” release Monday, 14 November 2016: “Controlled Wood Standard Amendments” https://ic.fsc.org/en/news/id/1703.) As such Category 1 “Illegally Harvested Wood” and Category 5 “Wood from forests in which genetically modified trees are planted” are designated “Low Risk”

Sonoco Risk Assessment Summary Refer to Document # SPC-DP-16b, Appendix E: FSC Controlled Wood Risk Assessment Summary.

Procedure for Filing Complaints, Including Contact Person Complaints regarding the Sonoco Products Company Due Diligence System and/or Risk Assessment should be directed to the company’s Central Office Management Representative: Ms. Laura Rowell, Global Sustainable Packaging Manager, Sonoco Product Company, 1 North 2nd Street, Hartsville, SC 29550 Phone # (843) 383-3276 E-mail: [email protected] Complaints must be in writing and sent by email. Sonoco will acknowledge the complaint as soon as practical, and will provide an initial response to the complaint within two weeks. Any complaints regarding the FSC Risk Assessments will be forwarded to the appropriate FSC office. Sonoco Products Company will assess the complaint and determine whether it is substantial. If so, the precautionary principle will be employed and Sonoco Products Company will also attempt to resolve the complaint directly with the person or organization that filed it. If the complaint can’t be resolved this way then the company will notify the FSC US National Office and the certification body and move to verification. The company will conduct field or office verification within two months. If the results of verification show that control measures are needed these will be implemented by the supplier and verified before any affected material is included in the Controlled Wood program.

mailto:[email protected]

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Sonoco Products Company will inform the complainant, the certification body, and the relevant FSC National Office of the results of the complaint and any actions taken towards its resolution. Sonoco Products Company’s Central Office Management Representative is responsible for maintaining copies of relevant correspondence; and recording and filing all complaints received and actions taken.

Document Name:

Summary of the Sonoco FSC Controlled Wood Risk Assessment

Document Owner: Global Sustainable Packaging Manager

Document # SPC-DP-16bsum

Last Revised: 01/13/17

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FSC Controlled Wood Risk Assessment Hartsville #10 (Corrugated) Sonoco Products Company

Purpose The purpose of the Controlled Wood Risk Assessment is to assess the risk of sourcing wood and fiber from any of the “Unacceptable” sources as defined by the Forest Stewardship Council® (FSC®) Chain of Custody and Controlled Wood Standards. This Risk Assessment is constructed using the FSC framework and definitions, and is separate from, but similar in many ways to, Risk Assessments prepared for the company to address other certification standards. Executive Summary The FSC Controlled Wood Standard (FSC-STD-40-005 V. 3-0) is designed to allow companies to avoid trading in illegally harvested wood, wood harvested in violation of traditional and civil rights, wood harvested in forests where high conservation values are threatened by management activities, wood harvested in forests undergoing significant conversion to plantations or non-forest use, and wood from forests in which genetically modified trees are planted. The risk assessment found that there is low risk for all five categories. Sonoco Products Company’s Wood Procurement Managers/designees are responsible for periodically accessing the FSC websites contained in Annex 2 of FSC-STD-40-005 (V3-0) and comparing Sonoco Products Company’s wood and fiber supply areas and Eco-regions against any published and known areas of concern. The specific states and counties where softwood fiber is sourced are attached in Appendix A. All non- certified wood and fiber for the Sonoco Products Company manufacturing facilities currently originates from the States contained in Appendix A. All wood and fiber currently originates from the portions of the states of South Carolina and North Carolina, Georgia, and Virginia which are within these TNC Ecoregions of the US: (51) Southern Blue Ridge, (52) Piedmont, (56) South Atlantic Coastal Plain and (57) Mid-Atlantic Coastal Plain. The Nature Conservancy map of U.S. Eco-regions is contained in Appendix B. All tree species that are sourced into the manufacturing facilities are native to the supply regions. This demonstrates that there are no CITES listed species or wood fiber originating from outside of North America. The tree species that would mostly commonly be sourced are attached in Appendix C. None of the sourced species are CITES listed as “Endangered.”

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The relevant sections of the FSC Controlled Wood Due Diligence System Standards are assessed in detail in the Controlled Wood Risk Assessment. The Assessment is also consistent with FSC Directives on Controlled Wood (FSC-DIR-40-005) and specifically Advice 14. An FSC produced List of U.S. Laws and Regulations is contained in Appendix D as required by FSC-Advice-40-004-19. It is a minimum list of applicable laws at the national level in the US, and it is not intended to be a comprehensive list of all laws pertaining to forest management in the United States. This list may be used in order to satisfy the requirements of ADVICE-40-005-19 until a more complete list is posted on the FSC Global Forest Registry. Based upon the various risk assessments that have been conducted involving a review of all relevant websites, the sub-scope of only hardwood species, assessment of the Eco-regions and the wood supply areas of Sonoco Products Company’s manufacturing facility in Hartsville, South Carolina, as well as the overall supply chain, all sources of non-certified supply are considered “Low Risk.” Therefore, no further verification monitoring or review is necessary. All wood and fiber material coming into Sonoco Products Company is considered “controlled material” and can be mixed with FSC certified and non-controversial material. This assessment also demonstrates that all wood and fiber inputs are “Negligible Risk” of coming from illegal sources under the European Union Timber Regulation (EUTR). This Executive Summary can be provided to “Operators” in the EU as objective evidence of legality. A finding that wood from the hardwood regions of the U.S. is “low risk” of originating from FSC “Uncontrolled” sources or SFI Controversial sources is further reinforced by the report from the American Hardwood Export Council (AHEC) entitled: “Assessment of Lawful Harvesting & Sustainability of US Hardwood Exports” and available at: http://www.ahec-europe.org/. The report addresses the hardwood Eco-regions and was co-authored by FSC US consultants Dr. Gary Dodge and Phil Guillery. In addition, Dr. Gary Dodge was recently employed by FSC US and is a national authority on FSC Controlled Wood. The AHEC report finds that:

“We can conclude that hardwood procured from anywhere in the Hardwood States could be considered Low Risk in all five risk categories of the standard. Minor and occasional instances contrary to this finding are present in one or more of the risk categories, and where they do occur, they should be further evaluated by companies procuring wood in those areas. However, we determine the level to be within the threshold for being low risk through our interpretation of the FSC standard and its requirements.

A Controlled Wood Risk Assessment Summary addressing FSC-STD-40-005 V3-0 “6 Publically available information” is included in Appendix E.

http://www.ahec-europe.org/

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Note: The US has a national risk assessment process which found “low risk” for FSC Categories 1 and 5 (Global Registry: http://www.globalforestregistry.org/NEW/map/). Determinations for Categories 2, 3, and 4 are still underway (Centralized National Risk Assessment for The United States of America FSC-CNRA-USA V1-0 EN.) Changes to the revised controlled wood system decided at the July 2016 meeting of the FSC’s International Board of Directors include deciding that “where a national risk assessment process is taking place, companies will be able to use part of the assessment that was agreed through national consensus, even when only some, but not all, categories of the national risk assessment are nationally concluded”. (Source: FSC website “Newsroom” release Monday, 14 November 2016: “Controlled Wood Standard Amendments” https://ic.fsc.org/en/news/id/1703 .) Despite the above Sonoco Products Company has independently assessed FSC Categories 1 and 5 found “low risk” for these categories, supporting the US NRA process.

http://www.globalforestregistry.org/NEW/map/

https://ic.fsc.org/en/news/id/1703

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Appendix A Districts of Origin (States and Counties)

Sonoco Products Company identified its supply areas through its Wood Purchase Agreements. Each load of non-certified wood delivered to the Company’s facility can be tracked back to the state and county and the individual landowner. Records of mill residual sources are available from those suppliers if needed. All wood material originates from the states and counties contained in the following list South Carolina All counties North Carolina All counties Georgia Franklin Banks Hart Madison Stephens Virginia Amelia Appomattox Bedford Bland Bristol Brunswick Buchanan Buckingham Campbell Carroll Charlotte Chesapeake Chesterfield Cumberland Dinwiddie Floyd Franklin Galax Giles Grayson Greenville Halifax Henry Isle of Wight Lunenburg Lynchburg Martinsville Mecklenburg Montgomery Nottoway Patrice Pittsylvania Powhatan Pulaski Radford Roanoke Roanoke City Russell Smyth Southampton Suffolk Sussex Tazewell Virginia Beach Washington Wythe

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Appendix B The Nature Conservancy Eco-regions of the U.S.

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Appendix C

Tree Species Sourced by Sonoco Products Company (Common & Scientific Names)

Tree species in Virginia, Georgia, North and South Carolina potentially found in Sonoco Products Company products.

Common Name Scientific Name Florida Maple Acer barbatum Chalk Maple Acer leucoderme Boxelder Acer negundo Black Maple Acer nigrum Norway Maple Acer platanoides Red Maple Acer rubrum Silver Maple Acer saccharinum Sugar Maple Acer saccharum Mountain Maple Acer spicatum Yellow Buckeye Aesculus flava Ohio Buckeye Aesculus glabra Ailanthus Ailanthus altissima Mimosa, Silktree Albizia julibrissin Pawpaw Asimina triloba Sweet Birch Betula lenta River Birch Betula nigra American Hornbeam, Musclewood Carpinus caroliniana Mockernut Hickory Carya alba Water Hickory Carya aquatica Southern Shagbark Hickory Carya carolinae-septentrionalis Bitternut Hickory Carya cordiformis Pignut Hickory Carya glabra Pecan Carya illinoinensis Shellbark Hickory Carya laciniosa Red Hickory Carya ovalis Shagbark Hickory Carya ovata Sand Hickory Carya pallida Black Hickory Carya texana Chinese Chestnut Castanea mollissima Allegheny Chinkapin Castanea pumila Southern Catalpa Catalpa bignonioides Sugarberry Celtis laevigata Hackberry Celtis occidentalis Eastern Redbud Cercis canadensis

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Sonoco Products Company Species List (cont.)

Common Name Scientific Name

Common Persimmon Diospyros virginiana American Beech Fagus grandifolia White Ash Fraxinus americana Carolina Ash Fraxinus caroliniana Oregon Ash Fraxinus latifolia Black Ash Fraxinus nigra Green Ash Fraxinus pennsylvanica Pumpkin Ash Fraxinus profunda Blue Ash Fraxinus quadrangulata

Waterlocust Gleditsia aquatica Honeylocust Gleditsia triacanthos Loblolly-bay Gordonia lasianthus American Holly liex opaca Black Walnut Juglans nigra Sweetgum Liquidambar styraciflua Yellow-poplar Liriodendron tulipifera Osage-orange Maclura pomifera Cucumbertree Magnolia acuminata Mountain or Fraser Magnolia Magnolia fraseri Southern Magnolia Magnolia grandiflora Bigleaf Magnolia Magnolia macrophylla Umbrella Magnolia Magnolia tripetala Sweetbay Magnolia virginiana Apple spp. Malus spp. Chinaberry Melia azedarach White Mulberry Morus alba Red Mulberry Morus rubra Water Tupelo Nyssa aquatica Swamp Tupelo Nyssa biflora Blackgum Nyssa sylvatica Eastern Hophornbeam Ostrya virginiana Sourwood Oxydendrum arboreum Paulownia, Empress-tree Paulownia tomentosa Redbay Persea borbonia Sand Pine Pinus clausa Shortleaf Pine Pinus echinata Slash Pine Pinus elliottii Spruce Pine Pinus glabra

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Common Name Scientific Name Longleaf Pine Pinus palustris Table Mountain Pine Pinus pungens Pitch Pine Pinus rigida Pond Pine Pinus serotina Eastern White Pine Pinus strobus Loblolly Pine Pinus taeda Virginia Pine Pinus virginiana Water-elm, Planertree Planera aquatica American Sycamore Platanus occidentalis Balsam Poplar Populus balsamifera Eastern Cottonwood Populus deltoides Bigtooth Aspen Populus grandidentata Swamp Cottonwood Populus heterophylla American Plum Prunus americana Pin Cherry Prunus pensylvanica Black Cherry Prunus serotina Chokecherry Prunus virginiana White Oak Quercus alba Nuttall Oak Quercus buckleyi Scarlet Oak Quercus coccinea Southern Red Oak Quercus falcata Scrub Oak Quercus ilicifolia Shingle Oak Quercus imbricaria Bluejack Oak Quercus incana California Black Oak Quercus kelloggii Turkey Oak Quercus laevis Laurel Oak Quercus laurifolia Overcup Oak Quercus lyrata Bur Oak Quercus macrocarpa Dwarf Post Oak Quercus margarettiae Blackjack Oak Quercus marilandica Swamp Chestnut Oak Quercus michauxii Chinkapin Oak Quercus muehlenbergii Water Oak Quercus nigra Cherrybark Oak Quercus pagoda Pin Oak Quercus palustris Willow Oak Quercus phellos

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Common Name Scientific Name Chestnut Oak Quercus prinus Northern Red Oak Quercus rubra Shumard Oak Quercus shumardii Post Oak Quercus stellata Black Oak Quercus velutina Black Locust Robinia pseudoacacia Coastal Plain Willow Salix caroliniana Black Willow Salix nigra Sassafras Sassafras albidum American Mountain-ash Sorbus americana American Basswood Tilia americana Carolina Basswood Tilia americana var caroliniana White Basswood Tilia americana var heterophylla Chinese Tallowtree Triadica sebifera Eastern Hemlock Tsuga canadensis Winged Elm Ulmus alata American Elm Ulmus americana Cedar Elm Ulmus crassifolia Siberian Elm Ulmus pumila Slippery Elm Ulmus rubra September Elm Ulmus serotina Rock Elm Ulmus thomasii

*Species list developed from USFS FIA plot data.

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FSC Controlled Wood Risk Assessment Document Owner: Procurement Staff Document # HP-COC-16 Last Revised: 7/15/16 Page 10 of 14


Appendix D FSC Controlled Wood Risk Assessment Summary

Certificate holder: Sonoco Products Company Certification Body (CB): SCS Global Services

FSC CW certificate code: Insert Date of CB approval: Insert

Date of risk assessment: December 27, 2016 Address of CB: SCS Global Services 2000 Powell Street, Suite 600 Emeryville, CA. 94608

Certificate holder address: Hartsville, South Carolina Title: FSC Controlled Wood Risk Assessment Summary for Sonoco Products Company

Eco-regions covered by this risk assessment*: (51) Southern Blue Ridge, (52) Piedmont, (56) South Atlantic Coastal Plain, and (57) Mid-Atlantic Coastal Plain

Risk

Finding 1. Illegally Harvested Wood The district of origin may be considered low risk in relation to illegal harvesting when all the following indicators related to forest governance are present:

1.1 Evidence of enforcement of logging related laws in the district

1. www.illegal-logging.org 2. www.eia-international.org 3. American Hardwood Export Council (AHEC) Legality Study: (An Assessment of Risk: Legality & Sustainability of US Hardwood Exports) http://www.ahec-europe.org/

1.There is nothing on the web site affecting Sonoco Products Company’s fiber supply area. Illegal harvesting in Papua New Guinea is the focus of this website.

2. The focus of this web site is on the trading of illegal wood. The wood and fiber supply area is not included. 3. There is strong evidence of active law enforcement within the districts of origin. Law enforcement in the U.S. is among the most effective in the world.

Low Risk

1.2 There is evidence in the district demonstrating the legality of harvests and wood purchases that includes robust and effective systems for granting licenses and harvest permits.

1. www.dfid.gov.uk 2.http://ec.europa.eu/development/index_en.cfm

1. This site addresses efforts of the British Government to fight worldwide poverty. Their efforts do not include the U.S. 2. The European Union is developing a licensing scheme for wood coming into

Low Risk

http://www.illegal-logging.org/

http://www.eia-international.org/


http://www.dfid.gov.uk/

http://ec.europa.eu/development/index_en.cfm

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3. The Lacey Act

the EU and proposes to cooperate with the U.S. to thwart the trade in illegally harvested timber. 3. The U.S. has passed comprehensive legislation to prevent illegal logging

1.3 There is little or no evidence or reporting of illegal harvesting in the district of origin.

1. www.eldis.org 2. www.globalwitness.org 3. www.panda.org

1. None of the regions of the world where illegal logging is occurring and causing problems are associated with Sonoco Products Company’s wood and fiber supply areas. 2. This site addresses illegal logging in the developing nations of the Pacific Rim, Africa, and South America. No issues were identified for Sonoco Products Company’s wood and fiber supply areas. 3. The World Wildlife Fund web site addresses illegal logging. No instances of illegal logging in the U.S. were cited.

Low Risk

1.4 There is a low perception of corruption related to the granting or issuing of harvesting permits and other areas of law enforcement related to harvesting and wood trade.

1. www.transparency.org 2. AHEC Legality Study http://www.ahec-europe.org/

1. This site addresses corruption, bribery and other illegal activities. No issues were identified addressing forestry and wood procurement where the company procures wood. 2. “We come to the conclusion that wood procured in the study area can be considered Low Risk to threat to legality. This conclusion is based on the determination that there is no reported systematic illegal logging reported in the study area and regulatory processes in the study area have been found to be highly effective.”

Low Risk

2. Wood harvested in violation of traditional or civil rights The district of origin may be considered low risk in

2.1 There is no UN Security Council ban on timber exports from the country concerned;

1.www.un.org/esa/africa/UNNews_Africa/timber.htm 2. AHEC Legality Study http://www.ahec-europe.org/

1.The web sites listed in Annex 2, Section 2, address Africa and Asia and are not relevant to the U.S.

Low Risk

http://www.eldis.org/

http://www.globalwitness.org/

http://www.panda.org/

http://www.transparency.org/


http://www.un.org/esa/africa/UNNews_Africa/timber.htm


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relation to the violation of traditional, civil and collective rights when all the following indicators are present:

2.There are no bans on timber exports from the wood and fiber supply areas.

2.2 The country or district is not designated a source of conflict timber (e.g. USAID Type 1 conflict timber)

1.www.natrualresources.org/mineral/CD/docs/other/N0262179.pdf 2.www.usaif.gov/hum_response/oti/pubs/vol1synth.pdf

1. USAID has not designated the Sonoco Products Company wood and fiber supply area as a source of conflict timber.

Low Risk

2.3 There is no evidence of child labor or violation of ILO Fundamental Principles and Rights at work taking place in forest areas in the district concerned

1. www.fscus.org: FSC-US Guidance on Controlled Wood Sources

1. The U.S. jurisdictions where Sonoco Products Company procures wood material have comprehensive laws prohibiting the use of child labor or violating citizen’s rights.

Low Risk

2.4 There are recognized and equitable process in place to resolve conflicts of substantial magnitude pertaining to traditional rights including use rights, cultural interests or traditional cultural identity in the district concerned

1. www.fscus.org: FSC-US Guidance on Controlling Wood Sources 2. AHEC Legality Study http://www.ahec-europe.org/

1. U.S. Federal and State laws preclude such violations and there are recognized processes in place to resolve conflicts over traditional rights and cultural interests. 2. Wood procured in the study area can be considered Low Risk of violating traditional and civil rights. There are recognized and equitable processes in place to resolve conflicts of substantial magnitude

Low Risk

2.5 There is no evidence of violation of the ILO Convention 169 on Indigenous and Tribal Peoples taking place in the forest areas in the district concerned.

1. www.fscus.org: FSC-US Guidance on Controlled Wood Sources 2. AHEC Legality Study http://www.ahec-europe.org/

1.ILO Fundamental Principles and rights at work are generally respected. 2. There is no evidence that ILO Fundamental Principles are not respected.

Low Risk

3. Wood harvested from forest in which high conservation values are threatened by management activities The district of origin may be considered low risk in relation to threat to high conservation values if: a) indicator 3.1 is met; or b) indicator 3.2 eliminates (or greatly

3.1 Forest management activities in the relevant level (eco-region, sub-eco-region, local) do not threaten eco-regionally significant high conservation values.

1. www.worldwildlife.org/science/ecoregions.cfm 2. AHEC Legality Study http://www.ahec-europe.org/

1. Forest management across the wood and fiber supply area does not threaten eco-regionally significant conservation values. 2. A strong system of forest protection is in place in the U.S.

Low Risk

3.2 A strong system of protection (effective protected areas and legislation) is in place that ensures survival of the HCVs in the ecoregion.

1. www.fscus.org: FSC-US Guidance on Controlled Wood Sources

1. It is unlikely that high conservation values would be threatened and it is not likely that an assessment would be needed for the majority of forests in the U.S.

Low Risk

http://www.natrualresources.org/mineral/CD/docs/other/N0262179.pdf

http://www.usaif.gov/hum_response/oti/pubs/vol1synth.pdf

http://www.fscus.org/





http://www.worldwildlife.org/science/ecoregions.cfm



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mitigates) the threat posed to the district of origin by non-compliance with 3.1.

2. www.biodiv.org/reports/list.aspx?type=for 3. AHEC Legality Study http://www.ahec-europe.org/

2. The level of legislative protection, combined with the levels of compliance with regulations provides strong evidence that logging and the associated activities with logging pose a mitigated threat to HCVF within the study area. 3. “We come to the conclusion that wood procured in the study area can be considered Low Risk of violating traditional and civil rights. This conclusion is based on the determination that there is no UN Security Council ban, there is no evidence of prolific child labor, there is no evidence that ILO Fundamental Principles are not respected, and there are recognized and equitable processes in place to resolve conflicts of substantial magnitude.”

4. Wood harvested from areas being converted from forests and other wooded ecosystems to plantations or non-forest uses The district of origin may be considered low risk in relation to conversion of forest to plantations or non-forest uses when the following indicator is present:

4.1 There is no net loss AND no significant rate of loss (> 0.5% per year)8 of natural forests and other naturally wooded ecosystems such as savannahs taking place in the eco-region in question.

1. U.S. Forest Service Forest Inventory and Analysis Reports 2. United Nations Food and Agriculture Organization's (FAO) State of the World's Forests 2001 Report 3. AHEC Legality Study http://www.ahec-europe.org/

1. The growth of the forests in the States where Sonoco Products Company procures wood generally exceeds withdrawals, thus indicating that there is “no net loss” and no significant rate of loss of forests across the company’s fiber supply area 2. North American forest (U.S. and Canada) cover expanded nearly 10 million acres (4 million hectares) over the last decade. Thus, there is low risk that forested ecosystems in the U.S. are experiencing loss. 3. The remainder of the study area (Sonoco Products Company’s wood and fiber supply area) is determined to be LOW RISK for conversion.”

Low Risk

5. Wood from forests in which genetically

a) There is no commercial use of genetically modified trees of the species

1.http://www.fao.org/docrep/008/ae574e/AE574E00.HTM.

1. Sonoco Products Company did not find its wood and fiber supply areas on

Low Risk

http://www.biodiv.org/reports/list.aspx?type=for



http://www.fao.org/docrep/008/ae574e/AE574E00.HTM

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modified trees are planted The district of origin may be considered low risk in relation to wood from genetically modified trees when one of the following indicators is complied with:

concerned taking place in the country or district concerned

2. AHEC Legality Study http://www.ahec-europe.org/

any lists contained in the FAO preliminary review of biotechnology in forestry 2. “At this time all wood sourced in the U.S. can be considered to not contain wood from GMO trees.”

b) Licenses are required for commercial use of genetically modified trees and there are no licenses for commercial use

1. AHEC Legality Study

1. “At this time all wood sourced in the U.S. can be considered to not contain wood from GMO trees.”

Low Risk

c) It is forbidden to use genetically modified trees commercially in the country concerned

1. AHEC Legality Study

1. “At this time all wood sourced in the U.S. can be considered to not contain wood from GMO trees.”

Low Risk


Public Notification Letter FSC® Chain of Custody ... · FSC® Chain of Custody Controlled Wood...

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