New EU Regulations that affect you

(This posting by courtesy of A. Wood)

Like it or not, our country’s membership of the European Union (EU) has a way of influencing almost everything we do.

A couple of new EU regulations collectively know as the EU Timber Regulations (EUTR), have started to send ripples of concern through UK companies who trade in or use materials which have their origins in forests. Paper and board can be traced back through pulp to the forests which grew the trees, so this affects you.
The UK Government has added EUTR requirements to our burden of red tape through a new statutory instrument (2013 No. 233) entitled “The Timber and Timber Products (Placing on the Market) Regulations 2013.

This contains a number of new offences for failing to comply with the following:

a) Article 4 (1) of the Timber Regulation (prohibition on placing illegally harvested timber on the market);
(b) Article 4 (2) of the Timber Regulation (obligation to exercise due diligence);
(c) Article 4 (3) of the Timber Regulation (obligation to maintain and evaluate due diligence system);
(d) Article 5 of the Timber Regulation (traceability obligation);
(e) Article 5 (1) of the Implementing Regulation (record-keeping obligation);
(f) Regulation 10 (obstruction of an inspector); or
(g) A notice of remedial actions.

These regulations place particular pressure on companies bringing timber or materials containing forest products into our country from outside the EU, paper companies and merchants for example. The regulations also have implications for companies using these materials.

Government powers available to deal with failure to comply with these requirements include: remedial action, seizure of material, fines and imprisonment.
In order to protect your company from prosecution, you must be able to demonstrate that you have assessed the risks associated with your supply chain, have exercised due diligence in the procurement of materials and have records to support these actions.
Those members of the forum who are also members of The Group Scheme will have a Chain of Custody manual, policy, procedures and records already go a long way towards demonstrating compliance. Our documentation is being updated to provide better protection. Updates will be rolled out in the New Year.

If you are not a member of our FSC Group Scheme and would like to know more, please contact me for more information.

There was an interesting article about this in Printweek, Which can be read at
this link (you may need to register).
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Why FSC?

Business Momentum can provide highly cost effective training in FSC® Chain of Custody, allowing you to achieve rapid implementation of practical and simple systems in order to meet the requirements of the FSC Chain of Custody standard. The process is quick and easy, using ready-made templates to set up the system, hence minimising costs. Only those organisations that have FSC chain of custody certification can legally use FSC labelling on their products.

Why FSC?
Increasingly, printers are being asked by their clients to secure responsibly sourced materials and, more specifically, paper and timber which is Forest Stewardship Council® certified. Whilst anyone can claim to purchase FSC certified paper, only those printers that operate within an FSC certified chain of custody can actually verify this to their customers.

FSC certification helps small and medium sized print businesses to:
  • take the first step for an environmental accreditation
  • win business
  • to comply with tender criteria and legislation for the environment. It is now becoming more and more essential for business to achieve the FSC Chain of Custody standard

Paul Stokes, of Business Momentum, is also a director of The Group Scheme, the UK's fastest growing FSC Chain of Custody group scheme for the Paper, Publishing and Print sectors. Membership of The Group Scheme is open to print related businesses with 15 or fewer employees. Fees for membership of the group scheme are available on request.

Who are FSC?
FSC is an international, non-governmental organisation dedicated to promoting responsible management of the world’s forests. It was founded in 1993 in response to public concern about deforestation and demand for a trustworthy wood-labelling scheme. There are national working groups in more than 50 countries including the UK. FSC UK is a registered charity. It is supported by NGOs including WWF, Greenpeace and the Woodland Trust.
FSC is not responsible for the content of any training offered by Business Momentum
Where companies fall outside the Group Scheme criteria above, Business Momentum can prepare them for compliance with the standard, and can arrange for assessment via an FSC accredited certification body.

To download our membership information pack, click here.
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FAQ: FSC Certification

“What is a ‘Chain of Custody’?”
The FSC® define this as ‘the path taken by raw materials, processed materials or finished products from the forest to the consumer including each stage of transformation, manufacturing, storage and transport where progress to the next stage involves a change of ownership of the materials or products’. So a chain of custody is essentially an audit trail, all the way from the forest to (in our case) the printed product. Each link in the chain needs to be certified so that it can be audited on behalf of the FSC.

“Are there any benefits to my business?”
FSC Certification can help your business to:
  • Win business
  • Retain existing customers
  • Comply with tender criteria and legislation for the environment
  • Take the first steps for an environmental certification
  • Discriminate your business from the competition
  • Establish credibility in an increasingly competitive and environmentally aware market

“How much does FSC certification cost?”
Printers with more than 15 employees will need individual certification. The cost of this will be from about £1,300 per year but will vary according to the size of the operation. If a print site has 15 employees or fewer, membership of an FSC group scheme can cost as little as £670.00 + VAT per year.

“What are the reasons for certification?”
I often ask my customers why they’ve gone in for FSC certification. The most common answers are:
“A large customer required it”
“It’s a less costly way to add some credibility to our letterhead/website/business than an ISO or more exacting standard”
“It may help us to win business with bigger clients”
“We work with a print manager that was putting FSC jobs elsewhere. Being certified has gained much more work from that customer - most of which is non-FSC”
I have yet to hear anyone say they did it for the environment.

“Which is better, FSC or recycled?”
FSC Mix or FSC 100% material categories are made from pulp from well managed forests. As more trees are planted more carbon dioxide is absorbed. This makes the use of paper environmentally friendly. Wood is a renewable resource; when forests are well managed, with consideration for the environment, the wildlife and the people who live and work in them, harvesting timber can actually be an effective way of safeguarding the forests for future generations. Choosing products sourced from these well-managed forests and from recycled post-consumer waste allows businesses and consumers to support the world‘s forests. Products carrying the FSC Recycled label have been made from at least 85% post consumer waste. Other recycling standards may not be as rigorous having as little as 25% recycled content.

“How difficult is it to manage chain of custody in my business?”
Not difficult at all. Any modern MIS can be configured to insert FSC claim information into job descriptions (on job sheets, delivery notes and invoices etc.), when claims are made, and produce the required annual reports. Once certified you can make claims on as many, or as few jobs as you like.

“If the paper is FSC Certified, why does the printer need to be as well?”
FSC has produced standards which
  • Make sure that FSC wood is accounted for as it passes along the supply chain
  • Make sure that when FSC wood is mixed with other wood, this does not come from undesirable sources (see FSC Con- trolled Wood)
  • Make sure that recycled/reclaimed material is acceptable (see Recycled Material)
  • Enables FSC certified products to be produced or stocked as well as uncertified products
  • Provide a range of labeling options
It is only by becoming part of a certified chain of custody that a printer can make FSC claims and apply FSC labels it’s products.

“If one member of The Group Scheme fails an audit, does it affect the rest of the group?”
The answer is… No.
The Group Scheme could only fail if the certification body identified several members failing (i.e. systematic rather than isolated issues). We manage the members to pre-empt that. If a member consistently failed to correct issues identified we would suspend their membership.


“Why would my customers want me to be FSC certified?”
It is a very cost-effective way for them to demonstrate their commitment to the environment. FSC have been very effective in communicating their message to government, big business, and the public, so businesses see a benefit to their brands in being able to say that their suppliers are FSC-certified, or to buy FSC certified products and have the FSC trademarks appear on them. 
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How can FSC certification form part of your marketing plan?

How can FSC certification form part of your marketing plan?

The FSC Standard is a Chain of Custody Standard. Put simply, this means that to maintain the standard, all you need to do is to ensure that any product that an FSC claim is made for has it’s transit through your workflow recorded, and that that record is kept and maintained in a way that can be inspected and analysed when required. A correctly set up MIS will do most of that for you. It will also facilitate reporting. In PrintSmith, for example, it is possible to report on the stock used and the product descriptions applied to any jobs that are invoiced or estimated.

It is well known that marketing to existing customers is more cost effective than searching for new customers - using reports from your MIS is probably the easiest way to manage it. Your MIS should be able to produce a report either as a document or as an export file for further analysis or variable data use.

So what might your marketing message be? FSC Certification helps your marketing message in four main ways:

  • It shows a commitment to The Environment .
  • It conveys an impression of good management practices.
  • It discriminates us from the competition.
  • It projects an image of corporate responsibility.

FSC is a market based initiative that is being progressively adopted by printers, and their customers. Increasing market pressure will soon make certification an essential part of every printers marketing message.
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About FSC certification

I am now a director of The Group Scheme Ltd. The Group Scheme is an FSC chain of custody scheme for printers and print related businesses.
The Group Scheme operates an FSC Group Chain of Custody Scheme. It has been set up so that smaller businesses can have access to FSC Chain of Custody in an affordable way.

Membership of this The Group Scheme is open to businesses that have fewer than 15 employees. However, for larger businesses assessment can be arranged via BMTRADA certifications.
A monthly payment scheme is available, which helps to make membership of The Group Scheme attainable for even the smallest business.
Cost effective training in the Chain of Custody standard is provided using qualified print-sector specialists utilising a ready- made template which minimises costs.
The costs
The initial training and pre-assessment costs approximately £800, with the annual assessment at £670 per business site.
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