We are now seeing review comments about millwork or casework subs not having FSC certification.

The reference manual, the addenda and the definition provided on this website all suggest that it is the Vendor who is subject to certification. Since 2010 the definition has been: "Entities that install an FSC-certified product on the project building/site (typically project contractors or subcontractors, but also furniture installers and the like), do not require CoC certification as long as they do not modify the product's packaging or form except as is required for installation."

Up until recently our casework/millwork subs were installers not vendors. When did this change? If our millwork sub comes on-site with his FSC trim and cuts it to fit, does he need to be certified? What constitutes modification beyond installation? Do furniture installers and general contractors now need to be certified also?

Does this all have more to do with including the whole assembly as a dollar value as opposed to just the wood component part of the assembly since the assembly value as a whole is going to come from the sub and not the suppliers? What if we are only claiming the supplier dollars and not the "value added" assembly dollars?

Sadly as LEED consultants in the Pacific Northwest where sustainable wood is a big deal, this credit is so difficult to document to GBCI reviewers' satisfaction that we can't currently recommend it to our clients as being worth their cost and effort. Whether they do the right thing or not. Clarity on this issue would help a lot.