Manufacturer and Vendor COC and Correct invoice format

For MRc7 documentation invoice must indicate manufacturer COC number and type of FSC certification (100%, mixed XX%) of each wood product, the number of FSC certificate is not required.
In a similar situation we uploaded on leedonline invoices of manufacturer (COC type of FSC certification, product cost), and both those of vendor (link between manufacturer and project).

Giorgia - LEEDme

If the vendor doesn't have FSC CoC, then the chain is broken and the doors can't count toward MRc7 -- even if they are simply a distributor or trader and didn't modify the product in any way.

FSC rules require that all invoices for FSC-certified products include the certificate holder's CoC code as well as what Giorgia called "the type of FSC certification" (e.g. FSC 100%, FSC Mix 70%, FSC Mix Credit, etc.) In FSC lingo, this is known as an FSC claim. If the manufacturer's invoice doesn't include both of these key elements -- the CoC code and an FSC claim or claims for the certified products they are selling -- then they are out of compliance with the FSC CoC standard, and are likely to have problems during their next CoC audit. It would be best if they were proactive in addressing the non-conformance by updating their systems and issuing a corrected invoice.

Thak you Jason for terminology clarification.

The vendor to which I have referred only made installation.
In USGBC addenda+ errata database I can find 10/01/2012: A chain-of-custody certification is not required by distributors of a product that is individually labeled with the Forest Stewardship Council logo and manufacturer's chain-of-custody number.
In addition there is the addenda dated 07/19/2010.

Giorgia - LEEDme

I couldn't find the addenda dated 07/19/2010. I did find the 10/12/2012 addenda that you referenced which reads:

Replace the definition of "chain-of-custody (COC)" with "the path taken by raw materials, processed materials, and products from the forest to the consumer, including all successive stages of processing, transformation, manufacturing and distribution. A chain-of-custody certificate number on invoices for nonlabeled products indicates that the certifier's guidelines for product accounting have been followed. A chain-of-custody certification is not required by distributors of a product that is individually labeled with the Forest Stewardship Council logo and manufacturer's chain-of-custody number. Chain of Custody (CoC) certification requirements are determined by Forest Stewardship Council Chain of Custody Standard 40-004 v2-1."

Unfortunately, this definition contains an internal contradiction, because the FSC CoC standard in question does not exempt all distributors of labeled products from CoC requirements; it only exempts retailers who sell to end consumers at the end of the distribution chain. Wholesale distributors who supply other companies down the chain still need FSC. In short, this is an error, and if this addenda is still applicable and hasn't been superseded by something more recent, then it needs to be corrected.

The LEED v4 Reference Guide which is the most recent attempt I know of to establish the rules for crediting FSC-certified wood in LEED projects does not perpetuate this error. On pg. 533, in the section on FSC Chain of Custody, it reads:

"CoC certification requirements are established by the FSC CoC Standard 40-004 v2.1... Every entity that processes or trades FSC-certified material before it is shipped to the project site must have FSC CoC certification. On-site installers of FSC-certified products must have CoC certification only if they modify the projects off the project site."

and then in the section on Documenting FSC Claims, it reads:

"Project teams must document FSC certification for all wood products that contribute to credit achievement. FSC-certified products qualify for credit only when purchased from a vendor with an FSC CoC certificate that is current at the time of sale. The vendor is defined as the company that sells products to the project contractors and subcontractors who do not modify the products off site."

From your description, the vendor in question is a project subcontractor who installed the doors and didn't alter them off site, so they do not need to have FSC CoC.

I fully agree. A project subcontractor who installed the doors and didn't alter them off site do not need to have FSC CoC.

Giorgia - LEEDme

Yes…If the “vendor” referred to in the original question is the installing contractor, the chain of custody is not broken. Nevertheless, FSC invoices are required as proof that certified goods were purchased & delivered.

On its own, the manufacturer’s CoC Certificate is not enough. Sometimes, a manufacturer that has a CoC Certificate makes both FSC-Certified and non-certified products. If Certified products were purchased, the invoices for those items should have included the FSC claim and the manufacturer’s CoC number, identifying the end-user (building owner or contractor) as the buyer.

If the installing contractor ordered FSC-Certified doors, and the manufacturer has erred by omitting the required information, the manufacturer must reissue a corrected invoice.

On the other hand, if the contractor ordered doors, but neglected to stipulate FSC-Certified doors, the manufacturer probably furnished ordinary, uncertified doors and their invoice would be missing the FSC & CoC information. If this is what happened, there is no chain of custody, and the doors count against MRc7.

Without proper FSC invoices from the manufacturer, you have no proof to show LEED reviewers that your project actually purchased FSC doors.

If the vendor invoices do not itemize FSC products, MRc7 requires a letter from the vendor to fill in the gaps. The letter & invoice must comply with the “Exception” described at the very end of the “Chain-of-Custody Requirements” section of the LEED-2009 BC+C Reference Guide:

“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, comply with the following requirements:
a. The vendor's COC number must be shown on the invoice.
b. The invoice must be supplemented by a letter from the vendor staring that the products invoiced are FSC certified.
c. The invoice or the letter must state whether the products are FSC Pure [FSC-100%], FSC Mixed Credit [FSC-Mix Credit], or FSC Mixed (NN)% [FSC-Mix-NN%].”

Therefore, even if you get a letter from the manufacture, they may also need to resubmit a revised invoice that reports their COC number (Item a, above)