Forest Stewardship Council®
Questions and answers from a webinar introducing the revised FSC®
Trademark standard for certificate holders (FSC-STD-50-001 V2-0)
13 December 2017
Contents
General questions on trademark use ........................................................................................ 2
Transition period ......................................................................................................................... 3
Trademark use management system ......................................................................................... 4
On-product labelling ................................................................................................................... 6
Size and colour requirements .................................................................................................... 8
Promotion .................................................................................................................................... 9
Trademark registration symbol ................................................................................................ 10
Label generator ......................................................................................................................... 12
Online training course .............................................................................................................. 13
Webinar attendance and materials .......................................................................................... 13
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FSC Global Development GmbH · [Link] · FSC® F000100
Charles-de-Gaulle-Straße 5 · 53113 Bonn · Germany
T +49 (0) 228 367 66 0 · F +49 (0) 228 367 66 65
Geschäftsführer | Director: Kim Bering Becker Carstensen
Handelsregister | Commercial Register: Bonn HRB15990
Forest Stewardship Council®
General questions on trademark use
1. In standard V1-2, the brand name as ‘FSC® certified Brand Name timber’ is allowed.
Why is such use not allowed in V2-0?
FSC may not be used as part of a brand name. However, if you specify that it refers to cer-
tification, as in the example “FSC® certified Brand Name timber”, this should be fine. There
has been no change to the requirements in this respect, even though the above example
was left out of the revised version.
2. Annex C of the new standard notes the following rule: "Do not say that products car-
rying the ‘Mix’ label are made of materials from responsibly or well-managed forests
without referring to the other sources used." Since Annex C is only for guidance,
and therefore no new rules should be introduced within this, the above rule must be
specified somewhere else. Could you clarify in which clause, and in which normative
document, this rule is specified?
There are general rules that require all trademark use to be accurate and not to create a
loss of credibility for the FSC system. In addition, most countries have general laws in
place governing the making of certification claims, which say that any statements made
about them have to be correct and verifiable, not misleading or exaggerating. Claiming that
FSC Mix material comes from FSC-certified forests only would not comply with either type
of requirement. Annex C does not lay out new requirements, but is intended as help to
make accurate and truthful statements about FSC and FSC-certified materials, in line with
the requirements provided earlier.
3. We cut and paste text from the standard into emails to describe to certificate holders
how to meet the standard. I assume we can still do this, even though there is a copy-
right statement saying “no copying” etc. on page 2?
Yes, it is fine to use the standard in this way to support your work with certificate holders.
The copyright statement has not changed from the previous version.
4. What are the guidelines or use restrictions for using logos for non FSC-certified peo-
ple/organizations, if they want to use logos on a blogging website used to talk
about/promote FSC products, and where can people get them?
The FSC requirements for promotional use of the FSC trademarks by non-certificate hold-
ers (FSC-STD-50-002) regulates this use of FSC trademarks. In short, retailers and similar
organizations would need to get in touch with their local FSC National Office for a license
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and artwork to promote FSC-certified products. A list with contact information can be found
on the FSC website. The requirements are currently being revised and are expected to be
released for consultation in January 2018.
5. Regarding clause 4.8 on labelling arrangements, can there be other certificate hold-
ers in between a supply chain of two companies?
Certificate holders do not have to be in a direct relationship in the supply chain in order to
have a labelling agreement in place.
6. Are suspended and dormant certificates included in VALID certificates (clause 1.2)?
No, they are not, in terms of FSC trademark use. The terminology will be aligned with the
new license agreements.
7. Are we allowed to translate ‘Forest Stewardship Council’ into Spanish, French, or
another language in a body copy (e.g. a product description)?
The name ‘Forest Stewardship Council’ may be translated in brackets after the original
name in English (see clause 2.2). It is not allowed to be replaced with a translation.
8. Clause 2.1e: Controlled wood (CW) needs to use FSC trademarks for stakeholder
consultations, and we were told it is OK to mention the certificate (e.g. in reports and
accounts) – but NOT to promote CW products. Is this correct?
This is correct. The consultation part is covered in the note under clause 1.2.
Transition period
9. What happens to certificate holders who have not changed to FSC-STD-50-001 V2-0
by 29 February 2019?
If they use FSC trademarks, and continue to do so in a way that is not compliant with V2-0
after the transition period, the usual system of compliance with the FSC normative frame-
work applies, including escalation from suspension to termination.
10. My company will conduct FSC surveillance on January 2018. What will the auditor
check in my company?
The auditor will check compliance with effective and applicable FSC normative documents.
The revised trademark standard will not yet be effective in January, but if you have any
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questions about it, you can ask your auditor to explain any unclear parts of the require-
ments.
11. What happens when a company has two certificates and license codes? Which code
takes priority? This trend is happening with Chinese certificate holders.
All products have to be labelled with the license code that is connected to the certification
that covers production of those products, unless a labelling arrangement is made between
two parts of the organization. In promotion, two license codes can be used, or just one, de-
pending on which part(s) of the organization the promotion refers to.
Trademark use management system
12. Regarding clause 2.2 of Annex A, could you please advise who will be able to decide
whether the client is ready for trademark use management system? Would that be
logo approvers, or would another person be responsible for making that decision?
It is for a certification body to agree internally who has the authority to decide on this. This
is not addressed in the trademark requirements.
13. If our customer is responsible for getting FSC approval and they opt for trademark
management, how can we know that is the case? Do we just rely on their own ap-
proval as supporting documents, without having to check ourselves?
First of all, the management system has to approved by you before it can be used by your
client. So, you would always know if they choose to do so. And yes, you would then just au-
dit the use of the system, and the quality of trademark use delivered through it, via annual
audits.
14. Our customer – a certificate holder – has already opted for the trademark use man-
agement system, with the approval of its certification body, with an email. Should we
request a new license agreement on this, complying with the new clause 4.8?
This is not necessary. The existing license agreements may be used for the time being,
even with transition to the new requirements. Clause 4.8 refers to labelling arrangements
between two certificate holders, and is not part of the trademark management system.
15. If we, as a customer, buy FSC-certified products from a supplier that already has
FSC licenses from different certification bodies to ours, and we request a product
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using our license number, between us we have different certification bodies. How do
we get approval from different certification bodies?
Sharing a certification body is not a condition for having a labelling arrangement in place. In
clause 4.8, it is explained that both certification bodies will have to be informed about the
arrangement, and this information shall contain a definition of the certification body (that of
clients or that of suppliers) that will take care of the approval, or if one of the certificate
holders will do this as part of their approved trademark management system.
16. Regarding the new management system for certificate holders, can you give some
guidelines on deciding how a company should be allowed to use it? For example,
how many correct submissions for approval should be acceptable?
This was intentionally left open in the requirements, to be agreed between a certificate
holder and a certification body, as this may vary in terms of complexity and the variety of
trademark uses by each certificate holder, or in terms of their past track record. In pilots,
we usually asked for five subsequent correct approval requests for each different type of
use (this could be by claim, by product category, or by on-product promotion), but this num-
ber is not fixed by the approved requirements.
17. The question of the trademark management system used by a client meant that of-
ten, a certificate holder prints packaging with the license number of a client. The cli-
ent has to show its label approval; if it uses the trademark management system, will
this be sufficient?
Yes, it will be sufficient – but the use of a client’s own trademark use management system
has to be specified in the labelling arrangement.
18. Regarding the trademark management system, does the tracking of correct uses
count before the standard is applicable? Or should it only start in March 2018?
This can be agreed case by case.
19. The customer should inform us, as a certification body, if they wish to approve their
own labels. Are there any guidelines that we need to follow?
All the conditions are presented in Annex A in the standard. The conditions have to be met
and the certification body has to be able to approve the system before a client can start us-
ing it for approvals.
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On-product labelling
20. Can mini labels be used in all conditions?
The term ‘mini label’ is not used in the new requirements. However, the current mini labels
can remain in use, as they comply with the compulsory elements of the FSC labels pre-
sented. And there are no conditions from FSC for using compulsory elements only.
21. If you have a wooden product, like a chair, with a paper label that is FSC certified
(only the label), what is the correct way to label it, so that it doesn't confuse consum-
ers?
A correct product type would need to be selected for the on-product label. In this case, a
product type ‘paper’ or ‘label’ would need to be selected. And of course, the label elements
would need to be big enough to be legible.
22. What does the FSC Mix label with the minimum elements look like? Could you
please provide an example?
The label with minimum elements looks identical to
the current mini label.
23. Could you please explain clause 4.5 of the new standard? Which additional FSC
logos do you mean? Extra logos? Forests For All Forever?
Any reference to FSC means using the FSC logo, name, initials, or Forest for All Forever
marks to make any reference to FSC or FSC certification on products.
24. FSC should provide a definition of the term ‘printed publication’, as there are ambi-
guities as to which printed products this term applies.
This term applies to any product, typically paper based, with editorial content. The product
category P8 is a good reference point. Please also note that stationery made of paper is
included, as specified in V2-0 of the requirements.
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25. In pharmacy remedies (where it is prohibited to enter non-pharmaceutical infor-
mation on the box), is it possible to insert the label inside the package?
Yes, it is. In fact, it was possible even with V1-2, based on the interpretation published con-
cerning this specific situation.
26. Regarding clause 8.10: there was a relaxation to say that text specifically about the
product or FSC status could be placed in the exclusion zone. Has this been removed
entirely?
This interpretation was criticized heavily when published, and therefore has not been in-
cluded in the new version of the standard.
27. If a product’s packaging is also FSC certified with the same license code, is it neces-
sary to put two FSC labels on the packaging, or it is possible to add the information
in the same label?
No, it is not required to use two different labels; only one can be used. If all materials used
are FSC certified, there is no need for a product-type specification at all. If it is necessary to
specify the certified parts, we recommend clarifying this outside of the label.
28. Regarding clause 4.5: some books with a label on the imprint page are sealed plastic
wrapping; can they have a logo on the cover? Lots of our publishers do this now.
The requirement for visible placement is just a 'should' now, so I think it's OK. Would
inside the box be OK?
It will be allowed to place the label inside the book in the future, as it is according to the V1-
2. However, if access to the imprint page of the book is being blocked in this way, the label
should be on the cover and not on the imprint page. A logo on the cover would not provide
sufficient information regarding the certification claim without seeing the other labelling ele-
ments, though; so, no, using a logo alone on the cover would not be possible.
29. Coming back to books and logo use (clause 4.5), how can the certification body
know how a book is displayed in a shop, when approving the logo use?
They cannot, and this should not influence the approval. It was just mentioned here as an
example of how books are sometimes being presented in shops.
30. Is there any guidance on product type usage on the logos? For example, we get a lot
of queries from clients using laminate products about which product type they
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should choose. A guidance which explains when pulp, fibre, paper, etc. should be
used may be helpful for both certification bodies and clients.
Thank you for this comment, we will look into this and create guidance on how to choose a
product type.
31. The product category is very limited in the label generator.
The intention is to keep the product types very broad in the label generator, as they are in-
tended for consumers to understand which materials of the products are FSC certified.
Most cases can be covered by using ‘wood’, ‘paper’ or ‘packaging’. New categories will be
added when none of the existing ones cover the material, which is often the case for new
non-timber forest products, for example.
32. Can you talk more about clause 3.6b and explain how, as approvers, we will know if
we are meeting this requirement?
In order to be able to approve the correct label claim and product type, you would need to
refer to the information provided about the materials used for the product. In this case, re-
ferring to clause 3.6b, you would need to know if neutral materials are being used for the
product in such a way that they cannot be distinguished from FSC-certified materials, to de-
termine that the use of, for example, ‘paper’, is not accurate enough and another product
type must be used instead (e.g. ‘wood’). FSC will still look into how the system could sup-
port providing this information efficiently.
Size and colour requirements
33. How can we, as a certification body, guarantee the legibility of the label? We do not
see the printed product when we receive the approval request.
We will need to respect the client’s judgement on this, and it is they who must ensure that
all elements of the label are legible on the final product. It should also be in their interest to
only print legible information on their products.
34. While answering about the size to be used, you said we could use the new size re-
quirements if we decide to move to the new standard. But shouldn't everyone
change to the new standard?
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Yes, everyone has to change to use the new standard. You can start using new size re-
quirements as soon as you transition to the new standard. This will apply to everyone even-
tually.
35. There was a minimum requirement for the resolution of digital reproductions (e.g. on
websites) of the trademarks. Does this still exist?
We have not had a minimum resolution requirement for the trademarks so far. There is
guidance about this in the marketing online toolkit, concerning use of Forest For All For-
ever marks, but there is not fixed requirement as such.
36. Can I follow the minimal size from now on?
The new size requirements are effective from 1 March 2018 onwards. If there is need for
smaller sizes in the meantime, please contact FSC via your certification body to discuss al-
ternatives.
37. Where can I find the new rules, namely the recommended minimum sizes?
You can find them in FSC-STD-50-001 V2-0, in Part IV.
38. Where is the 11 and 9 cm2 limit outlined in the standard?
This refers to the example provided, and how much less space FSC on-product labels re-
quire according to V2-0, or the requirements compared to V1-2. This is not outlined in the
standard itself.
39. Can we still use the black and white logo, or does it need to be green?
Yes, black and white can be still used. There is no change concerning colours.
Promotion
40. Are there any changes to the standard about FSC label usage on promotion panels?
The promotional elements are now identified as either compulsory or optional, but no other
changes are presented.
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41. I am a printer; can I use an FSC promotional logo for a client on my cardboard, even
if it (the cardboard) is not made from FSC-certified products?
You can use FSC promotional elements for promotional materials, made of cardboard, if it
is not misleading in terms of the certification status of that board and the cardboard is not
intended for sale.
42. Why has the promotional panel been removed from the glossary?
The promotional panel is just an example of an arrangement of the promotional elements.
The elements can be also used separately. The emphasis on the promotional panel layout
has been reduced in the standard, so as not to create the impression that this is the only
possible way to promote these elements.
43. You’ve talked about how the FSC logo etc. cannot be used on business cards. Is this
also valid for any other off-product communication?
The restriction on business cards is an exception; FSC trademarks are available for the
promotion of products and certification of an organization, in line with the requirements con-
cerning promotional use in the standard.
44. Is it possible to place an FSC logo on business cards?
Any organization may request an on-product label to be used on a business card made of
FSC-certified paper, printed by an FSC-certified printer. The on-product label includes the
FSC logo. A certificate holder may also add a sentence to promote their certification on
their business cards (see clause 7.3).
Trademark registration symbol
45. Serbia is outside of the European Union (EU) and we use the FSC sign with ‘TM’. Is
this automatically replaced by ® after accession to the EU?
We announce all changes in the registration status of countries by publishing the List of
Trademark Registrations twice a year. In case of Serbia’s accession, this information will
be included in the list after completion of the accession, depending on the agreement made
in this respect.
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46. I am an approver in a certification body and I don't have access to a label generator.
How can I see the list of countries (TM and ®) published there?
All certification bodies have been granted access to the label generator. Please contact
your colleagues to enquire about this access. If you do not know who is in charge of ac-
cess, please contact FSC at database@[Link]
47. ® versus TM … it is necessary for FSC to make a simple file for this purpose, for ex-
ample: [Link]
Thank you for the example. FSC offers a dynamic tool – the label generator – that creates
a label with the correct symbols based on countries of distribution, as inserted by the user.
48. Can we use FSC labels without ® or ™ at all, if the products are marketed worldwide
(in countries that use ® and ™)?
It is always recommended to use TM but this is not required, so the answer is yes.
49. Could you explain if FSC use on websites should follow local use and use the ®
symbol, or if it is global and should use the optional TM now?
If the target market is very limited, which can be determined by the language used, contact
information provided, delivery destinations offered, etc., a website can be categorized as
local. If the target group is not clear but the website is there for anyone to find, good prac-
tice would be to use the symbol of the country of the company releasing it. For example,
FSC International has a website that is certainly available globally, but we use ® because
we are based in Germany. Country offices then use the symbol that is applicable in their
territories.
50. Sorry, I didn't understand the answer. If we distribute a product in both a registered
region and a non-registered region, should the artwork be ®, TM or nothing?
We recommend the use of TM for these cases, but it is not required. It is not allowed, under
national laws, to use the mark ® for trademarks in countries where they are not registered.
This would give incorrect information about the registration status of the mark in that coun-
try.
51. Regarding the new version of Annex 1, is this valid immediately or only from 1 March
2018?
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The List of Trademark Registrations document is effective immediately on publication. This
means that the one published 20 November 2017 is already effective, with a transition pe-
riod of 12 months.
52. Can you use ® in regions without registration, such as when products are imported
into developing regions?
No, this is not allowed. Use of ® is limited to distribution in countries where the trademarks
are registered. Reselling of products after retail cannot be accounted for at the time when
the registration symbol is chosen; the determining factor is the intended distribution coun-
try/countries.
53. Regarding clause 6.2, if there is no FSC logo on the invoice, then is the ® symbol
needed after FSC in the disclaimer statement? It was NOT required for version 2-1,
as seen as business to business use only on shipping documents.
The use of registration symbols is not required for making FSC claims on invoices. The
scope of the trademark requirements specifies that these are not affected by the trademark
requirements.
54. Is it still optional to omit the TM symbol if a product is also being distributed to coun-
tries where the trademarks are fully registered? So, something going to Europe and
one country where trademarks are not registered, could have no symbol on the la-
bel?
If products are distributed to countries with and countries without registration, it is recom-
mended to use TM, but this is not required. It is also possible to use no symbol.
Label generator
55. Will members of chain of custody groups get own licenses, or at least own logins,
for the trademark portal?
We do have a project aimed at giving group managers the possibility to create and manage
access to the trademark portal for their group members. In addition, the licensing system is
being reviewed in the coming months. We will be able to provide you with more information
on both of these projects early next year.
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56. Please can you include me in the reply regarding the possibility to manage user
login and password generation for the logo generator for a multi-site certificate
holder?
All group managers will be informed when this option is being released.
Online training course
57. How will certificate holders be informed about the online training course? And how
can national offices help to communicate this to the certificate holders in our coun-
try?
We will inform stakeholders through our usual channels – the website, email forums and
newsletters. Certification bodies and national offices will be informed directly and provided
with news item templates to distribute to their clients.
58. Are the dates for the FSC training for the new standard version already set?
Yes, we aim to publish the online training courses in March 2018. The project is already un-
der way.
Webinar attendance and materials
59. Could I have a certificate of attendance?
If you need a certificate, please send an email to trademark@[Link] with full contact infor-
mation and we will send you a certificate.
60. Will this presentation be made available after the webinar? Can we please have a
copy of this presentation, to use as a training aid for others in our team?
The webinar will be published online, and participants will receive a copy of the presenta-
tion, with questions and answers after the webinar. There are also three other webinars of-
fered by FSC after this one, if your colleagues would like to join one themselves. Registra-
tion can be found here.
61. Is this conversation being recorded?
The conversation part is not being recorded as part of the presentation video. All questions
and answers are recorded in written format in this document.
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62. Will there be a webinar for certificate holders, like this one for certification bodies?
These webinars are intended for all stakeholders. In fact, almost half of the participants of
this webinar are certificate holders. In addition, many FSC national offices are arranging
meetings to introduce the new requirements.
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