Specifying FSC and PEFC timber

At a glance

Meanings follow FSC-STD-40-004 V3-1 (Annex E definitions, cl 5.1, Table C, cl 5.6) and PEFC ST 2002:2020 (3.27, 3.28, 5.2). Ask the supplier which claim applies to each item: do not infer it from a label.

Three conditions make a claim verifiable

Chain of custody is the documented route timber takes from the forest to the product sold with the claim. FSC’s standard describes it as running through each stage of sourcing, processing, trading and distribution where moving to the next stage changes ownership, and says that any change of ownership requires the organisation to be independently certified if it wants to make an FSC claim about its products.

A claim that reaches you therefore rests on three conditions:

• A certificate at every owner. Each organisation that owns certified timber and sells it on with a claim, makes or changes the product, labels it or promotes it, must itself be certified (FSC-STD-40-004 V3-1, Box 1). FSC UK says the same of anyone cutting to size, repackaging, relabelling or adding other forest-based components. Agents who only arrange a sale, and logistics providers who never take ownership, do not need to be.
• A scope that covers the product. A certificate covers named product groups, not everything a business sells. FSC UK asks buyers to check that the certificate covers the right category, and PEFC’s standard requires each certified organisation to define its scope as product groups (ST 2002:2020, 4.1.2).
• The claim on the paper. The claim and the seller’s certificate code have to be on the sales and delivery documents, as the next section sets out.

The drawing marks the five places where a claim most easily goes missing. One of them sits with the specifier: FSC UK advises buyers to ask for FSC when placing the order and to say that the claim must appear on the sales documents, because a company may sell both FSC and non-FSC versions of the same product. For tenders, it adds that both the product and the company itself, not just its supplier, must be certified.

What must be on the invoice and the delivery note

‘FSC timber’ on a quote is not a claim. The standards list what a sales or delivery document has to show before the claim counts. Both are close to the same seven items:

Where the invoice does not travel with the goods, FSC’s standard allows the delivery document to carry the same information, with a reference to the sales document (cl 5.3). For custom manufactured products, such as joinery made by a woodworker, FSC allows a supplementary document that links to the service invoice and lists the certified components, their quantities and claims, and the certificate code (cl 5.8). PEFC asks the organisation to specify the type of document in which its claims are made (5.2.2).

Look also for the licence code. FSC UK describes a certificate code in the form XXX-COC-000000 and a trademark licence code in the form FSC-C000000: they are different numbers, and the certificate code is the one to check.

Check a certificate in five steps

You do not have to take a claim on trust, and the schemes expect you to check. The steps follow FSC UK’s buyer guidance and the PEFC standard.

1. Get the certificate code before you order, and ask which business holds it. It should be the business that owns the timber and invoices you.
2. Look it up in the scheme’s public database (FSC’s certificate database, or PEFC’s). Do not rely on a copy of the certificate alone.
3. Check that it is valid. PEFC states that a certificate is valid for a maximum of five years, with annual surveillance audits in between, so look at the dates and the status.
4. Check the scope. The product group or category must cover what you are buying. FSC UK gives ‘indoor furniture’ as an example of a category to look for.
5. Match the claim. The invoice must carry the claim you specified, not only the word ‘FSC’ or ‘PEFC’. File a dated copy of what you checked against the item on the FF&E schedule.

A business that only passes on certified goods without taking ownership may not appear in the database at all, so the useful question is always who owns the timber when it is sold to you.

Certification is not legality: the UK Timber Regulations

FSC and PEFC certify forest management and chain of custody. The UK Timber Regulations are a separate legal duty. A person who first places timber or timber products on the Great Britain market is an operator, and a person who buys or sells timber already on the market is a trader. For goods imported from outside Great Britain the operator is the entity named in box 8 of the customs declaration (OPSS guidance, para 2.7). Both keep records for at least five years.

An operator must apply a due diligence system: gather information (species, quantity, supplier, country of harvest, compliance with applicable law), assess the risk of the timber being illegal, and mitigate any risk to negligible. The products in scope are listed by customs code and include veneer sheets, particle board, fibreboard, plywood and veneered panels, builders’ joinery and wooden furniture (OPSS guidance, Table 1).

FSC UK is direct about the limit: FSC is a useful tool for risk mitigation but not an automatic green lane, and submitting an FSC certificate on its own as a due diligence system would not be considered sufficient. OPSS says an operator that relies on a certification scheme must decide whether the scheme’s standard covers all the applicable legislation, and should be satisfied that the body that issued the certificate is in good standing. Certification can sit inside the evidence. It cannot replace it.

Two consequences for a specifier. First, ask the supplier for the species (common and scientific name) and the country of harvest: FSC’s standard requires certificate holders to provide them on request where legislation needs them (cl 6.1 b). Second, settle in writing who is the operator for the supply route, because that depends on who first places the timber on the market and is a question for your adviser, not an assumption. Breaching the due diligence duties can lead, on indictment, to a fine or imprisonment of up to two years, and breaching the traceability and record duties to a fine (SI 2013/233, regs 4 and 13). The EU Deforestation Regulation is separate and is not covered here.

Product claims, project claims and logos

A product claim describes the material. A project claim describes a whole building or fit-out, and has its own standard: FSC UK describes project certification (FSC-STD-40-006 V2-0) for organisations that manage projects and want to promote them as FSC certified. Ask for it only if the client wants to promote the project, and say so at the start.

Logos are a separate matter. FSC UK says only certificate holders and promotional licence holders may use the FSC trademarks to promote products, and PEFC’s standard requires a trademark licence for the logo and on-product claims (5.3). Keep both logos off drawings, boards and promotional material unless the user holds the licence for that use. FSC’s standard also says a product sold with an FSC 100%, Mix or Recycled claim must not carry the labels of other forest certification schemes, although both claims may appear on the sales documents (cl 5.4).

Timber, veneer and timber-based board in [items, by schedule reference] is to be supplied with the claim [FSC 100% / FSC Mix, minimum [x]% / FSC Recycled / x% PEFC certified] [credit claims: accepted / not accepted]. 'Controlled Wood' and 'controlled sources' are not accepted as a certified claim. Each organisation that owns the material and sells it on with the claim is to hold a valid chain of custody certificate whose scope covers the product.

Each sales and delivery document is to show the seller's name and contact details, the customer, the date, the description and quantity of each product, the seller's certificate code [FSC certificate code / PEFC certificate number] and the claim for each product. For finished work invoiced as a service, a linked supplementary document is to list the certified components, quantities, claims and certificate code.

Before order, [Supplier] is to give the certificate code and scope of each certified party it relies on, and [Designer] will check them in the scheme's database on [date] and file the result. Delivery documents are sent with each delivery and kept for [5] years. [Supplier] is to state each species (common and scientific name) and its country of harvest, and to confirm in writing which party is the operator under the UK Timber Regulations. Certification is not accepted as the only evidence of legality.

No change of claim (including a downgrade such as FSC 100% to FSC Mix) and no substitution of a specified product without written approval from [designer]. FSC and PEFC logos are not to be applied to the work, packaging, drawings or promotional material unless the user holds the trademark licence. Where a claim cannot be evidenced as above, the item does not conform and [Supplier] is to [remedy to be agreed with the contract adviser].

Standards and sources

• FSC-STD-40-004 V3-1 EN: Chain of Custody Certification: approved 14 Jan 2021, effective 1 Sep 2021; read 5 Nov 2026.
• PEFC ST 2002:2020: Chain of Custody of Forest and Tree Based Products: in force 14 Feb 2020; read 5 Nov 2026.
• FSC UK: UKTR and FSC; Choosing FSC-certified products: read 5 Nov 2026; pages show no date.
• gov.uk: Regulations: timber and FLEGT licences, with the OPSS guidance and SI 2013/233: page last updated 20 Aug 2025; read 5 Nov 2026.

Questions we are asked

Is FSC or PEFC timber automatically legal under the UK Timber Regulations?

No. FSC UK says FSC is a useful tool for risk mitigation but not an automatic green lane, and that an FSC certificate submitted on its own as a due diligence system would not be sufficient. OPSS guidance says an operator relying on a scheme must decide whether the scheme’s standard covers all the applicable legislation. Certification can form part of the evidence.

What is the difference between FSC Mix and FSC Mix Credit?

FSC Mix x% is a percentage claim: the number is the share of inputs that count towards the claim over a claim period or job order. FSC Mix Credit is a credit claim: the supplier sells part of its output against certified input it holds on account, so the claim does not tell you what is in a particular piece. Ask the supplier which one applies, and say in the specification which you accept.

Does a maker need its own certificate to supply FSC-certified joinery?

If it owns the certified material and sells the work with an FSC claim, FSC’s standard requires it to be certified, and FSC UK says the same of anyone who processes or changes certified products. A business that only arranges a sale or transports goods without taking ownership does not need one. Ask for the certificate code and check the scope.

Can an invoice just say ‘FSC timber’?

No. The standards ask for the seller’s details, the customer, the date, a product description, the quantity, the seller’s certificate code and the claim for each product. A bare ‘FSC timber’ leaves out the claim type and the certificate.

Can a piece carry both an FSC and a PEFC claim?

FSC’s standard allows an FSC-certified product to carry the FSC claim and the claim of another forest certification scheme on its sales and delivery documents, but a product sold with an FSC 100%, Mix or Recycled claim must not carry another scheme’s label. Whether a particular supply chain can make both claims is for the supplier to evidence.

Do I need FSC project certification?

Only if the client wants to promote the whole project as FSC certified. FSC UK describes it as a separate standard (FSC-STD-40-006) for organisations that manage projects. Product claims and the invoice checks on this sheet do not require it.