Document Code:  INT-STD-40-004_77

Topic:  Chain of Custody (CoC) Requirements

Document Type:  Interpretations (INT)

Posted on:  March 25, 2026

The interpretation INT-STD-40-004_77 is now available in the FSC Connect Document Centre and can be accessed via this link: https://connect.fsc.org/document-centre/documents/resource/380, page 41. This interpretation considers whether an organization can issue invoices for FSC Controlled Wood materials to a site that is its own legal entity under the scope of a single CoC certification, but is not ‘acting as the certificate holder’. It concludes that when the organization sells materials to an external client, the client must be another FSC-certified organization (Clause 5.6 FSC-STD-40-004 V3-1 - https://connect.fsc.org/document-centre/documents/resource/302), so that the certification body (CB) can verify this through sales documents. This is because, unless the receiving site is ‘acting as the certificate holder’, the CB may face challenges verifying the information, as not all sites are recorded in the FSC certification database under a single certification with multiple sites (see INT-STD-20-011_32, page 21).


The draft interpretation was consulted between 28 January 2026 and 13 February 2026, with a positive response from the majority of stakeholders. Following the consultation, the text was amended to reflect stakeholder feedback before final approval.


As with all interpretations published with reference to PSU-PRO-10-201 V2-2 Enquiry Procedure - https://connect.fsc.org/document-centre/documents/resource/194, this interpretation is effective and valid from the date of publication (24 March 2026).
For any queries or comments regarding the interpretation or process, please contact the Chain of Custody team at  chainofcustody@fsc.org.