FAQ's regarding the LEED® "Certified Wood Credit"
Please note: These questions and answers relate specifically to earning the certified wood credit in the LEED green building rating system. For help in finding FSC-certified building products, please visit www.findfsc.org. For additional questions about LEED, please visit www.usgbc.org.
Q: WHAT ARE THE CURRENT REQUIREMENTS FOR DOCUMENTING THE USE OF FSC-CERTIFIED WOOD IN LEED?
As of July 19th, 2010, the United States Green Building Council (USGBC) published several addenda relating to the MRc7 credit for FSC certified wood which can be found here. The addenda clarify two important issues relating to who needs to be FSC certified and partial claims:
- Organizations that install an FSC-certified product or products on the project building/site (typically project contractors or subcontractors such as flooring installers or framing contractors, but also furniture installers and the like) do not require FSC CoC certification as long as they do not modify the product’s packaging or form except as is required for installation. All other organizations will need to be FSC CoC certified in order for the certified wood products they fabricate and install to count toward MRc7. This includes organizations like cabinetmakers and architectural millworkers that manufacture products off-site and then install them on-site (even if considered a subcontractor).
- No partial claims can be made for products that contain FSC certified wood but are not sold with an FSC claim. This means that a company cannot mix FSC-certified components with non-certified components that are not eligible inputs into FSC Mixed products in an assembly and get credit for the certified portion. The product can only count towards the MRc7 point if the product complies with FSC Chain-of-Custody rules for Mixed products and the invoice carries a valid FSC claim and chain of custody number.
Both clarifications further align the USGBC LEED documentation requirements with the FSC CoC standard.
As of April 2008, the guiding language approved by the USGBC Materials and Resources Technical Advisory Group (MR TAG) for documenting the use of FSC-certified wood across all LEED rating systems — commercial (i.e. LEED-NC and LEED-CI) as well as residential (LEED for Homes) — is as follows:
All vendor invoices for permanently installed wood products, including FSC-certified and non FSC-certified, products purchased by the project contractor and subcontractors must be compiled. Vendors are defined as those companies that sell products to the project contractor or subcontractors.
The cost of all wood products, both FSC-certified and non-FSC, must be tallied on the appropriate LEED document (e.g., MRc7 template). Wood products that are not FSC-certified and those that are identified on invoices as “FSC Pure” and “FSC Mixed Credit” are to be valued at 100% of the invoiced product cost. Wood products identified as “FSC Mixed [NN]%” should be valued at the indicated percentage of their cost, e.g., a product identified as “FSC Mixed 75%,” should be valued at 75% of the cost.
Each vendor invoice must conform to the following requirements (except as noted in the Appendix under ‘Exceptions’):
- Each wood product must be identified on a line-item basis;
- FSC-certified products must be identified as such on a line-item basis;
- The $ value of each line item must be shown;
- The vendor’s chain-of-custody (CoC) certificate number must be shown on any invoice that includes FSC products.
Note that this means that each wood products vendor that invoices FSC-certified products must be CoC-certified by an FSC-accredited certification body.
Wood products identified as “FSC Recycled” or “FSC Recycled Credit” are not to be counted on the MRc7 template. These products qualify instead under MRc4 – Recycled Content.
Exceptions.In some rare instances, it may not be practical for a vendor to invoice wood products on a line-item basis because the invoice would be dozens of pages long. In such cases, the invoice should indicate the aggregate value of wood products sold by the vendor. If the wood products are FSC certified:
- The vendor’s CoC number must be shown on the invoice;
- The invoice must be supplemented by a letter from the vendor stating the products invoiced are FSC certified.
- The invoice or the letter must state whether the products are “FSC Pure,” “FSC Mixed Credit,” or “FSC Mixed,” followed by a percentage. Wood products identified as “FSC Pure” and “FSC Mixed Credit” are valued at 100% of their cost. Wood products identified as “FSC Mixed [NN]%” are valued at the stated percentage of their cost.
Q: HOW ARE THESE REQUIREMENTS DIFFERENT FROM HOW THINGS WORKED BEFORE?
Prior to the adoption of this revised language, FSC rules and LEED requirements were out of sync with respect to the extent of chain-of-custody certification required. Previously, LEED distinguished between products that were individually labeled and those that were not: For individually-labeled products, the manufacturer’s CoC number was required; for products that were not individually labeled, the required CoC number was that of the company supplying wood products to project contractors and subcontractors.
FSC does not make this distinction; it requires that all companies that take legal ownership of FSC products and produce, sell, promote, or trade them be certified for CoC. The fact that FSC rules and LEED requirements were out of sync created confusion in the supply chain for LEED projects. The intention of the new requirements is to eliminate this confusion.
In addition, according to previous LEED requirements, the only required documentation was a CoC certificate number, but that alone is insufficient to demonstrate compliance with credit requirements. There are two reasons for this. First, a CoC certificate gives a company the right to produce, sell, promote, or trade FSC-certified wood products, but it does not mean that company is actually doing so. Second, because the credit calculation is based on the cost of both FSC and non-FSC products, itemized cost information was needed. The revised language therefore focuses on vendor invoices that show both a valid CoC certificate number and line items indicating which products are FSC-certified.
Q: WHY ARE PRODUCTS THAT ARE IDENTIFIED ON VENDOR INVOICES AS “FSC Mixed [NN]%” VALUED LESS THAN PRODUCTS THAT ARE IDENTIFIED AS “FSC Pure” OR “FSC Mixed Credit,” WHICH ARE VALUED AT 100%?
The most recent FSC Chain of Custody Standard (FSC-STD-40-004 V2) establishes that FSC Pure products are made entirely of wood or fiber originating from FSC-certified forests, while FSC Mixed products combine FSC-certified material, controlled wood, and/or reclaimed material.
FSC Mixed products fall into two categories:
- Products invoiced on a line-item basis as “FSC Mixed [NN]%.” In these cases, the product or products contain the indicated percentage of FSC material.
- Products invoiced on a line-item basis as “FSC Mixed Credit.” This indicates that the products were manufactured under the “Credit System,” in which a percentage of a production batch, corresponding to the percentage of the input that is FSC certified, may be sold as “FSC Mixed Credit.” The specific product invoiced as “FSC Mixed Credit” may not itself contain FSC material, but the overall amount of fiber in that batch sold as FSC corresponds directly to the FSC certified total input.
The logic for valuing FSC Pure products at 100% is obvious, as they do, in fact, contain 100% FSC-certified wood.
“FSC Mixed Credit” products are also valued at 100% because the amount of material carrying this label corresponds to the amount of FSC material in the production batch, representing a “pass-through” of FSC-certified material: if 90% of inputs into the production batch are FSC certified, then 90% of the products that come out can be sold as FSC certified. The remainder of 10% can not be sold with an FSC claim.
Products labeled “FSC Mixed [NN]%” are valued at the indicated percentage since that is how much FSC certified wood went into that product production run, i.e., the percentage of actual FSC certified content, because this is consistent with past LEED practice and the intent of the Certified Wood credit.
Q: MUST THE INSTALLING FABRICATOR OR CONTRACTOR HAVE AN FSC CoC CERTIFICATE IN ORDER TO COMPLY WITH LEED's MRc7 CREDIT REQUIREMENTS?
Yes! Note this is a change of interpretation that is noted in the July 19th addenda issued by the USGBC.Previously the USGBC stated the installing fabricator or contractor did not have to hold a valid FSC CoC certificate to comply with LEED’s MRc7 credit although it was an added benefit. Now, the installing fabricator or contractor will need to be FSC CoC certified in order for their products to count towards the MRc7 credit if they modify the product’s packaging or form besides for what is required for installation.