Supporting FSC certificate holders in Ukraine during the armed conflict, along with protecting the integrity of certification system, is an essential part of FSC's normative decisions. Consistent steps of FSC International's response to the situation in Ukraine related to the martial law concerned certificate holders, certification bodies and other participants of the certification system. Accordingly, changes in the normative framework covering the issues of risk assessment of controlled wood for Ukraine, certification assessment, etc. are the necessary steps aimed at maintaining FSC certified status of organizations and reducing risks for all participants of FSC certification system.


An expected step is the possibility of excision of areas contaminated with explosive objects from the scope of FSC certification in Ukraine. For reasons beyond the control of the persons responsible for forest management, it is impossible to ensure compliance with FSC national forest stewardship standard requirements for Ukraine in such areas, unlike the rest of the territory, where these requirements are met.

The need for a clear and consistent normative regulation of the above possibility in FSC system has led to the development of normative advice FSC-ADV-20-001-12 (March 2022), which addressed the consequences of uncontrollable or non-auditable risks impacting the forest sector at large. The interpretation INT-ADV-20-001-12_02 (July 2022) clarified, among other things, the requirements for reducing the scope of FSC certificates. Thus, the interpretation INT-ADV-20-001-12_02 opened up the possibility for excising areas from FSC certification in accordance with the "FSC policy on the excision of areas from the scope of certification" FSC-POL-20-003 V 1-0 under specific uncontrollable risks by persons responsible for forest management.

It is the interpretation INT-POL-20-003_14 (December 2022) that specified the conditions for applying FSC excision policy (FSC-POL-20-003 V 1-0) to areas affected by armed conflict. In particular, if the threshold value of the area affected by an armed conflict, which is 5% of the forest management unit's area (clause 3.1.d), is exceeded (as defined by FSC-POL-20-003 V 1-0), such territory may be excised from the scope of certification, provided that a number of requirements of the named above document are met (clauses 2.2 and 3.2) and it is still possible to maintain certification in the rest of its territory.

In accordance with the above paragraphs of FSC-POL-20-003 V 1-0, the working group has completed the development of a draft "FSC criteria, indicators and verifiers for excision of CEO areas from the scope of certification in accordance with FSC-POL-20-003 V 1-0 for Ukraine". The draft document has now been submitted for final review to the Performance and Standards Unit of the FSC International Center. A decision on its approval and publication as a normative annex to FSC national forest stewardship standard of Ukraine is expected.


The requirements that forestry enterprises with more than 5% of territories contaminated with explosive objects shall meet to maintain their FSC-certified status relate to changes in both their management system (adaptation of processes, integration of risk-based approaches) and management practices. The arguments in favor of adapting planning (policies, objectives, procedures, etc.) and monitoring systems (verifiable targets, frequency, etc.) to take into account areas contaminated with explosive objects were undeniable throughout the development of the draft document. Assessing, documenting, monitoring the impacts associated with the presence of areas contaminated with explosive objects and applying appropriate response measures is one of the elements of the precautionary approach aimed at, among other things, protecting health and safety of workers.

The need to verify forest management for "non-controversy" (e.g., timber should not be associated with illegal forest management, human rights violations, deterioration of high conservation values, deforestation and forest degradation, etc.) has determined the requirements to prohibit any field activities in areas contaminated with explosive objects, including timber harvesting, except for the use of remotely control devices that protect the life and health of employees. At the same time, the track and trace system for forest products should ensure identification of the products' origin up to the plot level, to prevent the products associated with controversial wood categories and those that may originate from areas contaminated with explosive objects from being included into supply chains.

These and other systematic steps at the level of management and forestry practices that are aimed at adapting to the presence of areas contaminated with explosive objects are primarily aimed at ensuring safety of all participants in FSC certification process, preventing and reducing negative impacts from such areas, minimizing risks to environmental values in terms of their biophysical and human environment.

  Pavlo Kravets, Director of FSC Ukraine, said: “More than a year-long process of developing additional requirements to ensure responsible forest management in the context of risks caused by explosive objects has come to an end. We have gained a unique experience in finding innovative management solutions and introducing new forestry practices thanks to the flexible rules of FSC system and the dedicated efforts of the working group. We expect the updated version of FSC national forest stewardship standard of Ukraine to be approved in the nearest future, and we will inform you about this additionally”.