2014 policy cycle changes

MSC policies are reviewed following the policy development process and in consultation with stakeholders.

At each meeting of the MSC Technical Advisory Board (TAB) and Board of Trustees (BoT), changes to MSC’s certification requirements (CR) and other aspects of the program are considered. Below is a list of recent policy changes approved by the TAB and the Board and subsequently implemented.

A new version of the MSC CR (version 1.4) reflecting the Chain of Custody (CoC) changes in parts A and B was issued on 31 January 2014. This will become effective on 31 March 2014. All scheme documents are available at  current scheme requirements

For more information about any of the work described below check the improvement database, or contact standards@msc.org.

 

Recent Chain of Custody policy developments

  1. Chain of Custody Checklist
  2. Chain of Custody Suspension Process
  3. MSC Generated Chain of Custody Codes
  4. Multi-site Chain of Custody Certification
  5. Certifier Communication of Changes
  6. Review of Sub-contractor Requirements
  7. Scope of Chain of Custody (Phase 2)

 

Chain of Custody Checklist

Sections amended

  • 17.4.5.3 – new
  • 17.5.4 – new
  • BA1.1 – changed
  • BA1.2 – changed
  • BA1.3 – deleted
  • BA1.4 – new
  • Table BA1 – delete

Summary

The MSC CoC audit checklists will now become mandatory for all CABs to use during CoC audits. Two checklist templates are available to download:

  • Single / multi-site CoC checklist
  • Group CoC checklist

The new version of the MSC Certification Requirements (CR) version 1.4 will include a requirement that the MSC CoC audit checklists are mandatory for all CABs.

Chain of Custody Suspension Process

Sections amended

  • Self-declaration of mislabeling or non-conforming products

Clause 7.4 of MSC CR v 1.4

  • Procedure for handling non-conforming products

Section BD9 of the Annex BD of MSC CR v 1.4

  • New Guidance for definition of systematic breach of the Chain of Custody

CR Guidance Section G7.4 suspension or withdrawal of certification

    Summary

    • Self-declaration of mislabeling or non-conforming products

    New CR changes specify that companies which self-declare non-conforming product issues will not automatically have their certificate suspended, subject to specific requirements. This would apply to cases where companies identify mislabelling within their own operations and also cases where companies are notified by their supplier of having received non-conforming product.

    • These changes would require companies that self-report non-conforming product to follow the defined non-conforming product procedure
    • If the Conformity Assessment Body (CAB) verifies that corrective actions are sufficient and the non-conforming product procedure has been fully followed, the certificate shall not be suspended
    • If further corrective actions are required, these corrective actions shall be verified by the CAB within 30 calendar days
    • Procedure for handling non-conforming products

    CR changes require certified companies to have an implemented process for handling non-conforming product. This would require companies to:

    • Notify their CAB
    • Cease to sell any non-conforming products in stock as MSC certified until its certified status has been verified by the CAB
    • Product which cannot be verified as coming from a certified source – relabel or repack this product to ensure it is not sold with the ‘MSC-certified’ claim or ecolabel
    • If non-conforming product has already been sold or shipped as MSC, the company must notify all affected customers within 2 days, informing customers of the issue

    MSC Generated Chain of Custody Codes

    Sections amended

    • Clause 7.5.1.2
    • Clause 17.3.1.2

    Summary

    Following public consultation, the MSC’s TAB and the BoT have approved this proposal for MSC to introduce MSC-generated CoC codes. These codes will eventually replace the existing certifier-generated codes, and companies will have three years to transition packaging and other materials displaying their previous CoC codes. During this period, both old codes and new codes will be searchable and valid on the MSC Find a Supplier website.

    Multi-site Chain of Custody Certification

    Sections amended

    • Annex AA – new definition of multi-site
    • 17.2.4.2 – new (and relative sub-clauses)

    Summary

    A new definition of multi-site was introduced in the CR:

    Multi-site: Two or more sites that are individually audited and that share a CoC certificate.

    New requirements were added to section 17.2 of the CR specifying how CABs should document and audit multi-sites:

    • CABs must assess each site of the multi-site against the requirements under 17.1 (Need for certification)
    • Sites that only do trading can be remotely audited
    • CABs can issue or renew a multi-site certificate only after all sites have been audited
    • All sites that are part of the multi-site certificate must be recorded on the MSC database
    • CABs must define the scope of each site and audit accordingly
    • Where two or more legal entities apply for a multi-site certificate, the CAB is required to sign a contract with all legal entities.

    Certifier Communication of Changes

    Sections amended

    CR 7.3.2

    Summary

    Following public consultations, the MSC’s TAB and the BoT have approved the introduction of a new requirement  that CABs shall, in the case of an amendment to the MSC Standards or MSC CR, communicate this to their certificate holders within 60 days. The MSC shall provide standardised wording that the CAB can use.

    Review of Sub-contractor Requirements

    Sections amended

    Section BD4 of Annex BD of MSC CR v 1.4

    Summary

    CR changes specify that companies using contract processors and companies providing contract processing services are required to keep records of contract processed products:

    • Volumes and product details
    • Dates of dispatch and receipt
    • Consignment or financial documents

    They must also be able to conduct reconciliation of the volumes input/outputs (at least one batch shall be selected if non-certified contract processor used)

    New requirements replace some previous requirements for contract processing what include:

    • No requirement to keep the records of packaging
    • Requirement to provide a mass balance for each non-certified contract processor is removed as  replaced with new change

    The MSC-audit checklist  is modified to ensure the records  are verified by certifiers and to provide the guidance to the certifiers how to audit companies against subcontractors requirements

    Scope of Chain of Custody (Phase 2)

    Sections amended

    Annex BD and section 17

    Summary

    Following public consultation, the MSC’s TAB and the BoT have approved this proposal to reduce scope categories of information further to activities and species only.