Guidance

Criteria for evaluating forest certification schemes (Category A evidence), 5th edition

Published 27 February 2025

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This publication is available at https://www.gov.uk/government/publications/timber-certification-schemes-category-a-evidence-evaluation-criteria/criteria-for-evaluating-forest-certification-schemes-category-a-evidence-5th-edition

Purpose

The UK government Timber Procurement Policy (TPP) requires that only timber and wood-derived products originating from an independently verifiable legal and sustainable source – which can include from a licensed Forest Law Enforcement, Governance and Trade (FLEGT) partner – will be demanded for use on the government estate. Appropriate documentation will be required to prove the source of these products. 

A number of ways of implementing the procedure in practice have been identified. One of the most straightforward is the purchase of timber from certified sources, provided that the certification scheme involved delivers the government requirements for legality or sustainability. As there are several different timber certification schemes available, the government recognised that it needed a framework for assessing which ones provide assurance that its contract requirements for legal and sustainable timber sources are being delivered. This document sets out the criteria developed to provide that framework. 

For practical advice on how to implement the TPP during the procurement process, including types of evidence that contracting authorities can request of suppliers to demonstrate compliance with the criteria set out below, refer to the UK government’s Timber Procurement Advice Note (TPAN). The TPAN is a guidance document for contracting authorities and suppliers to the government.

Changes to the criteria: 5th edition

Section 1.1 provides an updated definition of ‘legal’ sources. No changes have been made to social or sustainable criteria.  

A history of previous changes to this document can be found in Annex 1. The latest changes have been necessary to ensure that the UK TPP is in line with the UK Timber Regulation (UKTR), which came into force on 1 January 2021. The definition of ‘legal’ within the UK government’s TPP has been amended in this 5th edition to reflect the exact definition of ‘legally harvested’ set out in the UKTR. Read more detailed information on the UKTR.

The UK government criteria 

The criteria sets out the requirement which must be met and guidance on interpretation and scoring, together with notes on the origin or purpose of the requirement where this might help with interpretation. It also indicates whether compliance is required for legal compliance (L), sustainability (S) or both. 

The requirements for the content of standards reflects the requirements of the UK government for legality and sustainability which are set out in the document ‘UK government Timber Procurement Policy: Definition of Legal and Sustainable for timber procurement’ 6th Edition, February 2025.

Scoring

Compliance with the requirements of each criterion will be scored on a 3-point scale:

0: Inadequately addressed and not acceptable.

1: Partially addressed.

2: Acceptable.

For assessing certification schemes’ overall compliance with the requirements of the UK government Timber Procurement Policy the following rules have been adopted.

A minimum score of 1 for each criterion identified as relating to legal requirements.

Sustainable

A minimum score of 1 for each criterion identified as relating to sustainable requirements, and an overall score of 75% of the total possible score for criteria relating to sustainable requirements.

Glossary of abbreviations

ISO: International Organisation for Standardisation

CITES: Convention on International Trade in Endangered Species of Wild Fauna and Flora

EMS: Environmental management system

FLEGT: Forest Law Enforcement, Governance and Trade

FMU: Forest management unit

FSC P&C: Forest Stewardship Council Principles and Criteria

ISEAL: International Social and Environmental Accreditation and Labelling Alliance

PEOLG: Pan European Operational Level Guidelines

1. Forest Standards

1.1 Content of standards for legal compliance

For more detailed information about how to comply with the UK Timber Regulations and UK FLEGT Regulations, read the guidance: Regulations: timber and FLEGT licences.

Most countries have legislation which they apply to the harvest and supply of timber. For timber placed on the market in Great Britain (England, Scotland and Wales) to be considered legal it must have been harvested in accordance with the applicable legislation in the country of harvest. The implication for anyone intending to place timber on the market in Great Britain is that they must identify the country of harvest, understand the applicable legislation, and ensure that the timber has been harvested in accordance with those laws. ‘Applicable legislation’ refers to the legislation that is in force in the country in which the timber was harvested. Timber harvesting laws vary from country to country, however some of the common subjects which harvesting laws cover include:

  • rights to harvest timber within legally gazetted boundaries
  • payments for harvest rights and timber including duties related to timber harvesting
  • timber harvesting, including environmental and forest legislation including forest management and biodiversity conservation, where directly related to timber harvesting
  • third parties’ legal rights concerning use and tenure that are affected by timber harvesting, and
  • trade and customs, in so far as the forest sector is concerned

Guidance in section 1.1 includes references to the EU Timber Regulation (EUTR). Note that the EUTR will be repealed when the EU Regulation on deforestation-free products (or EU Deforestation Regulation – EUDR) enters into application. Timber products produced before the entry into force of the EUDR on 29 June 2023, the EUTR will continue to apply until 31 December 2027. For other timber products produced after entry into force of the EUDR, the EUTR will be repealed when the EUDR enters into application. As of January 2025, this is scheduled to be on 30 December 2025 for large and medium businesses and 30 June 2026 for micro and small enterprises. These references are included here due to the ongoing application of the EUTR in Northern Ireland – the EUDR may similarly be applied in Northern Ireland upon its entry into application, however as of January 2025 this is unconfirmed.

The UK government’s Office for Product Safety & Standards document ‘Guidance on the UK Timber Regulations’ (January 2021) can be used as a point of reference.

Criterion 1.1.1. Rights to harvest timber within legally gazetted boundaries

This is relevant to definition L1 in definitions of legal and sustainable.

If schemes are only applicable to countries where legal use rights are clear, then an explicit requirement for legal compliance is sufficient for a score of 1, even if legal use rights are not explicitly addressed.

However, if the scheme can be applied in countries where legal use rights are not clear, there must be an explicit requirement.

The UK Timber Regulations guidance document Timber and Timber Products (Placing on the Market) Regulations 2013: UK sets out the requirements for evidence.

‘Guidance on the UK Timber Regulations (January 2021)’ includes in section 4.17 examples of documents that could show compliance with applicable legislation.

This is relevant to definition L2 in definitions of legal and sustainable.

Where payment is clearly required by law, then an explicit requirement for legal compliance is sufficient for a score of 1.

This is relevant to definition L3 in definitions of legal and sustainable.

In general, compliance with the law means compliance with all relevant laws. However, it is now recognised that in some countries, laws may be unclear or conflicting making clear definition of legality difficult to achieve.

For UK FLEGT Regulations as an example, developing a legality definition with multi-stakeholder support is a core element of the process.

This is relevant to definition L4 in definitions of legal and sustainable.

See criterion 1.1.3.

Criterion 1.1.5. Trade and customs, in so far as the forest sector is concerned

This is relevant to definition L4 in definitions of legal and sustainable.

See criterion 1.1.1.

1.2. Content of standards for sustainability requirements

Criterion 1.2.1. Certification standards must be consistent with a widely accepted set of international principles and criteria defining sustainable or responsible forest management at the forest management unit level

This is relevant to definition S1 in definitions of legal and sustainable.

It is not possible to define a detailed global standard for forest management because of the huge variation in climate, vegetation, topography, socio-economic context, and so on. Therefore, certification standards need to be adapted to local conditions, but to ensure consistency and avoid trade barriers, it is important to base each standard on accepted international principles such as:

  • intergovernmental processes designed for use at FMU level, for example the Pan-European Operational Level Guidelines (PEOLG)
  • requirements developed by an international organisation such as the ITTO Criteria
  • international principles developed explicitly for forest certification such as the FSC Principles and Criteria or Programme for the Endorsement of Forest Certification (PEFC) Sustainable Forest Management requirements

Such international principles can be developed either to guide national planning and reporting, or to guide management at the scale of the forest management unit. As certification applies at the latter level it is appropriate to base certification standards on international principles designed for this use. However, use of a set of appropriate international criteria developed for national reporting or other uses is sufficient for a score of 1.

Criterion 1.2.2. The standard must be performance-based

This is relevant to definition S2 in definitions of legal and sustainable.

There are 2 types of requirements – performance and management system. Only performance requirements guarantee a defined level of performance.

Therefore, only standards which include performance requirements (which may be in addition to system requirements) can provide the basis for the delivery of the UK government requirements for legal compliance or sustainability.

To score 2, criteria 1.2.3 to 1.2.6 must be scored 2. To score 1, each of the criteria 1.2.3 to 1.2.6 must be at least partially addressed.

Criterion 1.2.3. The standard must ensure that harm to ecosystems is minimised

To do this, the standard must include requirements for:

a) Appropriate assessment of impacts and planning to minimise impacts.

b) Protection of soil, water, and biodiversity.

c) Controlled and appropriate use of chemicals and use of Integrated Pest Management wherever possible.

d) Proper disposal of wastes to minimise any negative impacts.

This is relevant to definition S5 in definitions of legal and sustainable.

The first sentence sets out the goal of the criterion. Compliance will be assessed against the list of requirements.

To score a 2, each requirement must be adequately addressed. Where this is not achieved, but there are no major omissions, a score of 1 can be awarded.

Where an issue (for example, waste disposal) is adequately covered by legal requirements in all countries where a scheme can be used, it need not be explicit provided that legal compliance is required by the standard.

Criterion 1.2.4. The standard must seek to ensure that productivity of the forest is maintained

To do this, the standard must include requirements for:

a) Management planning and implementation of management activities to avoid significant negative impacts on forest productivity.

b) Monitoring which is adequate to check compliance with all requirements, together with review and feedback into planning.

c) Operations and operational procedures which minimise impacts on the range of forest resources and services.

d) Adequate training of all personnel, both employees and contractors.

e) Harvest levels that do not exceed the long-term production capacity of the forest, based on adequate inventory and growth and yield data.

This is relevant to definition S6 in definitions of legal and sustainable.

The first sentence sets out the goal of the criterion. Compliance will be assessed against the list of requirements.

To score a 2, each requirement must be adequately addressed. Where this is not achieved, but there are no major omissions, a score of 1 can be awarded.

Where an issue is adequately covered by legal requirements in all countries where a scheme can be used, it need not be explicit provided that legal compliance is required by the standard.

Criterion 1.2.5. The standard must seek to ensure that forest ecosystem health and vitality is maintained

To do this, the standard must include requirements for:

a) Management planning which aims to maintain or increase the health and vitality of forest ecosystems.

b) Management of natural processes, fires, pests and diseases.

c) Adequate protection of the forest from unauthorised activities such as illegal logging, mining and encroachment.

This is relevant to definition S7 in definitions of legal and sustainable.

The first sentence sets out the goal of the criterion. Compliance will be assessed against the list of requirements.

To score a 2, each requirement must be adequately addressed. Where this is not achieved, but there are no major omissions, a score of 1 can be awarded.

Where an issue is adequately covered by legal requirements in all countries where a scheme can be used, it need not be explicit provided that the standard assures legal compliance.

Criterion 1.2.6. The standard must seek to ensure that biodiversity is maintained

To do this, the standard must include requirements for:

a) Implementation of safeguards to protect rare, threatened, and endangered species.

b) The conservation/set-aside of key ecosystems or habitats in their natural state.

c) The protection of features and species of outstanding or exceptional value.

This is relevant to definition S8 in definitions of legal and sustainable.

The first sentence sets out the goal of the criterion. Compliance will be assessed against the list of requirements.

To score a 2, each requirement must be adequately addressed. Where this is not achieved, but there are no major omissions, a score of 1 can be awarded.

Where an issue is adequately covered by legal requirements in all countries where a scheme can be used, it need not be explicit provided that the standard assures legal compliance.

This includes those relevant to:

  • labour and welfare
  • health and safety

This is relevant to definition S9 in definitions of legal and sustainable.

If schemes are only applicable to countries where legal use rights are clear, then an explicit requirement for legal compliance is sufficient for a score of 1 even if legal use rights are not explicitly addressed. However, if the scheme can be applied in countries where legal use rights are not clear, there must be an explicit requirement.

This is relevant to definition SC1 in definitions of legal and sustainable.

To score 1 every aspect of the criterion must be adequately addressed.

To score 2 the standard must include a requirement for a process of free, prior and informed consent.

Where the criterion is adequately addressed by legal requirements in all countries where a scheme can be used, the standard need not make explicit reference to the subject matter of the criterion provided that the standard requires legal compliance.

Criterion 1.2.9. The standard must require that appropriate mechanisms are in place for resolving grievances and disputes including those relating to tenure and use rights, to forest management practices and to work conditions

This is relevant to definition SC2 in definitions of legal and sustainable.

To score 2 each aspect of the requirement must be adequately addressed. Where this is not achieved but there are no major omissions for any aspect a score of 1 can be awarded.

Where the criterion is adequately addressed by legal requirements in all countries where a scheme can be used, the standard need not make explicit reference to the subject matter of the criterion provided that the standard requires legal compliance.

Criterion 1.2.10. The standard must ensure that the basic labour rights of forest workers are safeguarded

To do this, the standard must include requirements concerning the following:

  • freedom of association and the effective recognition of the right to collective bargaining
  • the elimination of all forms of compulsory or forced labour
  • the effective abolition of child labour
  • the elimination of discrimination in respect of employment and occupation

This is relevant to definition SC3 in definitions of legal and sustainable.

To score 2 each requirement must be adequately addressed, for example by reference to all of the core International Labour Organization (ILO) conventions.  Where this is not achieved but there are no major omissions a score of 1 can be awarded.

Where the criterion is adequately addressed by legal requirements in all countries where a scheme can be used, the standard need not make explicit reference to the subject matter of the criterion provided that the standard requires legal compliance.

Criterion 1.2.11. The standard must require that appropriate safeguards are put in place to protect the health and safety of forest workers

This is relevant to definition SC3 in definitions of legal and sustainable.

To score 2 the requirement must be adequately addressed, for example by reference to relevant ILO conventions or national/local legal requirements. The core ILO conventions are those conventions which form the basis for the ILO Declaration on Fundamental Principles and Rights at Work.

Where this is not achieved but there are no major omissions a score of 1 can be awarded.

Where the criterion is adequately addressed by legal requirements in all countries where a scheme can be used, the standard need not make explicit reference to the subject matter of the criterion provided that the standard requires legal compliance.

1.3. Standard setting process

Note: if the body conforms, then a score of 2 will be awarded. If the body does not conform, then a score of 0 will be awarded.

Criterion 1.3.2. The standard-setting process must seek to ensure balanced representation and input from the economic, environmental and social interest categories

This is relevant to definition S3 in definitions of legal and sustainable.

It is widely accepted that ‘sustainable forest management’ is management which delivers an appropriate combination of economic, environmental and social benefits. In practice it is rarely possible to deliver all possible benefits all of the time, so it is necessary to find appropriate compromises between competing interests.

The only way to achieve balanced representation in practice is to ensure that the range of issues and viewpoints of the different stakeholder groups making up the economic, environmental and social interest categories are fed into and influence the standard-setting process.

Major stakeholder groups include such groups as forest owners and managers, processors, buyers, governments, academics, conservation organisations, non-governmental organisations (NGOs), workers, forest users, indigenous groups, and communities.

To score 2 the process must actively seek to ensure that the full range of stakeholder groups within each interest category are engaged and involved. A score of 1 can be achieved if the range of stakeholder groups within each interest category have access to the standard-setting process.

Criterion 1.3.3. The standard-setting and decision-making process

This adopted process must try to ensure that:

  • no single interest can dominate the process
  • no decision can be made in the absence of agreement from the majority of an interest category

This is relevant to definition S4 in definitions of legal and sustainable.

The way in which the process is run and decisions are made is as important as the range of interests represented since an appropriate compromise will only be achieved if all the interest categories are able to influence the standard-setting and decision-making process.

To achieve a score of 2 the standard-setting process must be designed to ensure that all 3 interest categories can influence the process equally and that the standard cannot be finalised in the absence of agreement from a majority of an interest category. In practice this can be achieved by either:

  • a process based on consensus where this means that a decision cannot be reached if any major stakeholder group sustains a strong objection
  • a process based on majority voting within each of the 3 interest categories

Where neither of these approaches is followed, in order to achieve a score of 1 the scheme must ensure that it would not be possible for a standard to be finalised if:

  • it would be possible for a major stakeholder group to be involved in the process but not able to significantly influence the content of the standard, and
  • the stakeholder group was strongly opposed to the content of the standard

2. Certification

Criterion 2.1. Certification must be undertaken by a body whose organisation, systems and procedures conform to applicable ISO guidance, or publicly available equivalent

Applicable ISO guidance includes:

  • ISO/IEC 17021:2015 – Conformity assessment: Requirements for bodies providing audit and certification of management systems
  • ISO/IEC 17065:2012 – Conformity assessment: Requirements for bodies certifying products, processes and services
  • General Requirements for bodies operating product certification systems

Criterion 2.2. Certification is undertaken by a body which is accredited to evaluate against forest management standards

The scope of the accreditation should include the elements set out in criteria 2.3 to 2.6.

Criterion 2.3. The requirements for certification audits must include assessment of systems and documentation together with verification of outcomes in the forest adequate to ensure that both system and performance requirements in the standard are being met

The make-up of the team, the sampling strategy and the amount of time spent carrying out the audit are all important in ensuring that sufficient objective evidence of compliance with the standard is collected to make the final decision robust.

Therefore, the possible scores against this criterion are either 0 or 2.

If a process provides a genuine opportunity for any major stakeholder group to influence the content of the standard, but a group chooses not to participate, this would not constitute a failure.

Criterion 2.4. The certification audit must include sufficient consultation with external stakeholders to ensure that all relevant issues are identified relating to compliance with the requirements of the standard

Consultation with external stakeholders is very important to establish whether there are any issues which might prevent full compliance with the standard which the audit team has not identified (for example, seasonal issues not evident at the time of the audit, ongoing social conflicts) and to ensure that any interpretation of the requirements of the standard for the immediate local conditions is appropriate.

To score 2, the stakeholder consultation must be designed to ensure identification of all relevant issues. To score 1, there must be some provision for consultation

Criterion 2.5. A summary of the results of the certification audit (excluding confidential information) must be publicly available to interested parties

Sustainability can only be delivered by an appropriate balance of economic, social and environmental imperatives. It is important that representatives of each of these groups can monitor certification to make sure that the appropriate balance is being delivered.

The information must, at a minimum, provide a summary of the findings with respect to conformance with the requirements of the forest management standard.

To score 2, the public summary must be available on a relevant website. To score 1, the summary must be available to any interested party on request within a defined timescale.

Criterion 2.6. There is an accessible and functioning mechanism for dealing with complaints and disputes which is open to any interested party

It is widely accepted good practice to ensure that any issues or concerns are dealt with efficiently and transparently, whatever their origin.

Criterion 2.7. The certification scheme must include measures which limit and clearly describe and justify the circumstances in which certification may be awarded to a forest, the character of which has been subject to planned and systematic transformation in a concentrated period with the consequence of significantly reducing the forest’s biodiversity or the health and vitality of the forest ecosystem

For example, the conversion of natural forest or forest with many of the characteristics of natural forest to industrial forest plantation.

Certification schemes may limit the circumstances in which affected forests may be certified in whatever ways they consider appropriate.

A score of 2, 1 or 0 shall be awarded based on the degree of assurance, provided that timber from forests that have been the subject of transformation, as described in the criterion, will enter the supply chain as timber from certified forests only in clearly defined and justifiable circumstances.

3. Accreditation

Criterion 3.1. Accreditation must be undertaken by a national or international body whose organisation, systems and procedures are consistent with ISO/IEC 17011:2017 (Conformity assessment – Requirements for accreditation bodies accrediting conformity bodies)

Note: this should be provided by the requirements of the certification scheme or through other mechanisms such as the International Accreditation Forum’s Multilateral Recognitions Arrangements.

4. Chain of custody

Criterion 4.1. Assessment of chain of custody must be undertaken by a certification body operating in accordance with ISO/IEC 17065:2012 (Conformity assessment – Requirements for bodies certifying products, processes and services or equivalent and accredited by an accreditation body operating in accordance with ISO 17011 or equivalent)

Chain of custody certification must be undertaken by an accredited competent third-party just as for forest management certification.

This means that each organisation in the chain from forest to final certified product which owns or processes the material in any way must have been audited to confirm that they are implementing chain of custody requirements and have a valid chain of custody certificate.

Therefore, the possible scores against this criterion are either 0 or 2.

This requirement is relevant when mixing of certified and non-certified material is allowed. Mixing occurs whenever the following approaches are used: percentage labelling, volume accounting, input-output or processor certification.

In such cases, in order to meet UK government requirements for legality within the Timber Procurement Policy, there must be a system in place which provides assurance that the uncertified material is from a legal source.

The UK government Timber Procurement Policy requires all timber and wood products to be from legal sources. Therefore, if mixing of certified and uncertified material is allowed, in order to meet UK government requirements for legality, there must be a system in place which provides assurance that the uncertified material is from a legal source.

If the certification system does not include requirements to ensure that the uncertified material is from legal sources, then only products which are 100% certified can be accepted as providing assurance of legality within the Timber Procurement Policy.

Note: If a scheme scores 0 for this criterion, it only affects acceptance of products containing uncertified material.

Criterion 4.4. If mixing of certified and uncertified material in a product or product line is allowed and the proportion of uncertified material can exceed 30%, then the uncertified material must be covered by a verifiable system which ensures that it is from sustainable forest sources where the requirements for sustainability set out in criteria 1.2.3 to 1.2.6 above are being met

This requirement is relevant when mixing of certified and non-certified material is allowed. Mixing occurs whenever the following approaches are used: percentage labelling, volume accounting, input-output or processor certification.

The UK government requires that 70% of the material in a product or product line is from sustainable sources. To meet this requirement, if the proportion of uncertified material is more than 30% then there must be a system in place which provides assurance that the uncertified material is from a sustainable source.

If such a system is not in place, then only material which contains 70% or more certified material can be accepted. Examples of approaches which provide such information include:

  • segregation – material from a certified forest is kept separate from uncertified material throughout the production process
  • percentage-based claims – the percentage of material in the product or product line from a certified forest is reported
  • mass-balance – the proportion of product sold as certified is equivalent to the proportion of certified raw material entering the process

Note: If a scheme scores 0 for this criterion, it only affects acceptance of products or product lines containing more than 30% uncertified material.

Criterion 4.5. There is a clearly defined mechanism for controlling all claims made about the certified nature of products which ensures that claims are clear and accurate, and that action is taken to prevent any false or misleading claims

This requirement is relevant when mixing of certified and non-certified material is allowed. Mixing occurs whenever the following approaches are used: percentage labelling, volume accounting, input-output or processor certification.

If claims are not controlled, then the veracity of any claim made is in question.

Note: ISO 14020:2022 (Environmental statements and programmes for products – Principles and general requirements) establishes principles and specifies general requirements that are applicable to all types of product-related environmental statements and environmental statement programmes. Environmental statements result from environmental statement programmes and include self-declared environmental claims, ecolabels, environmental product declarations (EPDs) and footprint communications.

Criterion 4.6. If recycled material is used, there must be a verifiable system in place which is designed to ensure that recycled material is from the following categories

  • pre-consumer recycled wood and wood fibre or industrial by-products but excluding sawmill co-products unless certified
  • post-consumer recycled wood and wood fibre
  • driftwood

Further guidance needs to be developed.

Note: If a scheme scores 0 for this criterion, it only affects acceptance of products containing recycled material.

5. National level application

Criterion 5.1. International certification programmes that endorse national or sub-national schemes or standards must be implementing documented systems that ensure the fulfilment, within a reasonable and practicable timeframe, of all requirements which are applicable at a national level

This is related to:

a) Forest standards (section 1)

b) Certification (section 2)

c) Accreditation (section 3)

d) Chain of custody (section 4)

Assessment against this criterion shall consider not only the existence of systems but also the documented results of their implementation; for example, reports, made by the programme in question, on scheme endorsement.

To score 2 every aspect of the criterion must be adequately addressed.

Where this is not achieved but there are no major omissions a score of 1 can be awarded.

Annex 1. History of amendments

Since the publication of the third edition of this document in April 2010, the following key changes have been made to the UK government Timber Procurement Policy: Definition of legal and sustainable for timber procurement, sixth edition, February 2025 and to this document.

  1. June 2013: change to definition of “legal” to reflect the definition of legally harvested timber and timber products within the EU Timber Regulation and movement of one criterion from legal criteria, to sustainable criteria (see 1.2.7 of this document and S9 in the UK government Timber Procurement Policy: Definition of legal and sustainable for timber procurement, sixth edition, February 2025).

  2. February 2025: change to the definition of “legal” to reflect the definition of legally harvested timber and timber products within the UK Timber Regulation, which was announced on 1 January 2021 (see S3 in the UK government Timber Procurement Policy: Definition of legal and sustainable for timber procurement, sixth edition, February 2025).

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