Common non-conformities in FSC® and PEFC Audits: Insights from the Middle East

This article highlights some of the common nonconformities normally raised during sustainability audits, drawing on SGS's extensive audit experience across the Middle East. These insights are derived from a significant volume of FSC and PEFC audits conducted across multiple countries and industry sectors, giving SGS clear visibility into the recurring trends and challenges observed in certified organizations.

The mainly recognized standards in this region are FSC and PEFC. These standards are laid out in a clear manner, and industries can implement the requirements without much difficulty based on their scope of certification. However, during audits, the nonconformities observed are generally not due to lack of implementation, but due to gaps in awareness and understanding of the requirements.

Understanding FSC and PEFC Certification

Forest Stewardship Council® - (FSC®) and the Programme for the Endorsement of Forest Certification (PEFC) are the two leading schemes for responsible forest management. Both set requirements that protect forests, support the rights of workers and communities, and verify that products originate from responsibly managed sources.

As sustainability expectations continue to rise across the GCC, FSC and PEFC offer an internationally recognized way to demonstrate responsible sourcing.

FSC is a global, not-for-profit organization dedicated to the promotion of responsible forest management worldwide. FSC defines standards based on agreed principles for responsible forest stewardship that are supported by environmental, social, and economic stakeholders. To learn more, visit FSC website [www.fsc.org]

PEFC is an international forest certification system that provides a framework for the endorsement of national certification schemes based on sustainable forest management requirements. It is used to verify that forest-based products originate from responsibly managed forests through independent third-party certification across a wide range of countries. To learn more, visit PEFC website [www.pefc.org]

For businesses in the Middle East, certification is increasingly important. It helps meet customer and procurement requirements, opens access to international markets, supports ESG and sustainability objectives, and strengthens supply chain transparency, traceability and brand reputation. We are accredited to deliver this certification. You can view SGS accreditation here.

Common Nonconformities Observed in Audits

Based on SGS's audit experience across the region, a number of recurring nonconformities continue to emerge during FSC and PEFC audits. These findings are typically linked to gaps in understanding, interpretation and operational control. The following sections highlight some of the most commonly observed areas and how organizations can address them.

FSC and PEFC Claims

One of the most observed areas is related to FSC and PEFC claims. Compared to other schemes, the terms used are not general, and many organizations still face confusion in handling claims during receiving, production, invoicing and selling activities.

Weak understanding of receiving claims from suppliers and issuing incorrect selling claims to customers often leads to multiple audit findings. Incorrect claims can invalidate the certified status of a product and mislead customers.

For example, you could imagine  a packaging manufacturer that receives material carrying an FSC Mix Credit claim but issues invoices stating FSC 100% cannot substantiate the claim it has made, resulting in a nonconformity that may also affect product already shipped.

It would be useful for organizations to understand the meaning of specific terms, and to verify output claims against supplier inputs through documented procedures and practical training.

Supplier Validation

Supplier validation is another recurring issue. In several cases, supplier certification status is not properly verified, validity status is not regularly checked, or records are not maintained correctly.

Since certified sourcing depends on valid supplier verification, this continues to be a common area of nonconformity. Consider a wood products manufacturer sourcing material from multiple suppliers across different countries. If supplier documentation is not consistently reviewed and maintained, the organization may be unable to demonstrate chain of custody compliance during an audit.

Organizations should verify each supplier's certificate status against the relevant FSC or PEFC database before purchasing and at regular intervals thereafter, and retain dated evidence of each check.

Material Accounting and Volume Control

Material accounting and volume control also remain key concerns during audits. Poor understanding of conversion factor calculations affects production accounting and traceability.

This often results in gaps in certified volume reconciliation and material balance records. Without accurate volume control, an organization cannot reliably demonstrate that the certified material it sells corresponds to the certified material it purchased.

Consider a sawmill that converts certified logs into sawn timber: if it applies an inaccurate yield factor, it may record more certified output than the input volume can support, creating a discrepancy that becomes evident during volume reconciliation at audit.

Organizations should establish realistic conversion factors based on their actual production process, review them periodically, and maintain a clear material balance that reconciles certified inputs against certified outputs.

Core Labor Requirements under FSC

Core labor requirements under FSC have become another important focus area. FSC requirements related to core labor principles require organizations to review their existing workplace practices, align procedures with national law, and update employee-related policies. Many organizations have implemented labor practices, but gaps are still observed where the requirements are not fully aligned with FSC expectations.

At the same time, organizations addressing these findings often show positive improvements in human resources practices, worker wellbeing facilities and workplace culture. Industries that are already familiar with social accountability or social compliance systems generally adapt more easily to these requirements.

To close these gaps, organizations should review existing policies against the specific FSC™ requirements and update any provisions that are missing or only partially addressed.

Trademark Usage

Trademark usage is also a frequently observed area of nonconformity. Both FSC and PEFC have specific requirements for the use of logos and trademarks on products and promotional materials. Although organizations are generally aware of these rules, shortcuts in logo usage, incorrect promotional claims or unapproved artwork still result in findings during audits. In some situations, organizations assume that certification itself automatically allows logo usage in all forms, which is not always acceptable under trademark requirements.

The benefit of having sustainability schemes within the organization is not fully realized due to lack of understanding, and organizations often find this a challenge.

FSC and PEFC provide guidance tools on their websites and confirming the best approach with your certification body like SGS can be helpful in this regard. Organizations should submit artwork for approval where required and confirm that any labeled product genuinely falls within the certified scope.

Overall, many of the nonconformities observed in FSC and PEFC audits are closely linked to awareness, interpretation of standard requirements and how they are integrated into operational control.

The organizations that perform best treat compliance proactively and address the root cause of a finding rather than only correcting the immediate issue. Continuous understanding of the requirements, internal awareness and training, robust management systems and proper internal monitoring remain important for maintaining the integrity of certification systems.

Viewed in this way, audit findings become opportunities to strengthen certification performance rather than problems simply to be closed.

About SGS

SGS is the world’s leading Testing, Inspection and Certification company. We operate a network of over 2,500 laboratories and business facilities across 115 countries, supported by a team of over 100,000 dedicated professionals. With more than 145 years of service excellence, we combine the precision and accuracy that define Swiss companies to help organizations achieve the highest standards of quality, compliance and sustainability.

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