Conformity assessment of UFCS against PEFC (2010).pdf - ITS Global

Conformity assessment of the 

Uruguayan Forest Certification 

Scheme against the requirements 

of the PEFC Council 

ITS Global 

Final Report 

20 October 2010

ITS GLOBAL 

International Trade Strategies Pty Ltd, trading as ITS Global 

Level 26, 35 Collins Street, Melbourne, 3000 

Tel: (61) 3 9654 8323 

Fax: (61) 3 9654 4922 

http://www.itsglobal.net 

Commercial-in-confidence. The views expressed in this publication are those of its authors. The consultant takes no 

liability for commercial decisions taken on the basis of information in this report. The information is accurate to the 

best of the consultant’s knowledge, however the consultant advises that no decision with commercial implications 

which depends upon government law or regulation or executive discretion should be taken by any person or entity 

without that party’s having secured direct advice from the government agency concerned in writing.

Evaluation and assessment of Uruguayan Forest Certification scheme against the requirements of the PEFC Council 

Preface 

The Programme for the Endorsement of Forest Certification Schemes Council (PEFCC) engaged 

ITS Global on 14 April 2010, to evaluate and assess the Uruguayan Forest Certification Scheme 

(UFCS) against requirements of the PEFC Council. 

The UFCS was submitted for assessment to the PEFCC by President (Dr Gerardo Barios) and Vice- 

President (Dr Alvaro Molinari) of PEFC Uruguay on 8 January 2010. 

This conformity assessment report has been prepared consistent with PEFCC’s guidelines in 

PEFC Council Technical Document 6/2007 (Content of the Consultant’s Assessment Report for 

Forest Certification Schemes). The following report details the findings of the evaluation, public 

comments and field visit, identifying areas of compliance and non compliance with PEFC 

requirements. 

Contact details for Consultants: 

Mr Zak Levick 

Dr Bob Smith 



(International Trade Strategies P/L) 

(International Trade Strategies P/L) 

Level 1, 34 Queen Street 

Level 1, 34 Queen Street 

Melbourne VIC 3000 Melbourne VIC 3000 

Australia 

Australia 

z.levick@itsglobal.net 

bobsmith12@ozemail.com.au 

Ph: +61 – 418 648 228 

www.itsglobal.net Page 3


Contents 

Preface ............................................................................................................ 3 

Contents ........................................................................................................... 4 

Acronyms .......................................................................................................... 6 

Executive Summary .............................................................................................. 7 

Recommendation to PEFC Council Board of Directors ................................................. 7 

Summary of findings ......................................................................................... 7 

1. Introduction ................................................................................................... 9 

Scope of assessment ......................................................................................... 9 

Assessment process and methodology for Report ...................................................... 9 

2. History and Structure of the Uruguayan Forest Certification Scheme (UFCS) .................... 10 

2.1 Development of Sustainable Forest Management Standard ..................................... 10 

2.2 Organisational structure of UFCS .................................................................... 12 

2.3 Documentation .......................................................................................... 12 

3. Assessment of the standard setting process for UFCS against PEFCC requirements ............. 14 

3.1 Standard setting process for forest management certification ................................ 14 

3.1.1 Independence...................................................................................... 14 

3.1.2 Participatory process ............................................................................. 15 

3.2 Standards for chain of custody certification ....................................................... 20 

3.3 Pilot testing .............................................................................................. 20 

3.4 Review of standards .................................................................................... 21 

3.4.1 Periodic review .................................................................................... 21 

4. Assessment of the implementation of UFCS against PEFCC requirements ........................ 23 

4.1 Criteria for forest certification ...................................................................... 24 

4.1.1 General requirements ............................................................................ 24 

4.1.2 Other requirements for forest management criteria ....................................... 24 

4.1.3 Laws and regulations ............................................................................. 25 

4.1.4 International Labour Organization (ILO) conventions ...................................... 25 

4.1.5 Other international conventions ............................................................... 26 

4.2 Level of application and implementation (Annex 3, 4) .......................................... 26 

4.2.1 General ............................................................................................. 26 

4.2.2 Regional Certification ............................................................................ 27 

4.2.3 Group Certification ............................................................................... 27 

4.2.4 Individual Certification .......................................................................... 29 

4.2.5 Implementation of changes to the scheme................................................... 29 

4.3 Appeals, complaints and dispute procedures (Annex 3, 6) ...................................... 29 

4.4 Overall Assessment ..................................................................................... 30 

5. Assessment of UFCS forest management standards against PEOLG ................................ 31 

5.1 Assessment Framework ................................................................................ 31 



5.2 Compatibility of the UNIT 1152: 2009 Standard with PEOLG ................................... 31 

5.2.1 Criterion 1 – Maintenance and appropriate enhancement of forest resources and their 

contribution to global carbon cycles .......................................................... 31 

5.2.2 Criterion 2 – Maintenance of forest ecosystem health and vitality ...................... 32 

5.2.3 Criterion 3 – Maintenance and encouragement of productive functions of forests 

(wood and non-wood) ............................................................................ 34 

5.2.4 Criterion 4 – Maintenance, conservation and appropriate enhancement of biological 

diversity in forest ecosystems .................................................................. 35 

5.2.5 Criterion 5 – Maintenance and appropriate enhancement of protective functions in 

forest management (notably soil and water) ................................................ 36 

5.2.6 Criterion 6 – Maintenance of other socio-economic functions and conditions ......... 37 

5.7 Overall assessment ..................................................................................... 38 

6. Assessment of UFCS chain of custody standard against PEFCC requirements .................... 39 

7. Assessment of the logo usage rules against PEFCC requirements ................................... 40 

8. Assessment of UFCS certification and accreditation arrangements against PEFCC requirements 

..................................................................................................................... 41 

8.1 Certification bodies .................................................................................... 41 

8.1.1 Competence of certification bodies ........................................................... 41 

8.1.2 Auditors ............................................................................................. 42 

8.2 Certification procedures .............................................................................. 42 

8.3 Accreditation ............................................................................................ 44 

8.4 PEFC Notification of Certification Bodies .......................................................... 45 

8.5 Overall Assessment ..................................................................................... 45 

Annex 1. Comments submitted to ITS Global during public consultation period .................... 47 

Annex 2. Report on the field visit ........................................................................... 48 

Annex 3. PEFC Council minimum requirements checklist ............................................... 51 

Annex 4. Panel of Expert Review 71 



Acronyms 

Chain of custody 

CoC 

Convention on Biological Diversity 

CBD 

General Document 

GD 

Instituto Uruguayo de Normas Técnicas 

UNIT 

International Accreditation Forum 

IAF 

International Electrotechnical Commission 

IEC 

International Organisation for Standardisation 

ISO 

International Labour Organization 

ILO 

Memorandum of Understanding 

MOU 

National Governing Body 

NGB 

Non-government Organisation 

NGO 

Not applicable 

NA 

Pan European Operational Level Guidelines for Sustainable Forest Management PEOLG 

Programme for Endorsement of Forest Certification Schemes 

PEFC 

Programme for Endorsement of Forest Certification Schemes Council 

PEFCC 

Quality Management Systems 

QMS 

Specialized Technical Committee on Sustainable Forest Management 

STC-SFM 

Sustainable Forest Management 

SFM 

Systems Document 

SD 

Uruguayan Forestry Certification Scheme 

UFCS 

Uruguayan Organisation of Accreditation 

OUA 

Uruguayan Society of Forestry Producers 

SPF 



Executive Summary 

Recommendation to PEFC Council Board of Directors 

The Uruguayan Forest Certification Scheme (UFCS), as presented by PEFC Uruguay on 8 January 

2010, together with supporting documentation (refer to 2.3 of this Report), does not meet the 

requirements of the Programme for the Endorsement of Forest Certification (PEFC) Scheme. 

The UFCS has several incidences of non-conformity, further detailed in parts 1(b), 1(c), 2(b), 

5(c) and 5(d) of Summary of Findings. 

The consultants consider that the identified non-conformities, with exception of 1(b), do not 

hamper creditable and reliable UFCS implementation consistent with PEFCC requirements. The 

consultants base this conclusion on detailed commentary included in the body of the following 

report. The consultants recommend that PEFCC consider the option of conditional endorsement 

of the UFCS, subject to PEFCC approval of the organisational and individual participation 

arrangements implemented by Instituto Uruguayo De Normas Técnicas (UNIT) to develop and 

approve forest management standards (UNIT 1151: 2009 and UNIT 1152: 2009). 

Summary of Findings 

The justification for endorsement is based on the following findings: 

1. For standard setting processes – initiated by the Uruguayan Society of Forestry Producers 

and managed by Instituto Uruguayo de Normas Técnicas (UNIT) - against PEFCC 

requirements: 

a. Independence processes conform with PEFCC requirements (refer to Section 3.1.1); 

b. Participatory processes do not conform to PEFCC requirements. Documentation 

presented by PEFC Uruguay and the Instituto Uruguayo De Normas Técnicas (UNIT) does 

not provide evidence that environmental non-government organisations were formally 

invited to participate in development and approval of forest management standards (as 

detailed in Section 3.1.2 and 3.5 of Report); 

c. Public consultation processes do not conform to PEFCC requirements. The public 

consultation processes implemented by UNIT for final draft of forest management 

standards (as detailed in Sections 3.1.2 and 3.5 of Report) was less than 60 days 

specified in PEFCC requirements; 

d. Pilot testing practices conform with PEFCC requirements (refer Section 3.3); 

e. Review of standard documentation conforms to PEFCC requirements (refer to Section 

3.4). 

2. For implementation of the UFCS against PEFCC requirements: 

a. General requirements of the UFCS in areas such as types of forests, management 

systems, auditing verification, property and land tenure, and customary and traditional 

rights conform with requirements of PEFCC (refer to Sections 4.1.1 and 4.1.2); 

b. Documented process for the UFCS do not conform with PEFCC requirements for making 

a summary of forest management plan publicly available (as detailed in Section 4.1.2 of 

Report); 

c. Required compliance with laws and regulations conform to PEFCC requirements (refer 

to Section 4.1.3); 

d. Level of implementation for individual and group forest certification processes for the 

UFCS conform with PEFCC requirements (refer to Section 4.2); 

e. Appeals, complaints and dispute procedures documented for the UFCS conform to 

PEFCC requirements (refer to 4.3). 

3. The forest management standards (UNIT 1151: 2009 and UNIT 1152: 2009) conform to 

PEFCC requirements for compliance with Pan European Operational Level Guidelines for 

Sustainable Forest Management (PEOLG) (refer to Section 5). 



4. The chain of custody (utilizes requirements of PEFC Annex 4) and logo use (utilizes 

requirements of PEFC Annex 5) arrangements for the UFCS conform to PEFC requirements 

(refer to Sections 6 and 7). 

5. For certification and accreditation arrangements used by the UFCS: 

a. Competencies required for certification bodies conform to PEFCC requirements. (Refer 

to Section 8.1.1) 

b. Competencies required of auditors conform to PEFCC requirements (Refer to Section 

8.1.2). 

c. Accreditation arrangements do not conform to PEFCC requirements. Currently there is 

no explicit requirement for the accreditation symbol of OUA, the Uruguayan 

organisation with authority to accredit certification bodies in the UFCS, to appear on 

accredited certificates from certification bodies (refer to Section 8.3). 

d. PEFC notification of certification bodies do not conform to PEFCC requirements. 

Current UFCS documentation does not include all notification requirements of PEFCC. 

(Refer to Section 8.4) 



1. Introduction 

In a letter dated 8 January 2010, the President and Vice President of PEFC Uruguay submitted 

an application to PEFCC (Programme for the Endorsement of Forest Certification Council) for 

the conformity assessment of the Uruguayan Forest Certification Scheme (UFCS). 

On 14 April 2010 the PEFCC appointed ITS Global to undertake an independent conformity 

assessment of the UFCS against the requirements of PEFCC. 

Scope of Assessment 

The conformity assessment of the UFCS was undertaken consistent with PEFCC minimum 

requirements for national and sub-national schemes as detailed in PEFCC Technical Document, 

Annex 7. 

Following a summary of the development and evolution of the UFCS (Chapter 2) the report 

assesses the conformity of UFCS against the framework relevant to: 

• Standard setting process (Chapter 3); 

• Implementation levels and organisation arrangement of the certification scheme (Chapter 

4); 

• Forest management standard (Chapter 5); 

• Chain of custody standard (Chapter 6); 

• Implementation of the PEFC logo usage rights (Chapter 7); 

• Certification and accreditation arrangements (Chapter 8). 

The report also includes: 

• Evaluation of the comments received from stakeholders resulting from the public 

consultation period (Annex 1); 

• Intelligence and insight gained from a Field Visit and meeting with stakeholders who have 

been involved in the development and/or use of the UFCS (Annex 2); 

• PEFCC Minimum Requirements Checklist (Annex 3); and 

• Evaluation of the comments from the Panel of Experts (which are provided in Annex 4 of the 

• report) 

Assessment Process and Methodology for Report 

Evidence and assessments detailed in the report are generated by benchmarking PEFCC’s 

requirements against the standards, processes and accountabilities detailed in the UFCS’s 

application documentation together with documentation and records reviewed during Field 

Visit. 

The following conformance definitions were applied in assessing the conformity of the UFCS 

with requirements of PEFCC: 

• Conforms – the criteria and requirements of the UFCS are assessed as equivalent to PEFCC 

requirements; 

• Partly conforms – the criteria and requirement of the UFCS are assessed as being, in 

principle, equivalent to PEFCC requirements but with minor inconsistencies or gaps when 

compared to PEFCC requirements; 

• Does not conform – the criteria and requirement in the UFCS are assessed as having 

substantial differences to the PEFCC requirements; 

• Not applicable (NA). 



2. History and Structure of the Uruguayan Forest Certification 

Scheme (UFCS) 

The development of THE UFCS (a certification scheme for plantation forests) was undertaken in 

two parts. The first component was the development – at request of Uruguayan Society of 

Forest Producers in 2007 – and approval of forest management standard and chain of custody 

standard (CoC) by STC-SFM (Specialised Technical Committee on Sustainable Forest 

Management). This component was undertaken between 2007 and 2009, consistent with 

processes of Uruguayan Institute of Technical Norms (UNIT). 

The second part saw the development of the organisational structures and implementation 

processes (including accreditation and certification procedures) for the application of the UFCS 

by PEFC Uruguay during 2009. 

It is noted that both the certification of forest management standard (covering forest 

management and CoC), and organisational processes and implementation procedures were 

undertaken with a view to aligning the UFCS procedures and processes with PEFCC 

requirements. 

2.1 Development of Sustainable Forest Management Standard 

The evolution of sustainable forest management standard can be tracked over two phases 

between 2006 and 2009. 

Phase 1 

The first phase commenced in late 2006 when the Uruguayan Institute of Technical Norms 

(Instituto Uruguayo de Normas Técnicas, UNIT), at request of Uruguayan Society of Forestry 

Producers, committed to developing a sustainable forest management standard for plantations 

under the project - “Access to markets and the integration through technical normalization”. 

UNIT is the internationally recognised national standardization body responsible for 

development of Uruguayan technical standards and guides. 

Consistent with their methodologies and internationally recognised processes, UNIT coordinated 

the establishment of the Specialized Technical Committee for the Sustainable Forest 

Management (STC-SFM) in 2006, with the aim to develop standards for Uruguayan sustainable 

forest management and chain of custody. The STC-SFM is the equivalent of standard setting 

body in PEFC documentation. 

The STC-SFM, as required by UNIT processes, formally requested the participation of 36 

individuals and organisations and was constituted with diverse membership including forest 

industry, forest growers, academia, technical expert, social interests and environmental 

interests (refer to GD05 and www.unit.org.uy). 

The STC-SFM - the body solely responsible for the content of forest management standard 

(Norm) and operating by consensus (as defined by ISO Guide 2) - utilized the “Conservation of 

Temperate and Boreal Forests” (Montreal Process), National (Uruguayan) Code of Good Forest 

Practice (2004) and Uruguayan Government forestry policies ratified in 1995, as reference 

documents to develop sustainable forest management standard. 

The STC-SFM also had the objective of constructing Uruguayan forest management standards in 

a format similar to Standard UNE 162002: 2001 (Spanish forest management standard which is 

endorsed under the Spanish scheme). 

Following their deliberations between 2006 and 2009, the STC-SFM approved the National 

(Uruguayan) Norms of Certification for forest management. These Norms included: 

• UNIT 1151 (Sustainable Forest Management. Glossary of Terms). This document 

specifies the definitions to be applied in Uruguay when applying UNIT 1152 (Sustainable 



Forest Management. Criteria and Indicators). UNIT 1151 was approved by STC-SFM on 24 

April 2006 and subsequently approved by UNIT’s General Norm Committee on 10 May 

2006. 

• UNIT 1152 (Sustainable Forest Management. Criteria and Indicators). This 

document specifies the indicators, justifications, objectives and parameters for 

evaluating social, environmental and economic outcomes to be delivered from forest 

management units for each of the Montreal Process Criteria. The initial edition of UNIT 

1152 was approved by STC-SFM on 24 April 2006 and subsequently by UNIT’s Norms 

General Committee on 10 May 2006. Following a review by STC-SFM of “Conservation 

and maintenance of soil and water resources” (Criteria 4, Item 6.4), a revised edition of 

UNIT 1152 was approved by STC-SFM on 18 December 2006 and approved by UNIT’s 

General Norm Committee on 7 March 2007. 

• UNIT 1153 (Sustainable Forest Management. Chain of Custody). The STC-SFM, 

following deliberations on appropriate CoC systems for Uruguay, recommended the use 

of the requirements specified in PEFCC Annex 4 (Chain of Custody of Forest Based 

Products) for firms seeking CoC certification under the UFCS. This recommendation was 

approved by STC-SFM on 18 December 2006 and subsequently approved by UNIT’s 

General Committee of Norms on 7 March 2007. 

Phase 2 

Following the Uruguayan Society of Forestry Producers (SPF) gaining PEFC Council membership 

in 2009, and their subsequent endorsement as PEFC National Governing Body for Uruguay, the 

Uruguayan Forest Management Standards (UNIT 1151:2006 and UNIT 1152:2006) were placed on 

public consultation from 1 April to 23 May 2009 with aim of meeting PEFCC requirements for 

public consultation. 

The STC-SFM – after considering the five comments resulting from public consultation processes 

in April-May 2009 and results of pilot testing - approved a revised edition of UNIT 1151 and UNIT 

1152 on 10 December 2009 (refer to GD12 and GD13 respectively). The revised edition of UNIT 

1151:2009 and UNIT 1152:2009 were subsequently approved by UNIT’s General Norm Committee 

on 14 December 2009 and PEFC Uruguayan General Assembly on 18 December 2009 (refer to 

GD05). 

As a consequence of the above process, the UFCS comprises of the following scheme specific 

sustainable forest management standards: 

• UNIT 1151:2009. Sustainable Forest Management. Glossary of Terms. 

• UNIT 1152:2009. Sustainable Forest Management. Criteria and Indicators. 

For chain of custody certification the UFCS utilizes the requirements of PEFCC’s Annex 4: Chain 

of Custody of Forest Based Products. 

The consultant’s assessment notes that the original Scheme Documentation submitted by PEFC 

Uruguay was incorrectly numbered as UNIT 1151 (2006) and UNIT 1152 (2006) (refer to GD10 and 

GD11 respectively). 

Revised numbered editions of forest management standards were received following subsequent 

discussions with PEFC Uruguay. The revised editions are identified as: 

• UNIT 1151: 2009 (Edition 2009-12-15). Sustainable Forest Management – Glossary of 

Terms (included as Document GD12), 

• UNIT 1152: 2009 (Edition 2009-12-15). Sustainable Forest Management – Criteria and 

Indicators (included as Document GD13). 

The revised numbered editions represent the documents approved by PEFC Uruguay General 

Assembly on 18 December 2009. These documents are consistent with the documentation for 

UNIT 1151 (2009) and UNIT 1152 (2009) on UNIT’s website (www.unit.org.uy). 

For the purpose of evaluating the conformity of sustainable forest management standard 

against PEFC requirements, the (English) edition of UNIT 1151: (2009) (referred to as GD12), 

and UNIT 1152 (2009) (referred to as GD13) were used. 



As documented above, the UFCS uses these forest management standards together with PEFCC’s 

Annex 4 Chain of Custody and other UFCS documentation as approved by PEFC Uruguay General 

Assembly on 18 December 2009. 

2.2 Organisational Structure of the UFCS 

Concurrent with the finalisation of forest management standards, PEFC Uruguay developed legal 

arrangements and organisational structures and processes with purpose of aligning UFCS with 

the requirement of PEFCC. PEFC Uruguay General Assembly approved the UFCS (forest 

management standards and organisational processes) on 18 December 2009 (refer to GD01). 

In a letter dated 8 January 2010 PEFC Uruguay formally submitted documentation for 

Conformity Assessment of Revised Uruguay Forest Certification Scheme to PEFCC. 

2.3 Documentation 

The documents detailed below were used in conducting the conformity assessment. Please note 

that the general documentation presented by PEFC Uruguay (no number) has been referenced 

as GD documents (including UNIT 1151:2009 and UNIT 1152:2009) by the Consultant while 

system documents forming part of PEFC Uruguay’s document register procedures are referred to 

as SD documents. 

Accordingly, PEFC Uruguay’s forest certification scheme includes the following documentation: 

General Documents (GD) 

(Note: These documents were not numbered in documentation submitted by PEFC Uruguay) 

GD01 Letter of Application for Conformity Assessment by PEFC Uruguay of revised 

Uruguayan Forest Certification Scheme (dated 8 January 2010). 

GD02 Uruguayan Forest Certification Scheme (UFCS) – PEFC Uruguay (2009). 

GD03 Proceedings (18 December 2009) PEFC Uruguay Assembly (undated). 

GD04 “Statues” Civil Association – PEFC Uruguay 

GD05 Unit Norms about Sustainable Forest Management including Project Process 

meetings (6 November 2009). 

GD06 Annex 2. SGS – Management System Certification – Audit Report, UNIT 1152 

(2006). 

GD07 

GD08 

PEFC Council Minimum Requirements Checklist and Annexes. 

UNIT 1151: 2009 – Report Corresponding to Unit Norm 1151: 2006. Sustainable 

Forest Management. Glossary of Terms. 

GD09 UNIT 1152: 2009 – Report Corresponding to the Norm UNIT 1152: 2009. 

Sustainable Forest Management. Criteria and Indicators. 

GD10 Institute Uruguayu de Norms Tecnicas; (Amended Version) UNIT 1151: 2006. 

Sustainable Forest Management – Glossary of Terms. Reference Number UNIT 

1151: 2006. 

GD11 

GD12 

GD13 

Amended Version UNIT 1152: 2006. Sustainable Forest Management. Criteria 

and Indicators. 

UNIT 1151: 2009 (Edition 2009-12-15). Sustainable Forest Management. Glossary 

of Terms. (Instituto Uruguayo De Norms Tecnicas). 

UNIT 1152: 2009 (Edition 2009-12-15). Sustainable Forest Management. Criteria 

and Indicators. (Instituto Uruguayo De Norms Tecnicas). 

Please note that documents GD12 and GD13 were not part of original documentation 

submitted by PEFC Uruguay. 



System Documents (SD) – PEFC Uruguay 

(Note: These documents were referenced as GD documents in PEFC Uruguay documentation) 

SD01 

SD02 

SD03 

SD04 

SD05 

SD06 

SD07 

SD08 

SD09 

Current Documents Listing (Register) 

Procedure of Elaboration and Control of Documents 

Organism (Organisation) of Forest Certification 

Criteria for Auditors Qualifications 

Use of PEFC Logo in Uruguay 

Settlement of Disagreements 

Requirements for Group Certification 

Standard Setting Process 

Chain of Custody 

It should be noted that the UFCS also refers to documentation from other sources which are 

referenced to support UFCS documentation. This includes: 

• PEFCC Statutes, Annexes and Guides 

• Institute Uruguayo de Norms Tecnicas’ (UNIT) control procedures and processes 

for standard setting (refer to Unit website – www.unit.org.uy) 

• Institute Uruguayo de Norms Tecnicas – Estatutos (1945) 

• Organismo Uruguayo de Acreditacion’s procedures and processes (refer to 

www.organismouruguayodeacreditacion.org) 

• ISO 19011: 2002 

• ISO Guides 61 and 65 

• ISO 17021 

• Core International Labour Organisation (ILO) Conventions 

• Montreal Process – Criteria and Indicators for the Conservation and Sustainable 

Management of Temperate and Boreal Forests 

• National (Uruguayan) Code of Good Forest Practice (2004) 

In a meeting with Instituto Uruguayo De Norms Tecnicas (UNIT) held during the Field Visit 

(detailed in Annex 2), the statutes and standard operating procedures employed by UNIT to 

develop and approve technical standards, together with records specific to operation of STC- 

SFM (including initial letters requesting participation of organisations, minutes of meetings and 

letters to organisations requesting input during public consultation period) were made available 

for inspection. UNIT documents were utilized in forming opinions regarding level of conformity 

of the UFCS against the requirements of PEFCC. 



3. Assessment of the standard setting process for the UFCS 

against PEFCC requirements 

An assessment of the rules for standard setting for the UFCS against the requirements for 

endorsement and mutual recognition by PEFCC is documented in this Chapter. 

3.1 Standard Setting Process for Forest Management Certification 

3.1.1 Independence 

1) Has the development of the certification standards been independent from the 

certification and accreditation processes? (Annex 2, 3.2) 

Documentation 

The forest certification standards – UNIT 1151: (2009) (GD12) and UNIT 1152: (2009) (GD13) 

were developed and approved by Specialized Technical Committee on Sustainable Forest 

Management (STC-SFM). The STC-SFM operated consistent with the processes required by 

Uruguayan Institute of Technical Norms (UNIT). UNIT is the internationally recognised standards 

body for Uruguay (refer to Section 7 of GD02 and www.unit.org.uy). 

Accreditation of certification bodies for the UFCS is undertaken by Uruguayan Organisation of 

Accreditation (OUA), an organisation independent of UNIT and PEFC Uruguay (refer to SD03, 

Section 3a). 

Conforms 

Practice 

The STC-SFM was solely responsible for developing and approving the content of sustainable 

forest management standards (UNIT 1151: 2009; and UNIT 1152: 2009). 

Consistent with the processes of UNIT, the General Committee of Norms (UNIT) formally 

approved the sustainable forest management standard developed by STC-SFM on 14 December 

2009 (refer GD03). PEFC Uruguay adopted the forest management standards approved by UNIT 

at meeting on 18 December 2009. 

Conforms 

2) Has the standard setting process been carried out at national and/or sub-national 

levels? (Annex 2, 3.3) 

Documentation 

The standard setting process was carried out at national level (refer to GD02). 

Conforms 

Practice 

The forest management standards (UNIT 1151: 2009 and UNIT 1152: 2009) are applied for all 

plantation forests applying for certification under the UFCS (refer to GD02). 

Conforms 

3) Has the standard setting process been co-ordinated by the PEFC National Governing 

Body? (Annex 2, 3.3) 

Documentation 

The standard setting process was initiated by predecessor to PEFC Uruguay but developed and 

approved by STC-SFM consistent with technical standard setting processes required by UNIT. On 

the 18 December 2009 PEFC Uruguay approved the forest management standards adopted by 



Norms General Committee (UNIT) on 14 December 2009. On the basis of these arrangements it 

is assessed that PEFC Uruguay co-ordinated the standard setting process (refer to GD02 and 

GD03). 

Conforms 

Practice 

The forest management standards developed by STC-SFM were approved by UNIT’s General 

Committee of Norms on 14 December 2009 and subsequently adopted by PEFC Uruguay on 18 

December 2009 (refer to GD02 and GD03). 

Conforms 

4) Has the certification standard been drafted to be applied at individual and/or group 

and/or regional level? (Annex 2, 3.3) 

Documentation 

The UFCS provides for individual certification and group certification (refer to GD02). 

Conforms 

Practice 

The UFCS has not been implemented to date. 


5) Has the development of certification criteria been initiated by national forest owners’ 

organisations or national forestry sector organisations having support of the major forest 

owners’ organisations in that country? (Annex 2, 3.4.1) 

The UFCS was initiated by a request to UNIT from Uruguayan Society of Forestry Producers, an 

organisation with membership representing over 90 percent of forest plantation owners in 

Uruguay to develop a sustainable forest management standard for plantations. UNIT, consistent 

with their procedures, subsequently established the Project “Access to markets and the 

integration through technical normalization” to manage the standard development process. 

Conforms 

3.1.2 Participatory Process 

6) Have all relevant interested parties representing the different aspects of sustainable 

forest management been invited to participate in the standard setting process and a 

created Forum? (Annex 2, 3.4.1) 

Documentation 

The STC-SFM, as required by UNIT processes, was appointed consistent with requirements of 

ISO/IEC Directive Part 1 (Standard Development, Process and Procedures). 

Consistent with UNIT operating procedures, the STC-SFM was formed in 2006 with a diverse 

range of institutions and individuals requested to participate (refer to GD02, Section 7 for list of 

organisations and individuals asked to participate). 

Invitations, as required by UNIT processes, covered economic, social and environmental 

interests in Uruguay, including forest owners, forest industry, government (environmental, 

agricultural and forestry agencies), non-government organisations (such as Asociacion National 

de ONG-ANOG), academia and unions. This was confirmed by a review of letters of invitation to 

participate on the STC-SFM and minutes of meetings of STC-SFM as well as discussion with 

relevant stakeholders held during Field Visit. 



Notwithstanding the diverse range of institutions and individuals requested to participate, the 

documentation presented by PEFC Uruguay and UNIT does not demonstrate that environmental 

non-government organisations (ENGOs) were asked to formally participate in the work of STC- 

SFM. 

Does not Conform 

Practice 

In establishing the STC-SFM, UNIT formally invited 36 organisations and individuals - 

representing social, economic and environmental interests in Uruguay - to participate in 

standard setting process. The list of institutions and individuals invited to participate in STC- 

SFM is maintained by UNIT, and was sighted by the consultants during Field Visit. 

However, as noted above, from the information presented by UNIT and PEFC Uruguay there is 

no evidence to support a conclusion that environmental non-government organisations (ENGOs) 

were invited to participate in work of STC-SFM. 


7) Do consensus-building procedures of the Forum provide for balanced representation of 

interest categories? (Annex 2; 3.4.1) 

Documentation 

The STC-SFM, as required by UNIT’s processes, seeks to achieve consensus amongst the 

participants and interest groups consistent with the framework specified by ISO Guide 2 (refer 

to GD05 and SD08). 

Conforms 

Practice 

The minutes of STC-SFM meetings between 2006 and 2009 (maintained by UNIT) provide 

evidence that STC-SFM operated by consensus. 

Conforms 

8) Have the views of all relevant parties been documented and considered in an open and 

transparent way? (Annex 2, 3.4.1) 

Documentation 

Procedures for operation of STC-SFM require the views of all members to be documented and 

considered in an open and transparent manner (refer to SD08). 

Conforms 

Practice 

A review of STC-SFM minutes of meetings (maintained by UNIT) during Field Visit and discussion 

with participants in STC-SFM indicates the views of all members were documented and 

considered in open and transparent manner. (Refer to Annex 2, Section 3) 

Conforms 

9) Has the formal approval of standards been based on evidence of consensus? (Annex 2, 

3.4.1) 

Documentation 

UNIT operating procedures, which are consistent with requirements of ISO/IEC Directive Part 1, 

require the STC-SFM to formally recommend forest management standards based on consensus 

outcomes for UNIT’s formal approval (refer to GD09 and SD08). 

Conforms 



Practice 

PEFC Uruguay on 18 December 2009 formally adopted without change the forest management 

standards approved by UNIT’s Norms General Committee 14 December 2009 (GD02 and GD13, 

Section 4). 

Conforms 

10) Does the implementation of the consensus based approach comply with Guideline GL 

5/2006? 

Documentation 

The STC-SFM, consistent with UNIT’s standard setting processes (refer to www.iso.org for 

standard development processes and procedures implemented by UNIT), is required to make 

decisions by consensus consistent with intent of ISO Guide 2 and Guideline GL 5/2006. 

Conforms 

Practice 

The minutes of meetings of STC-SFM between 2006 and 2009 (retained electronically by UNIT 

and reviewed on Field Visit) provide evidence that STC-SFM made decisions based on consensus 

(consistent with intent of Guideline GL 5/2006) during the development and approval of 

sustainable forest management standards. 

Conforms 

11) Has the Forum defined its own written procedures which have been made available to 

interested parties on request? (Annex 2, 3.4.1) 

Documentation 

The procedures of STC-SFM (the Forum) are documented by UNIT. Procedures are available to 

interested parties on UNIT’s website www.unit.org.uy (refer GD03). 

Conforms 

Practice 

The STC-SFM followed the documented procedures specified by UNIT in developing and 

approving forest management standards. 

Conforms 

12) Do the written procedures for standard setting contain an appeal mechanism for 

impartial handling of any substantive and procedural complaints? (Annex 2, 3.4.1) 

Documentation 

UNIT statutes (Estatutos, 1945) detail appeal procedures for the impartial handling of 

complaints submitted in relation to STC-SFM’s standard setting procedures. 

Conforms 

Practice 

If UNIT or STC-SFM had received complaints regarding the standard setting issues, the process 

specified by UNIT statutes would have been implemented. 

Conforms 

13) Has the start of the standard setting process been communicated to the public? (Annex 

2, 3.4.2) 

Documentation 



UNIT’s procedures require the commencement of standard setting process be communicated by 

placing information of commencement of Project on UNIT’s website supplemented by press 

release. 

Conforms 

Practice 

The commencement of standard setting process was communicated to the public by UNIT 

announcement on their website of Project “Access to markets and the integration through 

technical normalization” in 2006. This is UNIT’s standard operating practice. 

Conforms 

14) Has the information on the development process been distributed and discussed? 

(Annex 2, 3.4.2) 

Documentation 

The development process for standard setting used by UNIT require the STC-SFM to conduct its 

work consistent with rules and processes specified by UNIT. UNIT’s processes require standard 

development processes to be undertaken consistent with ISO/IEC Directives, Part 1 (SD08). 

Conforms 

Practice 

UNIT distributed information via its website on the standard setting development process. 

Members of the STC-SFM interviewed during Field Visit stated that UNIT explained and discussed 

the processes required to be implemented in developing and approving the SFM standards. 

Conforms 

15) Has the final draft standard been available to all interested parties, e.g. by posting it 

on the internet? (Annex 2, 3.4.2) 

Documentation 

The final drafts of UNIT 1151:2009 (Sustainable Forest Management. Glossary of Terms) and 

UNIT 1152:2009 (Sustainable Forest Management. Criteria and Indicators) were approved by the 

General Norms Committee of UNIT in May 2006 and March 2007 respectively. They were made 

available on UNIT’s website (www.unit.org.uy/gfs) during public consultation period (April/May 

2009) (refer to GD02 and GD05). 

Conforms 

Practice 

The final draft standard was available on UNIT’s web-site from 1 April 2009 to 28 June 2009. 

Conforms 

16) Has the final draft standard been sent out for a formal national consultation process? 

(Annex 2, 3.4.3) 

Documentation 

With the purpose of meeting PEFCC requirements the final draft standards (UNIT 1151:2006 and 

UNIT 1152:2006) were made available for public review and comment from 1 April to 23 May 

2009 with public notification via UNIT’s website and print media advertisements (refer to 

GD05). 

Conforms 

Practice 



Formal national consultation was undertaken between April and May 2009 (refer to GD02, GD05, 

GD12 and GD13). 

Conforms 

17) Have the views of interested parties been discussed? (Annex 2, 3.4.3) 

Documentation 

Standard setting rules require the views of interested parties to be discussed (SD08). 

Conforms 

Practice 

The STC-SFM documented and considered the submissions received from five organisations 

generated by public consultation processes at three meetings held in October 2009. The revised 

editions of UNIT 1151:2009 and UNIT 1152:2009 were finalised after consideration of these 

comments. The revised STC-SFM standards were approved by UNIT’s Norms General Committee 

on 14 December 2009 (refer to GD01, GD05, GD12 and GD13). 

Conforms 

18) Has the Forum given general information on the changes made as a result of a 

consultation process? (Annex 2, 3.4.3) 

Documentation 

UNIT’s rules and operating processes require that STC-SFM maintain records of all changes to 

standards as they develop. This information is held by UNIT and is publicly available. 

Conforms 

Practice 

The STC-SFM documented in minutes of meetings the changes made to final draft versions of 

forest management standards (UNIT 1151:2009 and UNIT 1152:2009) emanating from results of 

consultations and results of pilot testing programs in second half of 2009 (refer to GD05). 

Conforms 

19) Had the consultation process been at least 60 days? (Annex 2, 3.4.3) 

Documentation 

UFCS documentation does not explicitly state the consultation process will span at least 60 

days. However documentation (GD02 and SD08) does state the standards will be developed in 

accordance with PEFC requirements. PEFC requirements specify a 60 day consultation period. 

Conforms 

Practice 

Formal consultation process for UNIT 1151:2009 and 1152:2009 was from 1 April to 23 May 2009, 

a period of 53 days (refer to GD03). Discussions with UNIT executives during the Field Visit 

indicated that it was planned to place media advertisements covering 60 day period required by 

PEFCC consultation process. However media advertisements were incorrectly placed reducing 

the period to less than 60 days. 

Although the media notification for consultation was less than 60 days it is noted that final 

drafts of UNIT 1151:2009 and UNIT 1152:2009 were available on UNIT’s website from 1 April 

2009 to 28 June 2009. The media notification referred interested persons to this website. 

It is also noted that STC-SFM did not consider the issues raised from submissions received 

following public consultation until October 2009, a period of over 3 months from withdrawal of 



final drafts of standards on UNIT’s website. Consequently there would have been time for STC- 

SFM to incorporate any late submissions on standards in their deliberations. 

Does not conform 

3.2 Standards for Chain of Custody Certification 

PEFC Uruguay, on the advice of UNIT, adopted the PEFCC’s Technical Document Annex 4 as the 

system for CoC certification under the UFCS on 18 December 2009 (refer to GD01, GD02 and 

SD09). 

Conforms 

3.3 Pilot Testing 

35) Have the first results on the testing of the final drafts for national/sub-national forest 

certification standards and their implementation arrangements been available prior to 

submission of the scheme for the PEFC Council endorsement and mutual recognition? 

(Annex 2, 5) 

Documentation 

UFCS documentation (refer to GD02) states that a validation audit of implementation 

arrangements for UNIT 1151:2006 and UNIT 1152:2006 was undertaken by SGS in February 2009. 

The SGS audit used UNIT 1151 (2006) and UNIT 1152 (2006) as reference. Results of the audit 

are included in GD06. 

Furthermore, GD02 states that Forestry Department of Faculty of Agronomy (University of 

Uruguay) undertook a document and field audit of UNIT 1152: 2006. This work was undertaken 

in March/April 2009. 

The results of audit were available to STC-SFM prior to submission of the UFCS by PEFC Uruguay 

to PEFCC. 

Conforms 

Practice 

Based on documentation presented during Field Visit it was observed that UNIT 1151 (2006) and 

UNIT 1152 (2006) were subject to three pilot tests. These included the two pilot tests sighted 

above, plus a third pilot audit by a consultant in May 2009 focusing on verification of 

documentation and implementation arrangements for draft forest management standards. The 

results of third audit were sighted during Field Visit. 

The experiences learnt from three pilot tests were available and used by STC-SFM in 

determining final edition of UNIT 1151: 2009 (refer to GD12) and UNIT 1152: 2009 (refer to 

GD13). 

Conforms 

36) Has appropriate action been taken to incorporate improvements and recommendations 

prior to submission of the scheme for the PEFC Council endorsement and mutual 

recognition process? (Annex 2, 5) 

Documentation 

Minutes of STC-SFM deliberations during the second half of 2009 (electronically retained by 

UNIT) demonstrate that STC-SFM incorporated the findings of pilot testing in the final approved 

standard for sustainable forest management, namely UNIT 1151:2009 (GD12) and UNIT 



1152:2009 (GD13). Changes were made in areas of community recognition and engagement, soil 

and water management, landscape and protected lands. 

Conforms 

Practice 

Refer to above response. 

Conforms 

3.4 Review of Standards 

3.4.1 Periodic Review 

37) Have the standards on forest and chain of custody certification been reviewed at least 

every 5 years or it is foreseen to review these standards at least every 5 years? (Annex 2, 

6.1) 

Documentation 

UFCS documentation (SD08 and GD02) requires that forest certification standards and 

implementation arrangements must be reviewed at least every five years. 

For chain of custody certification the UFCS has adopted PEFCC Annex 4 requirements and it will 

be PEFCC’s responsibility to review this standard. 

Conforms 

Practice 

Not applicable at this time. 


38) Does the scheme documentation indicate which organisation is responsible to initiate 

the revision work? (Annex 2, 6.1) 

Scheme documentation specifies that PEFC Uruguay is responsible for initiating required 

revisions (refer to GD02, Section 7). 

Conforms 

39) Has the revision procedures been participatory, fair and transparent? (Annex 2, 6.1) 

Not applicable at this time as this is the initial assessment for mutual recognition. 

Not Applicable 

40) Has the PEFC National Governing Body appropriately considered the revisions of the 

general PEFC requirements for standard setting and implementation in the national 

standards? (Annex 2, 6.2) 



41) Has the PEFC National Governing Body indicated to the PEFC Council the appropriate 

considerations of the revisions induced by the PEFC Council in national standards? (Annex 

2, 6.2) 





3.5 Overall Assessment 

The standard setting process for UFCS does not meet PEFC Scheme requirements due to nonconformities 

associated with i) a lack of evidence to demonstrate environmental nongovernment 

organisations were formally invited to participate in work of STC-SFM; and ii) the 

public consultation process for the final draft spanning a period of less than 60 days. Additional 

commentary is presented below to assist in evaluating the significance of these nonconformities. 

The first assessed non-conformity relates to the lack of evidence indicating environmental nongovernment 

organisations were invited to participate in deliberations of STC-SFM. As noted in 

Field Visit Report (Annex 2) the umbrella ENGO in Uruguay is ‘Group Guayubira’ 

(www.guayubira.org.uy) which strongly advocates a policy of no expansion of introduced and/or 

monoculture forest plantations in Uruguay. While Group Guayubira or other environmentally 

focused non-government organisations did not formally participate in deliberations of STC-SFM, 

it is noted that many specific issues of concern to ENGOs were discussed and addressed during 

the development of forest management standards. It is also noted that representatives of 

Department of Environment (Uruguay) formally participated in deliberations and approvals of 

forest management standards. 

On a procedural point the processes used to develop forest management standards (UNIT 1151: 

2009) and UNIT 1152: 2009) were approved by UNIT - the internationally recognised national 

standardization body for developing technical (national) standards in Uruguay. 

The second non-conformity relates to the announced public consultation process for final draft 

of forest management standards (UNIT 1151: 2006 and UNIT 1152: 2006) co-ordinated by UNIT 

spanning a period of 53 days (1 April 2009 to 23 May 2009). This is less than the 60 days 

consultation period specified by PEFCC (refer to Question 19). The intent of PEFC Uruguay and 

UNIT was that the formal public consultation period was to be a period of 60 days to meet 

PEFCC requirements. The reduced public consultation process occurred due to 

miscommunication in placing media advertisements for period of public consultation. 

As noted in the response to Question 19, the final draft of forest management standards were 

available on UNIT’s website from 1 April 2009 to 28 June 2009. Furthermore, letters informing 

organisations of public consultation for UNIT 1151: 2006 and UNIT 1152: 2006 were forwarded 

by UNIT on behalf of STC-SFM. 



4. Assessment of the Implementation of the UFCS against PEFCC 

Requirements 

Performance requirements for the UFCS are detailed in PEFC Uruguay system documents (SD01 

to SD09) and GD02. 

The UFCS provide for: 

• Individual Forest Certification for a person or legal entity (organisation) acting as 

Applicant Entity for forest areas that the applicant manages and voluntarily seeks to 

include in the certification process; and 

• Group Forest Certification for forest managers who form a group through a legally 

constituted Association which is designated as the Applicant Entity. The UFCS also 

provides for forest managers to be grouped through a legally documented agreement 

with designated person(s) acting as an Applicant Entity. 

The requirements for Group Forest Certification are detailed in document SD07. The 

requirements for Individual Forest Certification are specified in Document GD02 (Section 5.1). 

The implementation of the UFCS requires the Applicant Entity applying for Forest Management 

Certification to construct a Forest Management System (referred to as SD03, Section 5.4). The 

Forest Management System should detail the policies, organisational structure and processes 

the Applicant Entity is implementing in forests and/or chain of custody to demonstrate 

compliance with requirements of the UFCS. 

The Forest Management System also incorporates a requirement for General Plan of 

Management for forest management units undertaking certification. The General Plan of 

Management must be constructed consistent with the concept of Sustainable Forest 

Management, “seeking a balance between the conservation of the natural resources, historiccultural 

and socio-economic aspects, productivity (technical, economic and financial) and the 

general society’s well being”. UFCS documentation details the economic, social and 

environmental goals to be addressed in General Plan of Management. (Refer to GD13, Section 

4). 

The standard (Norm) for sustainable forest management under the UFCS is UNIT 1152: 2009 

(refer to GD13)(Sustainable Forest Management. Criteria and Indicators) and supported by UNIT 

1151: 2009 (Sustainable Forest Management. Glossary of Terms) (referred to GD12). These were 

approved by PEFC Uruguay General Assembly on 18 December 2009. The Norm UNIT 1152: 2009 

is based on the Montreal Process (“Criteria and indicators for the conservation and sustainable 

management of temperate and boreal forests”), the National (Uruguayan) Code of Good 

Forestry Practices (2004) and other Uruguayan legislative and regulatory requirements for 

conducting forestry activities. 

The forest management standards (UNIT 1151: 2009 and UNIT 1152: 2009) utilize the seven 

criteria of the Montreal Process to state the outcomes required to demonstrate sustainable 

forest management for Uruguayan plantation forests. For each Montreal Process criterion the 

standard for sustainable forest management for the UFCS (UNIT 1152: 2009) specifies indicators 

– variables which are monitored – to provide evidence of attaining the outcome targeted by 

criterion. Success in delivering each indicator is evaluated by evidence produced by 

justification statements (i.e. outlines the importance of the relevant indicator); objective (i.e. 

output the forest manager is expected to deliver to demonstrate compliance with the 

indicator); parameters (i.e. framework of variables to be monitored); procedure (i.e. specific 

actions to implement parameters); documents (i.e. information and records to verify actions); 

and register (i.e. evaluation from monitoring of parameters that analyse and track degree of 

compliance in attaining objective and indicator). 

The UFCS utilizes PEFCC requirements for chain of custody certification as detailed in Annex 4 

(Chain of Custody of Forest Based Products – Requirements). 



4.1 Criteria for Forest Certification 

4.1.1 General Requirements 

1) Are the criteria relevant to all types of forests and management systems, which exist in 

the nation/region and have they been elaborated for? (Annex 3, 3.6) 

The criteria for forest certification in the UFCS are relevant to all plantation forests and 

management systems in the unit of forest management (refer to GD01 and GD13, Section 1). 

Conforms 

2) Do the criteria clearly express the objectives for forest management that can be 

unambiguously verified by different auditors? (Annex 3, 3.6) 

The UFCS Criteria and Indicators as detailed in UNIT 1152:2009 (refer to GD13) clearly state the 

objectives for forest management and are supported by explicit justifications, objectives and 

means of verification. The UFCS requirements can be implemented and unambiguously audited by 

different auditors based on the justification as the normative requirements. 

Conforms 

3) Are management and performance requirements applicable at the level of a forest 

management unit? (Annex 3, 3.6) 

Management and performance requirements of the UFCS are applicable at the level of a forest 

management unit (FMU) (refer to GD13, Section 4.1). 

Conforms 

4) Are management and performance requirements applicable optionally also at group and 

regional levels? (Annex 3, 3.6) 

Management and performance requirements for the UFCS are applicable at group and individual 

levels (refer to GD02). 

Conforms 

4.1.2 Other Requirements for Forest Management Criteria 

5) Does the scheme require that property rights and land tenure arrangements shall be 

clearly defined, documented and established for the relevant forest area? (Annex 3, 3.5) 

As a component of forest owner demonstrating legal compliance for forest management 

activities, Criteria 7 (UNIT 1152: 2009) requires property rights and land tenure to be defined, 

documented and legally established for all forest areas being assessed for certification. 

Conforms 

6) Does the scheme require the clarification, recognition and respect of legal, customary 

and traditional rights related to the forest land in compliance with chapter 3.5 of Annex? 

(Annex 3, 3.5) 

UNIT 1152: 2009 requires the forest owner applying for certification to identify, recognise and 

respect legal, customary and traditional rights to forest land (Criteria 6, Indicator 6.6.3 and 

Criteria 7). 

Conforms 



7) Does the scheme require that a summary of the forest management plan or its 

equivalent, which contains information about the forest management measures to be 

applied, is publicly available, except for confidential business and personal information? 

(Annex 3, 3.5) 

Scheme documentation as presented does not provide for copies of forest management plans to 

be made publicly available. During Field Visit representatives of forest companies indicated 

that current practice was to make available forest management plans to individuals and 

organisations who request copies. 


4.1.3 Laws and Regulations 

8) Are the national certification criteria in compliance with national laws, programs and 

policies? (Annex 3, 3.2, 3.6) 

The UFCS require compliance with national forest policy, legislation and relevant regulations as 

detailed in GD02, Section 5 and requirements of Criteria 7, UNIT 1152: 2009 (refer to GD13). 

Conforms 

9) Are the references to national laws, programs and policies indicated in the scheme 

documentation when relevant, e.g. if the requirement of the PEOLG is not addressed in the 

certification criteria but is included in normative regulations? (Annex 3, 3.6) 

The UFCS documentation (UNIT 1152:2009, Criteria 7) requires groups or individuals seeking 

certification to compile a register of compliance with relevant policies, legislation and 

regulations (refer to GD13). 

Conforms 

10) Does the scheme include the requirement that any apparent violation of the legislation 

shall be taken into consideration in internal and external audits? (Annex 3, 3.2) 

The UFCS requires the Applicant Entity to conform to relevant legislation. Conformity is to be 

verified in Conformity Audit (Criterion 7 – UNIT 1152) - “Any apparent violation of the 

legislation shall be considered during the auditing and certification processes” (GD02, Section 

2). 

Conforms 

4.1.4 International Labour Organization (ILO) Conventions 

11) Are the Fundamental ILO Conventions ratified by the country and implemented through 

the legislative framework? (Annex 3, 3.3) 

Uruguay has ratified core ILO conventions as detailed below: 

ILO Convention 

Action 

No: 29 Forced Labour, 1930 Ratified – 6/9/1995 

No 87: Freedom of Association and Protection of the Right to Ratified – 18/3/1954 

Organise, 1948 

No 98: Right to Organise and Collective Bargaining, 1949 Ratified – 18/3/1954 

No 100: Equal Remuneration, 1951 Ratified – 16/11/1989 

No 105: Abolition of Forced Labour 1957 Ratified - 22.11.1968 

No 111: Discrimination (Employment and Occupation), 1958 Ratified – 16/11/1989 

No 138: Minimum Age for Admission to Employment, 1973 Ratified – 2/6/1977 

No 182: Worst Forms of Child Labour, 1999 Ratified – 3/8/2001 



The requirements of the ratified ILO conventions can be enforced through the legislative 

framework for Uruguay. 

Conforms 

12) Do the national certification criteria address the core elements of those Fundamental 

ILO Conventions which have not been ratified by the country? (Annex 3, 3.3) 

As noted previously, all core ILO Conventions have been ratified by Uruguay. 

Conforms 

13) Has the ILO Code of Practise on Safety and Health in Forestry Work been considered in 

development of national and regional certification criteria? (Annex 3, 3.3) 

The ILO Code of Practice on Safety and Health in Forestry Work was considered in development 

of forest management standard and is captured by requirements of Criteria 6, Indicator 6.6.1 of 

UNIT 1152: 2009. 

Conforms 

4.1.5 Other International Conventions 

14) Are the international conventions relevant to forest management and ratified by the 

country respected through the legislative framework? (Annex 3, 3.4) 

Uruguay has implemented the following actions in relation to international conventions relevant 

to forest management: 

International Convention 

Convention on Biological Diversity Ratified – 5/11/1993 

Kyoto Protocol and Carbon Sinks Ratified – 5/2/2001 

Convention on International Trade in Endangered Species Ratified – 2/4/1975 

Cartagena Protocol on Biosafety Signed - 1/2/2001 

The requirements of ratified conventions can be enforced through the legislative framework for 

Uruguay. 

The intent of the Cartagena Protocol on Biosafety is repeated in Criteria 3, Indicator 6.3.2 of 

UNIT 1152: 2009. 

Conforms 

15) Are the requirements agreed upon in the conventions, even if they are not ratified by 

the country, respected in the certification criteria to the degree that they are covered in 

PEOLG or other reference documents basis approved by the PEFC Council? (Annex 3, 3.4) 

The requirements in the international conventions (protocols) detailed in question 14 are 

respected in the forest management standard UNIT 1152: 2009. 

Conforms 

4.2 Level of Application and Implementation (Annex 3, 4) 

4.2.1 General 

The UFCS provides options for individual and group certificates (either an organisation or legally 

appointed individuals who undertake responsibilities of Applicant Entity for the management of 



forest for a number of owners). The UFCS details the rules for individual certification (GD02) 

and group certification (SD07) including responsibilities and authorities for all participants 

seeking certification. 

16) Are the applicants, the certified areas and participating forest owners / managers / 

others actors clearly identified in the scheme documentation? (Annex 3, 4.1) 

UFCS documentation (refer to SD07 and GD02) clearly identifies the applicant, certified areas, 

forest owners/managers for each category of certification. 

Conforms 

17) Does the scheme documentation require that all actors involved in or operating on the 

certified area comply with the certification requirements? (Annex 3, 4.1) 

UFCS documentation (refer to SD07 for Group Certification and GD02, Section 5.1 for Individual 

certification). 

Conforms 

18) Does the scheme documentation require that all actors individually certified or 

participating in regional/group certification are responsible for ensuring that contractors’ 

activities and operations meet the respective forest management criteria? (Annex 3, 3.4) 

UFCS documentation requires that contractors (third parties) perform duties according to 

requirement of “Sustainable Forestry Certification System” (refer to SD07 and GD02). 

Conforms 

4.2.2 Regional Certification 

Not Applicable (No. 19 – 34) 

4.2.3 Group Certification 

35) Does the national definition for group certification comply with the PEFC Council 

definition? (Annex 3, 4.1 b) 

The criteria and requirements for group certification within the UFCS as set out in SD07 comply 

with PEFCC requirements. 

Conforms 

36) Does the scheme documentation clearly define who the applicant is for group 

certification? (Annex 3, 4.1 b) 

The UFCS clearly identifies the Applicant Entity (Group Administrator) for group certification 

(refer to GD02, Section 5.2 and SD07). 

Conforms 

37) Does the scheme documentation describe the applicant’s responsibility to assure the 

compliance of all participants with the certification requirements? (Annex 3, 4.1 b) 

UFCS documentation (refer to SD07) requires all members in group certification to “commit to 

comply with the obligations imposed by Sustainable Forest Management System”. It is the 

responsibility of Group Administrator (Applicant Entity), who acts on behalf of group members, 

to ensure all members comply with forest management requirements. 



Conforms 

38) Does the scheme documentation describe the applicant’s responsibility to ensure that 

credible registers are kept of participants to certification and certified forest area? 

(Annex 3, 4.1 b) 

UFCS documentation (refer to SD07, Section 4) requires the Group Administrator to “maintain a 

register of all forested areas and group members included on group certificate, identifying the 

owner, manager and area”. 

Conforms 

39) Does the scheme documentation describe the applicant’s responsibility to implement 

the rules for group certification? (Annex 3, 4.1 b) 

UFCS documentation (refer to SD07, Section 4) requires the Group Administrator “to guarantee 

that all activities related with the certificate take place according to the requirement of the 

Sustainable Forestry Management System”. 

Conforms 

40) Does the scheme documentation require that total forest area participating in group 

certification is recorded? (Annex 3, 4.1 b) 

The UFCS documentation (refer to SD07) requires that Group Administrator keep a register of all 

forested areas included those participating in group certification. 

Conforms 

41) Does the scheme documentation describe that forest owners should submit all the 

forest area under his management in the catchment area for the group certification? (Not 

obligatory to be met but should be aimed at) (Annex 3, 4.1 b) 

UFCS documentation (refer to SD07, Section 7) recommends that forest owners “include the 

totality of the forest areas” for group certification. 

Conforms 

42) Does the scheme documentation define the responsibilities and authorities of the 

applicant and participating forest owners / managers for the inclusion of new participants 

and to inform the certification body thereof? (Annex 3, 4.1 b) 

UFCS documentation (refer to SD07, Section 4 and 5) details the responsibility and authority for 

inclusion of new members and notification of certification bodies. 

Conforms 

43) Does the scheme documentation define the responsibilities and authorities of the 

applicant and participating forest owners/managers for the internal control of conformity 

and follow up corrective and/or preventive measures? (Annex 3, 4.1 b) 

The UFCS documentation details the responsibilities and authorities of applicants and 

participants to comply with certification requirements identified during audit. Documentation 

further requires applicants to commit to correct non-conformities and implement preventive 

and corrective measures (refer to SD07). 

Conforms 

44) Does the scheme documentation describe that the forest management certificate is 

issued to the applicant (certificate holder)? (Annex 3, 4.1 b) 



UFCS documentation (refer to SD07) requires the Group Administrator to hold Group Certificate 

issued by certification body. 

Conforms 

45) Does the scheme documentation describe that participants in group certification shall 

receive either a copy of the regional certificate including the appendix (when applicable) 

listing all participating forest owners or an individual attestation issued by the 

certification body or the applicant which refers to the main certificate? (Annex 3, 4.1 b) 

Group members will receive from Group Administrator a “document accrediting their 

participation in the Group Certificate” (refer to SD07). 

Conforms 

4.2.4 Individual Certification 

46) Does the scheme documentation describe that forest owner should submit all the 

forest area under his management in the catchment area of the certification scheme in the 

certification? (Not obligatory to be met but should be aimed at) (Annex 3, 4.1 c) 

UFCS documentation (refer to GD02, Section 5.1) recommends that the applicant for individual 

certification include all forests that are managed in certification process. 

Conforms 

4.2.5 Implementation of changes to the scheme 

47) Does the scheme documentation define transition period(s) for implementation of 

changes to the endorsed scheme in compliance with chapter 5 of Annex 3? (This is not 

applicable to the initial endorsement of a scheme) (Annex 3, 5) 

Not relevant at this time as the UFCS is applying for initial conformity assessment. 


4.3 Appeals, Complaints and Dispute Procedures (Annex 3, 6) 

48) Has the PEFC National Governing Body set up or appointed an impartial and 

independent dispute settlement body on a permanent basis or does it have written 

procedures for the establishment of a dispute settlement body on an ad hoc basis? 

(Annex 3, 6.1) 

PEFC Uruguay has rules to establish on an ad hoc basis (as required) a Settlement and 

Disagreement Commission to handle complaints that cannot be resolved by procedures of 

certification body (refer to GD06). 

Conforms 

49) Has the PEFC National Governing Body established and documented procedures for an 

independent dispute settlement body, either permanent of ad hoc, that takes care of 

those complaints arising from forest management or chain of custody scheme 

implementation that cannot be addressed in the dispute settlement procedures of the 

relevant certification or accreditation body? (Annex 3, 6.1) 

PEFC Uruguay has rules for establishment on an ad hoc basis a Settlement of Disagreements 

Commission to address complaints arising from forest management, chain of custody and 



implementation issues that cannot be addressed by certification body or accreditation body 

(refer to GD06). 

Conforms 

50) Can the dispute settlement body also resolve possible grievances in chain of custody 

certification that do not exclusively concern an applicant and a certification body? (Annex 

3, 6.1) 

The Settlements of Disagreement Commission (refer to SD06) has charter to resolve grievances 

in CoC certification that do not inclusively concern an applicant and certification body. 

Conforms 

51) Does the scheme documentation require that the accredited certification body has 

procedures for dispute settlement for all grievances between the applicant and the 

certification body? (Annex 3, 6.2) 

UFCS documentation (refer to SD03, Section 5(v) and Section 13) requires the accredited 

certification body to have “policies and procedures for resolution of claims, disputes and 

litigation received by any interested party (includes applicant) in the certification”. 

Conforms 

52) Does the scheme documentation require that the relevant accreditation body, whose 

accreditation covers the certification, deals with disputes and complaints concerning 

observance of the accreditation requirements? (Annex 3, 6.2) 

UFCS documentation (refer to SD03, Section 13) requires the accredited certification body to 

“take proper corrective and preventative actions” in relation to accreditation requirements and 

maintain required registers of actions taken. 

Conforms 


The implementation processes for UFCS do not meet PEFCC requirements due to nonconformity 

associated with the requirement that summaries of forest management plans are 

made publically available. 

The UFCS is assessed as meeting all other implementation process requirements for forest 

certification and chain of custody certification. 



5. Assessment of the UFCS Forest Management Standards against 

PEOLG 

5.1 Assessment Framework 

The UFCS utilizes Norm (Standard) 1152: 2009 (Sustainable Forest Management. Criteria and 

Indicators) (GD13), supported by Norm UNIT 1151: 2009 (Sustainable Forest Management. 

Glossary of Definitions) (GD12) for evaluating the creditability and reliability of forest 

management of plantations. 

The forest management standard is structured to be internationally credible, practical and 

audible to certify forest owners under individual or group certification arrangements. 

The Criteria and Indicators of the Standard (UNIT 1152: 2009 and UNIT 1151: 2009) are 

evaluated below for equivalence with the PEOLG. In evaluating the indicators, it is relevant to 

note that the requirements for justification, objective, parameters, procedures, documents and 

registers will be implemented to demonstrate meeting indicators. 

5.2 Compatibility of the UNIT 1152: 2009 Standard with PEOLG 

All references referred to in the following table are to Criteria and associated Indicators 

specified in UNIT 1152: 2009. For the guidance of readers Criteria in UNIT 1152:2009 relevant to 

demonstrating equivalence with PEOLG Criterion are coded as C (e.g. C 1) and associated 

relevant Indicators coded as I (e.g. I 6.1.1). 

5.2.1 Criterion 1 – Maintenance and appropriate enhancement of forest 

resources and their contribution to global carbon cycles 

PEOLG 

Criterion 

Evidence 

Reference to UNIT 

1152: 2009 

1.1 Guidelines for forest management planning 

General: Section 4.1 

(Requirements for 

Plantification) 

Specific: 

C1: I6.1.1, I 6.1.2, 

I6.1.3. 

C2: I6.2.1, I6.2.2, 

I6.2.3, I6.2.4 

C4: I6.4.1, I6.4.2, 

I6.4.3, I6.4.4 

C6: I6.6.1, I6.6.3, 

I6.6.4 

1.1 a The Standard requires forest owners to 

practice sustainable forest 

management (SFM) documented in 

Forest Management Plan to deliver a 

“balance between conservation of 

natural resources, historic-cultural and 

socio-economic aspects, productivity 

(technical, economic and financial) 

and general society’s well being”. 

Land-use planning to achieve 

sustainable development values is an 

explicit requirement of Standard. 

1.1 b The Standard requires forest owners to 

undertake “territory inventory” and 

mapping covering conservation of 

biological diversity and maintenance 

and improvement of forest ecosystems 

(including soil and water). 

1.1 c The Standard requires forest owners to 

prepare and periodically review 

management plans. The management 

plans are to be based on relevant laws, 

consistent with the scale of forestry on 

the property. 




Specific: 

C1: I6.1.1; I6.1.2, 

I6.1.3 

C2: I6.2.1 I6.2.2, 

I6.2.3, I6.2.4 


(General Plan for 

Management) 

Specific: 

C1 – 7 and Indicators 

Assessment 

Conforms 

Conforms 

Conforms 

1.1 d A core requirement in application of General: Section 4 Conforms 



the Standard (UNIT 1152: 2009) is the 

monitoring and evaluation of 

parameters to provide evidence (as 

documented in registers) in 

achievement of objectives defined for 

each indicator. 



Specific: The 

Parameters and 

associated Registers 

for each Indicator. 

1.2 Guidelines for forest management practices 

1.2 a The Standard requires forest owners to 

prepare General Plans of Management 

(consistent with the scale of forestry 

operations) which delivers in the 

context of SFM protection of water and 

soil resources and balances harvesting 

and growth rates. Silvicultural “tasks 

must reduce to a minimum the 

mechanical damage to the forest 

population”. 

1.2 b The Standard requires the General Plan 

of Management to detail silvicultural 

treatment to deliver sustainable 

development. 

1.2 c The Standard facilitates the expansion 

of plantations on land designated by 

Uruguayan legislation. It is noted that 

Uruguay has long established 

regulations specifying the soil types 

and landscapes where forest 

plantations can be established. All 

plantations established in Uruguay are 

on agricultural lands. 

Plantation projects are required to be 

approved by Ministry of Forestry 

(Agriculture) and Ministry for 

Environment. These arrangements in 

Standard and Uruguayan regulatory 

requirements are assessed as meeting 

the PEOLG’s requirements of taking 

into consideration the conversion of 

abandoned agricultural and treeless 

land. 

General: Section 4 

(Requirement for 


Specific: 

C2: I6.2.1, I6.2.2, 

I6.2.3 

C3: I6.3.1 

C4: I6.4.1, I6.4.2, 

I6.4.3, I6.4.4 


(Requirement for The 

Plantification); 

Specific: 

C1: I6.1.2 

C2: I6.2.2, I6.2.3, 

I6.2.4 

C3: I6.3.1, I6.3.2 


(Plantification); 

Specific: 

C2: I6.2.2 

C7: I6.7.1 

Conforms 

Conforms 

Conforms 

5.2.2 Criterion 2 – Maintenance of Forest Ecosystem Health and Vitality 

PEOLG 

Criterion 

Evidence Reference Assessment 


2.1 a The Standard requires forest 

management planning to maintain and 

improve the health and vitality of 

forest ecosystems against fire, climatic 

agents, mechanical damage, pests and 

diseases and rehabilitate damaged 

ecosystems where possible by 




Specific: 

C1: I6.1.2 

C2: I6.2.1 

C3: I6.3.1, I6.3.2 

Conforms 



silvicultural means. 

2.1 b The Standard requires managers to 

monitor the health and vitality of 

forest ecosystems including pests and 

diseases, overgrazing and overstocking 

(animal loads), fire, climatic agents 

and forest management activities. 

2.1 c The Standard requires forest 

management plans to include 

procedures to minimise the risks of 

degradation and damage to forest 

ecosystems and be consistent with 

Uruguayan regulations relevant to 

plantation management. 




Specific: 

C2: I6.2.1 

C3: I6.3.1, I6.3.2 

C4: I6.4.2, I6.4.3 




Specific: 

C2: I6.2.1 

C3: I6.3.2, I6.3.3 

C7: I6.7.1 



management practices to describe, 

evaluate and plan the management of 

natural ecosystems to increase their 

genetic and structural diversity with 

the purpose of enhancing the stability 

and vitality of the combined plantation 

and natural ecosystem to resist 

“adverse environmental factors and to 

strengthen the natural mechanisms of 

regulation”. 

2.2 b The Standard requires plantations be 

established with appropriate species 

for the site and assessment of impacts 

on ecosystems and genetic integrity of 

native species. Silviculture, harvesting 

and transport techniques must 

minimise damage to trees, soil and 

water resources. The use of fuels and 

lubricants must be undertaken to 

prevent soil contamination. 


management practices to use 

agrochemicals consistent with 

integrated control systems 

incorporating economic, silvicultural 

and biological considerations to 

protect forest, soil and water 

resources. 

2.2 d The Standard requires managers to 

implement procedures for “storage, 

manipulation, application and 

management of agrochemicals” 

(interpreted to include fertilizers) to 

prevent soil and water contamination. 

The use of fertilizers is captured under 

the requirement that use of 

agrochemicals (interpreted to include 

fertilizer) must be at levels to prevent 

soil and water contamination. 




Specific: 

C1: I6.1.2, I6.1.3 




Specific: 

C1: I6.1.2 

C2: I6.2.1 

C3: I6.3.1 

C4: I6.4.3, I6.4.4 

Specific: 

C3: I6.3.2 

C4: I6.4.3 

Specific: 

C4: I6.4.3, I6.4.4 

Conforms 

Conforms 

Conforms 

Conforms 

Conforms 

Conforms 



5.2.3 Criterion 3 – Maintenance and Encouragement of Productive Functions 

of Forests (wood and non-wood) 

PEOLG 

Criterion 



3.1 a The Standard’s primary goal is the 

implementation of auditable actions by 

forest owners to maintain the 

capability of forests to produce a range 

of wood and non-wood products and 

services on a sustainable basis. 

3.1 b The Standard requires that forest 

management planning “must be 

formulated, documented and reviewed 

periodically, in the short and long term 

for the achievement of sustainable 

economic development, in 

consideration of new markets and 

economical activities in relation to all 

the products and relevant services in 

management unit”. 


management plans to account for the 

different uses and functions of forest 

areas covering merchantable and nonmerchantable 

forest goods and services 

for the socio-cultural content including 

the experience and traditional 

knowledge of local community and 

other interested parties in using 

forests. 




Specific: 

C2: I6.2.1, I6.2.3, 

I6.2.4 




Specific: 

C2: I6.2.2, I6.2.3 

C6: I6.6.3 




Specific: 

C2: I6.2.3, I6.2.4 

C6: I6.6.3, I6.6.4 


UNIT 1152 (2009). 


management practices to be 

implemented to improve forest 

resources and encourage the 

production of a diversified output of 

goods and services. The evidence for 

quality is demonstrated in the 

justification, objectives, parameters, 

procedures, documentation and 

register requirements for each 

indicator. 

3.2 b The Standard specifies practices to 

maintain productive capacity of 

plantation forests during planting 

(regeneration), tending and harvesting 

activities with aim of reducing damage 

to retained stands and soil and water 

resources. 

3.2 c Standard requires owners’ commitment 

to practice sustainable forestry, 

incorporating both wood and non-wood 

forest products. The Standard requires 

optimum commercial use of harvested 

forest products. The Standard requires 




Specific: 

C2: I6.2.2, I6.2.3, 

I6.2.4 

C3: I6.3.1 

C4: I6.4.1, I6.4.3, I 

6.4.4 




Specific: 

C2: I6.2.2, I6.2.3, 

I6.2.4 

Conforms 

Conforms 

Conforms 

Conforms 

Conforms 

Conforms 



forest practices to maintain the 

capacity of soils. 

3.2 d The Standard requires the planning 

construction and maintenance of 

infrastructure to achieve Sustainable 

Forest Management. 

C4: I6.4.1, I6.4.3 


(General Plan of 

Management) 

Specific: 

C1: I6.1.2 

C2: I6.2.1 

C4: I6.4.3, I6.4.4 

Conforms 

5.2.4 Criterion 4 – Maintenance, Conservation and Appropriate Enhancement 

of Biological Diversity in Forest Ecosystems 

PEOLG 

Criterion 



4.1 a The Standard requires management 

planning to maintain and enhance 

biodiversity at ecosystem, species and 

genetic level, and where appropriate 

at landscape level. 

4.1 b The Standard requires forest 

management planning to incorporate 

terrestrial inventory and mapping of 

national ecosystems and species and 

their condition and importance, using 

published and in-situ resources. 


4.2 a The Standard relates to plantation 

management. The Standard requires 

the use of species and varieties 

appropriate to site with an evaluation 

of the impact of species (variety) on 

the ecosystems and genetic integrity of 

native species. 

4.2 b The Standard requires an account, for 

each site, of the origins of species (and 

varieties) with goal of identifying 

appropriate species as well as “the 

impact on the ecosystems and genetic 

integrity of the native species and 

local origins”. 


management practices to increase the 

genetic, species and structural 

diversity of natural ecosystems. 

4.2 d The Standard requires that the 

traditional management systems and 

knowledge associated with the use of 

forests by local communities and other 

interested parties must be considered 

and respected in forest management 

practices. Also the Standard requires 

the tracking of level of wood and nonwood 

resources produced from forest 

to demonstrate the maintenance and 

improvement of socio-economic 




Specific: 

C1: I6.1.2, I6.1.3 

C2: I6.2.1 




Specific: 

C1: I6.1.1, I6.1.2, 

I6.1.3 

Specific: 

C1: I6.1.1, I6.1.2, 

I6.1.3 

C2: I6.2.1 

Specific: 

C2: I6.2.1 

Specific: 

C1: I6.1.2, I6.1.3 




Specific: 

C2: I6.2.4 

C6: I6.6.4 

Conforms 

Conforms 

Conforms 

Conforms 

Conforms 

Conforms 



benefit to society. 

4.2 e The Standard requires the protection 

of natural forests, water and soil 

resources and biodiversity during forest 

management and harvesting. 

4.2 f The Standard requires infrastructure to 

be planned, constructed and 

maintained to “accomplish a 

Sustainable Forest Management”. 

Delivery of sustainable forest 

management explicitly requires 

damage minimisation to ecosystems. 

4.2 g The Standard requires forest 

management practices to conserve 

native plant and animal species, 

control exotic animal and plant species 

that might represent a threat or pest 

and control animal load in areas under 

husbandry and/or joint use. 

4.2 h The Standard requires silvicultural 

practices to include procedures for 

conservation of biological diversity 

through retention of dead and fallen 

and standing for fauna habitats and 

maintenance of ageing forests of “rare 

or singular species”. The Standard also 

requires forest management practices 

to consider “the potential effects of 

these measures on the safety of people 

and the protection and stability of 

forests and surrounding ecosystems 

simultaneously”. 

4.2 i The Standard requires the conservation 

of sites of special biotypes (including 

catchment, wetlands and rocky 

surfaces) and their restoration if 

appropriate. 




Specific: 

C1: I6.1.2, I6.1.3 

C2: I6.2.1 

C3: I6.3.1 

C4: I6.4.2, I6.4.3, 

I6.4.4 

Specific: 

C1: I6.1.2 

C2: I6.2.1 

C3: I6.3.1 

C4: I6.4.2, I6.4.3, 

I6.4.4 

Specific: 

C1: I6.1.2 

C4: I6.4.2 

Specific: 

C1: I6.1.2 

Specific: 

C1: I6.1.2 

Conforms 

Conforms 

Conforms 

Conforms 

Conforms 

5.2.5 Criterion 5 – Maintenance and Appropriate Enhancement of Protective 

Functions in Forest Management (notably soil and water) 

PEOLG 

Criterion 




management planning to maintain and 

improve the protective functions of 

forests by “seeking a balance between 

conservation of natural resources, 

historic-cultural and socio-economic 

aspects, productivity (technical, 

economic and financial) and general 

society’s well being”. Key components 




Specific: 

C1: I6.1.2 

C4: I6.4.3, I6.4.4 

Conforms 



for maintaining and enhancing 

protective functions of forests for 

society include conservation of 

biodiversity to improve the capability 

of plantations in responding to 

“adverse environmental factors and to 

strengthen natural systems of 

regulation”; infrastructure protection 

and conservation and maintenance of 

soil and water resources. 

5.1 b The Standard requires the forest 

management plans to take full account 

of areas that fulfil specific or 

recognised protective functions for 

society. 


management practices to undertake 

risk assessment of the potential soil 

erosion and degradation and 

preventive actions which will be 

implemented. The Standard requires 

procedures to control animal “load in 

areas under husbandry and/or joint 

use” 

5.2 b The Standard requires that all forest 

management units be considered a 

water resource with an objective of 

preventing contamination of water 

resources from forest management 

activities, agrochemicals, fuels and 




Specific: 

C6: I6.6.4 


Specific: 

C4: I6.4.2 

lubricants. 

5.2 c The Standard requires the installation 

and maintenance of infrastructure 

(roads and bridges) to ensure minimum 

impact of forest management on soil 

and water resources in the landscape. 

Specific: 

C4: I6.4.4 

Specific: 

C1: I6.1.2 

C4: I6.4.2, I6.4.3, 

I6.4.4 

Conforms 

Conforms 

Conforms 

Conforms 

5.2.6 Criterion 6 – Maintenance of Other Socio-economic Functions and 

Conditions 

PEOLG 

Criterion 



6.1 a The Standard contains requirements 

for forest management planning to 

respect the multiple functions of 

forests to society with explicit 

recognition of role of forestry in rural 

development and new opportunities for 

employment. 

6.1 b The Standard requires property rights 

and tenure arrangements to be 

included in the management plans. 

Legal, customary and traditional rights 

of local community must be identified 

and incorporated into management 

plans. 




Specific: 

C2: I6.2.2, I6.2.3, 

I6.2.4 

C6: I6.6.3, I6.6.4 

Specific: 

C6: I6.6.3, I6.6.4 

C7: I6.,7.1 

Conforms 

Conforms 



6.1 c The forest owner has responsibility to Specific: 

provide for access to forests for C6: I6.6.3, 6.6.4 

specific purposes (e.g. recreation). C7: I6.7.1 

6.1 d The Standard requires forest Specific: 

management plans to identify and C6: I6.6.4 

conserve historical, cultural, spiritual 

and recreational values of significance 

to deliver the socio-economic and 

multiple use functions of forests. 

6.1 e The Standard requires forest Specific: 

management plans to specify C6: I6.6.2 

activities, including on-going training, 

to be implemented to demonstrate 

that workers (forest managers, 

contractors, employees and forest 

owners) are qualified for “activities 

they do”. 


6.2 a The Standard requires forest General: Section 4.1 

management practices to incorporate (Requirement for The 

the experiences and traditional Plantification) 

knowledge of local communities and Specific: 

other interested parties. 

C6: I6.6.3, I6.6.4 

6.2 b The Standard requires forest 

management practices to achieve safe 

working conditions for workers and 

contractors. 


management operations to take into 

account all socio-economic functions of 

forests including employment, safety, 

training, rural development, and 

recreational and aesthetic values 

operating at landscape level. 

Specific: 

C6: I6.6.1 

Specific: 

C6: I6.6.1, I6.6.2, 

I6.6.3, I6.6.4 

Conforms 

Conforms 

Conforms 

Conforms 

Conforms 

Conforms 


The UFCS Standard for SFM (UNIT 1152: 2009 and UNIT 1151: 2009) is in compliance with the 

requirements of PEOLG. 



6. Assessment of the UFCS Chain of Custody Standard against 

PEFCC Requirements 

UFCS documentation (refer to GD02, GD08 and SD09) requires organisations who desire chain of 

custody certification under the UFCS to demonstrate compliance with requirements of PEFCC’s 

Annex 4 (Chain of Custody of Forest Based Products – 17/6/2005) and associated appendices. 

Conforms 



7. Assessment of the Logo Usage Rules against PEFCC 

Requirements 

PEFC Uruguay has rules and monitoring procedures (refer to SD05) requiring certified 

organisations to use PEFC logo consistent with requirements of PEFCC GL 1/2006 (Issuance of 

PEFC Logo Use Licence by PEFCC). 

Conforms 



8. Assessment of the UFCS Certification and Accreditation 

Arrangements against PEFCC Requirements 

8.1 Certification Bodies 

8.1.1 Competence of Certification Bodies 

1) Does the scheme documentation require that certification shall be carried out by 

impartial, independent third parties that cannot be involved in the standard-setting 

process as governing or decision making bodies, or in the forest management and are 

independent of the certified entity? (Annex 6, 3.1) 

UFCS documentation (refer to Section 5, SD03) requires that certification be performed by 

organisations that are “impartial and independent” and not involved in any process of 

normalisation (standard setting) or part of PEFC Uruguay. 

Conforms 

2) Does the scheme documentation require that a certification body for forest 

management certification or chain of custody certification against a scheme specific chain 

of custody standard shall fulfil requirements defined in ISO 17021 or ISO Guide 65? 

(Annex 6, 3.1) 

UFCS documentation (refer to SD03, Section 3) requires a certification body to have 

documented procedures “compatible with the requirements of ISO 17021 or ISO Guide 65”. 

Conforms 

3) Does the scheme documentation require that certification bodies carrying out chain of 

custody certification against PEFC Annex 4 fulfil requirements defined in ISO Guide 65? 

(Annex 6, 3.1) 

UFCS documentation (refer to SD03, Section 3) requires certification bodies undertaking CoC 

certification to have a “system that complies with requirements of ISO 65 Guide”. 

Conforms 

4) Does the scheme documentation require that certification bodies carrying out forest 

certification shall have the technical competence in forest management on its economic, 

social and environmental impacts, and on the forest certification criteria? (Annex 6, 3.1) 

UFCS documentation requires certification bodies to have competencies in UNIT 1152:2009 

(Sustainable Forest Management – Criteria and Indicators) (refer to SD03, Section 3); and 

require personnel to have competence in the field of forest management and related social, 

economic and environmental impacts (refer to SD03, Section 5 (m)). 

Conforms 

5) Does the scheme documentation require that certification bodies carrying out chain of 

custody certification have technical competence in forest based product procurement and 

processing, material flows in different stages of processing and trading? (Annex 6, 3.1) 

UFCS documentation requires certification bodies to have competencies in Chain of Custody 

(PEFC – Annex 4) (refer to SD03, Section 3); and personnel with required competencies in forest 

based chain of custody processes (refer to SD03, Section 5 (m)). 

Conforms 



6) Does the scheme documentation require that certification bodies have a good 

understanding of the national PEFC system against which it carries out forest or chain of 

custody certification? (Annex 6, 3.1) 

UFCS documentation (refer to SD03, Section 3) requires certification bodies “be informed on 

the PEFC Uruguay Scheme for the certification of Forest Management or Chain of Custody”. 

Conforms 

8.1.2 Auditors 

7) Does the scheme documentation require certification bodies have the responsibility to 

use competent auditors that have adequate technical know-how on the certification 

process and issues related to forest management or chain of custody respectively? (Annex 

6, 3.2) 

UFCS documentation (refer to SD04, Sections 4, 5 and 8) requires certification bodies to use 

auditors that have specified qualifications, “knowledge and experience from Uruguayan forestry 

sector” and capabilities in audit techniques to competently perform audits. 

Conforms 

8) Does the scheme documentation require that auditors fulfill general criteria of ISO 

19011 for Quality Management Systems auditors or for Environmental Management 

Systems auditors? (Annex 6, 3.2) 

UFCS documentation (refer to SD04, Section 4) requires auditors to meet criteria defined in 

“ISO/ICC 19011:2002 Norm”. 

Conforms 

9) Does the scheme documentation include additional qualification requirements for 

auditors carrying out forest management or chain of custody audits? (Annex 6, 3.2) 

UFCS documentation (refer to SD04, Sections 5 and 8) details additional criteria for auditors, 

required by PEFC Uruguay, in order to undertake forest management and chain of custody 

certification. The criteria relates to education, work experience, competence and training. 

Conforms 

8.2 Certification Procedures 

10) Does the scheme documentation require that certification bodies shall have 

established internal procedures for forest management and/or chain of custody 

certification? (Annex 6, 4) 

UFCS documentation (refer to SD03, Section 5(p)) requires certification bodies to have internal 

procedures for forest management and/or chain of custody certification. 

Conforms 

11) Does the scheme documentation require that applied certification procedures for 

forest management certification or chain of custody certification against a scheme 

specific chain of custody standard shall fulfil or be compatible with requirements defined 

in ISO 17021 or ISO Guide 65? (Annex 6, 4) 

UFCS documentation (refer to SD03, Section 5(p)) requires certification bodies to establish and 

document internal procedures compatible with the requirements of ISO 17021 or ISO Guide 65 



for forest management standard. As UFCS uses Annex 4 requirements for chain of custody 

certification (this is not a scheme specific CoC standard) the consultants’ response refers only 

to forest management standard. 

Conforms 

12) Does the scheme documentation require that applied certification procedures for chain 

of custody certification against Annex 4 shall fulfil or be compatible with the 

requirements defined in ISO Guide 65? (Annex 6, 4) 

UFCS documentation (refer to SD03, Section 3 and 5(n)) requires certification bodies 

undertaking chain of custody certification (to PEFCC Annex 4 requirements) to have quality 

systems consistent with requirements of ISO Guide 65 adjusted to the type, range and volume 

of work. 

Conforms 

13) Does the scheme documentation require that applied auditing procedures shall fulfil or 

be compatible with the requirements of ISO 19011? (Annex 6, 4) 

UFCS documentation (refer to SD03, Section 5(q)) requires certification bodies to “have audit 

procedures according to the ISO 19011 requirements”. 

Conforms 

14) Does the scheme documentation require that the certification body informs the 

relevant PEFC NGB about all issued forest management and chain of custody certifications 

and changes concerning validity and scope of these certificates? (Annex 6, 4) 

UFCS documentation (refer to SD03, Section 5(w)) requires certification bodies to inform PEFC 

Uruguay about all certifications and changes to the scope and validity of certification 

certificates. 

Conforms 

15) Does the scheme documentation require that the certification body carries out 

controls of PEFC logo usage if the certified entity is a PEFC logo user? (Annex 6, 4) 

UFCS documentation (refer to SD03, Section 5(e)) requires certification bodies to “control the 

proper use of PEFC logo by the certified entities”. 

Conforms 

16) Does the scheme documentation require that the maximum period for surveillance 

audits not exceed one year? (Annex 6) 

UFCS documentation (refer to SD03, Section 5(p)) requires certification bodies to have followup 

audits (surveillance audits) not exceeding one year. 

Conforms 

17) Does a maximum period for assessment audit not exceed five years for both forest 

management and chain of custody certifications? (Annex 6, 4) 

UFCS documentation (refer to SD03, Section 5(p)) requires certification bodies to have 

reassessment audits (renovation audits) for forest management or CoC not exceeding 5 years. 

Conforms 



18) Does the scheme documentation include requirements for public availability of 

certification report summaries? (Annex 6, 4) 

UFCS documentation (refer to SD03, Section 9(g)) includes requirements for public availability 

of certification report summaries. 

Conforms 

19) Does the scheme documentation include requirements for usage of information from 

external parties as the audit evidence? (Annex 6, 4) 

UFCS documentation provides for usage of information from external parties as audit evidence. 

The UFCS documentation requires certification bodies to have procedures that allow 

participation by all parties in the control and function of the certification system (refer to 

SD03, Section 5(f)). 

Conforms 

20) Does the scheme documentation include additional requirements for certification 

procedures? (Annex 6, 4) 

UFCS documentation (refer to SD03) specifies procedures consistent with requirements of 

PEFCC’s Annex 6, Section 4. 

Conforms 

8.3 Accreditation 

21) Does the scheme documentation require that certification bodies carrying out forest 

management or chain of custody certification are accredited by a national accreditation 

body? (Annex 6, 5) 

Certification bodies must be “endorsed by the Uruguayan Organisation of Accreditation (OUA) or 

other organisation recognised by IAF” (refer to SD03 Section 3(a)). The OUA is the national 

accreditation body for certification bodies (www.organismouruguayodeacreditacion.org) 

Conforms 

22) Does the scheme documentation require that an accredited certificate bears an 

accreditation symbol of the relevant accreditation body? (Annex 6, 5) 

UFCS documentation does not explicitly require that accredited certificates issued by 

certification body must bear the accreditation symbol of the relevant accreditation body. 


23) Does the scheme documentation require that the accreditation shall be issued by an 

accreditation body which is a part of the International Accreditation Forum (IAF) umbrella 

or a member of IAF’s special recognition regional groups and which implement procedures 

described in ISO 17011 and other documents recognised by the above mentioned 

organisations? (Annex 6, 5) 

UFCS documentation (refer to SD03, Section 3(a)) requires that accreditation of certification 

bodies is performed by OUA or accreditation body which is recognised by IAF. The OAU is a 

member of regional groups recognised by IAF. 

Conforms 



24) Does the scheme documentation require that certification body undertake forest 

management or/and chain of custody certification against a scheme specific chain of 

custody standard as “accredited certification” based on ISO 17021 or ISO Guide 65 and 

the relevant forest management or chain of custody standard(s) shall be covered by the 

accreditation scope? (Annex 6, 5) 

UFCS documentation (refer to SD03, Section 3) requires certification bodies to be accredited 

specific to UNIT 1152 (Sustainable Forest Management and CoC) and PEFC Annex 4 for CoC and 

have quality systems in place that are consistent with requirement of ISO 17021 or ISO Guide 

65. 

Conforms 

25) Does the scheme documentation require that a certification body undertaking chain of 

custody certification against PEFC Annex 4 as “accredited certification” based on ISO 

Guide 65? (Annex 6, 5) 

UFCS documentation (refer to SD03, Section 3) requires that CoC certification bodies must have 

quality systems which meet requirements of ISO Guide 65. 

Conforms 

8.4 PEFC Notification of Certification Bodies 

26) Does the scheme documentation provide for PEFC notification of certification bodies? 

(Annex 6, 6) 

UFCS documentation (refer to SD03, Section 3(e)) requires that certification bodies must have 

received notification from PEFC Uruguay or PEFC International of their endorsement. UFCS 

documentation does not explicitly detail requirements for notification conditions to cover 

administration conditions, financial conditions and compliance with accreditation conditions. 

Partly Conforms 

27) Are the procedures for PEFC notification of certification bodies non-discriminatory? 

(Annex 6, 6) 

UFCS documentation does not contain explicit procedures for PEFC notification of certification 

bodies in a non-discriminatory manner. The UFCS documentation refers to policies and 

procedures of certification bodies not being discriminatory (refer to SD03, Section 4). 



Utilizing the information presented above, the consultants assessed that the UFCS certification 

and accreditation arrangement does not meet PEFC Scheme requirements due to nonconformities. 

These non conformities are associated with i) a lack of specific requirements for 

accreditation certificates issued by certification bodies to include the accreditation symbol of 

OUA, and ii) and lack of explicit procedures for PEFC notification of certification bodies in a non 

discriminatory manner. 

Regarding i) (Section 8.3, question 22) discussions during Field Visit with representatives of OUA 

indicated they would consider this requirement in finalising procedures for the accreditation of 

certification bodies under the UFCS. 



Regarding ii) (Section 8.4. question 27) PEFC Uruguay commented during Field Visit that while 

current UFCS documentation does not fully cover PEFC requirements, the practice of PEFC 

Uruguay would be to inform certificate bodies of information detailed by PEFCC in a nondiscriminatory 

manner. 



Annex 1. Comments Submitted to ITS Global during Public 

Consultation Period 

One submission was received as a result of public consultation period for UFCS. 

The submission was from Cassie Phillips, Vice President, Sustainable Forests and Products, 

Corporate Headquarters, Weyerhaeuser dated 24 September 2010. 

The general theme of the Weyerhaeuser submission is to express support of PEFCC’s assessment 

and recognition of UFCS. The submission specifically makes the following comments: 

1) Uruguay’s policy for forest industry development is concentrated exclusively on renewable 

forestry plantations; 

2) Uruguay’s policies of identifying “forestry priority soils” underpin the regulatory structure 

for the establishment of plantations. These soils are assessed as having limitations for 

commercial crops and intensive animal production, but are particularly suitable for forest 

plantations; 

3) Regulatory approvals are required from Uruguayan Ministry of Agriculture and Ministry of 

Environment to establish plantations; 

4) The importance of expanding forest products industry in terms of Uruguayan sustainable 

and development initiatives and exports; 

5) The importance of forest certification to generate market confidence, specifically to show 

that Uruguay plantation practices are consistent with SFM principles; 

6) The independence of UNIT in developing and approving forest management standards. 



Annex 2. Report on the Field Visit 

A Field Visit was undertaken by Dr Bob Smith from 23 to 27 August 2010, with the purpose of 

gaining additional information to support the conformity assessment of the UFCS against the 

requirements of PEFCC. 

Detailed below are the results of meetings with various groups involved in the development and 

approval of the UFCS. 

1) Meeting with PEFC Uruguay 

Attendees: 

Mr Gerardo Barrios (President) 

Mr Civil Alvaro Molinari (Vice President) 

Mr Oscar Regueira 

Dr Ricardo Methol 

Mr Edgardo Cardozo (Society of Forestry Producers) 

Ms Andrea Regusci (Society of Forestry Producers) 

Discussions: 

The meeting covered the following issues: 

i) Explanation of the importance of PEFC recognition of the UFCS, specifically in regard to 

maintaining market access (in particular, markets in the USA and Europe). 

ii) 

The evolution and processes followed in the formation of PEFC Uruguay, and the goal of 

aligning the UFCS with requirements of PEFCC. 

iii) The development and co-ordination of forest management standards (UNIT 1151:2009 

and UNIT 1152: 2009) by Specialized Technical Committee for Sustainable Forest 

Management (STC-SFM) which operated consistent with requirements of UNIT. The STC- 

SFM operated independently from PEFC Uruguay. 

iv) 

Clarification of issues raised in Interim Report on the conformity of the UFCS against 

PEFCC requirements. 

v) Levels of participation by diversity of groups in development of forest management 

standards (UNIT 1151:2009 and UNIT 1152:2009). Consensus that wide diversity of groups 

representing government (forestry and environment departments), academia, industry, 

social/environmental issues and unions participated. PEFC Uruguay noted that, although 

invited, no environmental NGO participated in development of Standard. PEFC Uruguay 

noted that peak environmental NGO in Uruguay, Group GUAYUBIRA 

(www.guayubira.org.uy) has a national initiative against establishment of monoculture 

plantations in Uruguay. 

vi) 

PEFC Uruguay considers the UFCS to be a challenge to implement. The implementation of 

the UFCS will lead to significant gains in the economic, social and environmental 

outcomes sought from plantation forests in Uruguay. 

2) Meeting with Instituto Uruguayo de Normas Técnicas (UNIT) 

Attendee: Mr Ferdando Gomez (Executive Director Norms) 

Discussion: 

The meeting covered the following issues: 

i) The history of UNIT in developing and approving technical standards in Uruguay. 

ii) The processes UNIT follows (methodology) in developing standards focusing on the role of 

specialized technical committees. 

iii) The evolution of development and approval of forest management standards commencing 

with UNIT approval of Project “Access to markets and the integration through technical 

normalization” and approval of UNIT 1151: 2009 and UNIT 1152: 2009 by UNIT’s General 

Committee of Norms on 14 December 2009. 

iv) Explanation of the UNIT statutes and associated documentation for impartial handling of 

disputes and complaints associated with standard setting processes. 

v) Review of a sample of minutes (relating to meeting of STC-SFM between 2006 and 2009). 



vi) 

Explanation of process followed for public consultation of forest management standards 

UNIT 1152: 2006 and UNIT 1151: 2006 in 2009, including use of UNIT’s website, media 

advertisements and 24 individually targeted letters requesting comment. 

It was explained that while intended for consultation to run for 60 days there was an 

error in the media advertisement identifying public consultation period from 1 April to 23 

May 2009, a period of 53 days. 

UNIT representative explained and showed evidence from electronic logs that the forest 

management standards were on UNIT’s website for the period 1 st April 2009 to 28 th June 

2009. 

UNIT would have accepted any submission received after the advertised closure of public 

consultation period (23 May 2009) as a valid submission. However none were received. 

3) Meeting with representatives of Specialized Technical Committee – Sustainable Forest 

Management (STC-SFM): 

Attendees: 

Mr Juan Cabris, Forestry Department, University of Uruguay – Former Chairperson of STC- 

SFM 

Ms Carolina Sans Dobe, Associate Professor, Dept of Forestry, University of Uruguay 

Ms Ana Quintillan, Benho de Seguros Del Estado (BSE) 

Mr Miguel Farina, Manager, Weyerhaeuser Products, SA 

Ms Mary Rosas, Consultant, Terrasys 

Mr Peter Baptista, Manager, Forestry Directorate, Dept of Agriculture 

Discussions: 

i) Outline of the long development (over 40 meetings) and testing process for UNIT 1151 

and UNIT 1152, including three versions between 2006 and 2009. 

ii) Discussions establishing that the STC-SFM operated by consensus. 

iii) Explanation that the STC-SFM’s activities were co-ordinated and undertaken consistent 

with UNIT procedures. 

iv) Explanation that the STC-SFM took into account the intent of ILO Protocol for Health and 

Safety for Forestry in their deliberations and the requirements of Uruguayan legislation 

on worker health and safety. 

4) Meeting with Forestry Directorate, Dept of Agriculture (Uruguay): 

Attendees: 

Mr Daniel San Roman, Director, Forestry Division 

Mr Peter Baptista, Manager, Forestry Division 

Discussions: 

i) History of proactive Uruguayan Government policy to expand forestry plantations within 

the framework of protecting high quality agricultural lands for cropping and dairying. 

ii) Explanation and examples of process the Forestry Division must follow by regulation to 

approve plantation development proposals above 100 ha. 

iii) The UFCS is consistent with the Uruguayan Government’s policies and legal requirements 

for establishment and management of forestry plantations. 

5) Meeting with Dept of Environment (Uruguay): 

Attendees: 

Mr Jorge Rucks, National Director, Dept of Environment (Uruguay) 

Mr Luis Sayagues, Adviser 

Discussions: 

i) Plantation forestry in Uruguay is conducted within a framework established for 

agriculture. 

ii) The focus of regulatory process is to organise forests within landscape on soils specified 

by Government regulations. 



iii) Plantation forestry is a major component of sustainable development policy of 

Government. 

iv) Forest management standards (UNIT 1152: 2009 and UNIT 1151: 2009) considered to be of 

“high quality and practical”. 

v) Department of Environment had very satisfactory input in the development and approval 

of forest management standards. 

vi) Department of Environment’s major interest in forest plantations relate to flow-on 

impacts associated with herbicide and pesticide use, water use, biodiversity, protected 

areas, scenic amenity and protection of small farms principally dairy farms. 

vii) Commented that ENGOs (umbrella ENGO in Uruguay is Group Guayubira – 

www.guayubira.org.au) while invited did not participate in development of forest 

management standards as they do not support expansion of plantations in Uruguay, 

primarily citing: 

Adverse changes in landscape; 

Use of introduced species and monocultures; 

Implied support for international companies; 

Impacts on protected areas; and 

Adverse cultural and social impacts on local communities. 

6) Meeting with Organismo Uruguayo De Acreditacion (OUA): 

Attendee: Mr Feodero Kunin, President 

Discussion: 

i) Explanation, based around power point presentation, of the role and authorities of OUA 

in accrediting certification bodies. 

ii) OUA’s utilization of independent Accreditation Committee to accredit certification 

bodies. 

iii) OUA’s procedures for finalizing accreditation of certification bodies based on UFCS 

procedures. 

7) Meeting with College of Agriculture, University of Uruguay: 

Attendees: 

(a) Soils Department 

Dr Duran, Former Dean 

Dr Mano Perez 

Mr Jorge Hernandez 

(b) Forestry Department 

Associate Professor Carolina Sans Dobe (Forest technical expert) 

Dr Juan Cabris (Forest technical expert) 

Mr Luis Gallo (Forest technical expert) 

Ms Graciela Rumero (Forest pests expert) 

Dr Carlos Pelegrino (Landscape expert) 

Discussions: 

i) Explanation of the involvement of University of Uruguay staff in the development of 

forest management standards including provision of technical advice and pilot testing. 

ii) 

iii) 

Consensus that forest management standard in the UFCS was appropriate for Uruguay. 

Highlighted necessity to ensure field staff and managers receive appropriate training to 

successfully implement the UFSC. 



Annex 3. PEFC Council Minimum Requirements Checklist 

Detailed below is an assessment of the UFCS against PEFCC minimum requirements checklist 

(GL2/2010) covering: 

‣ Part I - Checklist for Standard Setting Process (Annex 2) 

‣ Part II Checklist for Certification Schemes and their Implementation (Annex 3) 

‣ Part III - Checklist for UFCS Compliance with PEOLG (Annex 3, Chapter 4.2) 

‣ Part VI - Checklist for the UFCS CoC Standard (Annex 4) 

‣ Part VII - Checklist for Certification and Accreditation Procedures (Annex 6) 

The column titled “Consultant assessment & reference to assessment report (where relevant)” 

is an assessment of the UFCS’ level of conformity with PEFCC requirements for the specific 

question, cross referenced to a section in the assessment report. Where a suitable cross 

reference in the assessment report is not available, a response is provided in the column 

headed “Reference to application documents”. 

For tracking purposes the Checklist retains the responses submitted by PEFC Uruguay as part of 

UFCS documentation (highlighted in red). The original response submitted by PEFC Uruguay 

used an earlier version of the Checklist (GL 2/2008). In the following tables, PEFC Uruguay’s 

answers have been integrated into the current Checklist format (GL 2/2010). It is also 

important to note that column titled “Reference to application documents” refers to the 

reference used by PEFC Uruguay in submitting documentation. When matching PEFC Uruguay’s 

reference to Consultant’s assessment reference (last column of Checklist) the following table 

may assist the reader: 

Reference Document in 

PEFC Uruguay Documentation 

PEFC Application Letter 

Uruguayan Forest Certification Scheme 

PEFC Uruguay Acta 18-12-2009 

PEFC Uruguay Statutes 

Annex 1 UFCS 

Annex 2 UFCS 

PEFC Checklist - December 

Report UNIT 1151 - 2009 

Report UNIT 1152 - 2009 

UNIT 1151 – 2009 – Amended Version 

UNIT 1152 – 2009 Amended Version 

Documents Numbered – DG01 to DG09 

Equivalent Document used in 

Consultant’s Assessment 

GD03 

GD02 

GD03 

GD04 

GD03 

GD06 

GD07 

GD08 

GD09 

GD10 

GD11 

SD01 to SD09 

PART I: MINIMUM REQUIREMENTS CHECKLIST FOR STANDARD SETTING PROCESS (ANNEX 2) 

SCOPE: 

Part I covers the requirements for the standard setting process defined in Annex 2 of the PEFC 

Council Technical Document (Rules for Standard Setting). 

No. 

Question 

Reference 

to PEFC 

Council 

doc. 

1 Has the development of the 

Annex 2, 3.2 

certification standards been 

independent from the certification 

and accreditation process? [*1] 

Assess. 

Basis* 

Yes/ 

No* 

Standard setting for forest certification 

Doc. 

Yes 

Reference to 

application 

documents 

Section 7 of the 

Uruguayan 

Forest 

Certification 

Scheme (UFCS). 

Consultant assessment & 

reference to assessment 

report (where relevant) 

Conforms 

(Section 3.1.1) 



No. 

Question 

Reference 


Council 

doc. 

Assess. 

Basis* 

Yes/ 

No* 

2 Has the standard setting process 

been carried out at national and/or 

sub-national levels? Annex 2, 3.3 Doc. Yes 

Reference to 

application 

documents 

Process Yes Annex 1 of UFCS 


UFCS. GD 07.01. 

Requirements 

for group 

certification 




Conforms 


Conforms 

National level 


Process 

Yes 


UFCS. Annex 1 

Conforms 


3 Has the standard setting process 

been co-ordinated by the PEFC 

National Governing Body? [*1] 

4 Has the certification standard been 

drafted to be applied at individual 

and/or group and/or regional level? 

Annex 2, 3.3 Doc. Yes 

Annex 2, 3.3 

Process Yes Annex 1 

Yes 

Section 1 of 

UFCS. 


UFCS, 5.1, 5.2 

and DG 07.01. 

Conforms (Section 3.1.1) 

Conforms 


Conforms 


5 Has the development of 

certification criteria been initiated 

by national forest owners' 

Annex 2, 

3.4.1 

organisations or national forestry 

sector organisations having support 

of the major forest owners' 

organisations in that country? [*1] 

Yes 

Section 1 and 7 

of UFCS 

Conforms 


6 Have all relevant interested parties 

representing the different aspects of 

sustainable forest management 

Annex 2, 

been invited to participate in the 

3.4.1 

standard setting process and a 

created Forum? [*1] 

7 Do consensus-building procedures of 

the Forum provide for balanced 

Annex 2, 

representation of interest 

3.4.1 

categories? [*2] 

8 Have the views of all relevant 

interested parties been documented 

and considered in an open and 

transparent way? [*3] Annex 2, 

3.4.1 

Doc. 

Yes 





Process Yes Annex 1 Does not Conform 


Doc. 

Yes 


Doc. 

Yes 





Conforms 


Conforms 


Conforms 


9 Has the formal approval of standards 

been based on evidence of 

consensus? [*3] Annex 2, 

3.4.1 


Doc. 

Yes 



UFCS 

Conforms 


Conforms 


Conforms 




No. 

Question 

10 Does the implementation of the 

consensus based approach comply 

with Guideline GL 5/2006 

Reference 


Council 

doc. 

11 Has the Forum defined its own 

written procedures which have been 

made available to interest parties 

upon request? [*2] Annex 2, 

3.4.1 

12 Do the written procedures for 

standard setting contain an appeal 

mechanism for impartial handling of 

any substantive and procedural 

complaints? [*2] 

13 Has the start of the standard setting 

process been communicated to the 

public? [*3] 

Assess. 

Basis* 

Yes/ 

No* 

GL 5/2006 Doc. Yes 


Doc. 

Yes 


Annex2, 

3.4.1 Doc. No 

Annex2, 

3.4.2 

Process 

Doc. 

No 

Yes 

Reference to 

application 

documents 





VER CON UNIT 


14 Has the information on the Annex 2, 

development process been 3.4.2 Doc. Yes 

distributed and discussed? [*3] 

15 Has the final draft standard been 

available to all interested parties, e.g. 

by posting it on the Internet? 

[*3] 

16 Has the final draft standard been 

sent out for formal national 

Annex 2, 

consultation process? [*3] 3.4.3 

17 Have views of interested parties 

been discussed? [*3] Annex 2, 

3.4.3 

18 Has the Forum given general 

information on the changes made as 

a result of a consultation process? [*3] Annex 2, 

3.4.3 

19 Had the consultation been at least 

[*3] 

60 days? Annex 2, 

3.4.3 

20- 

34 

Process 

Yes 

Annex 2, 

3.4.2 Doc. Yes 

Process 

Doc. 

Process 

Doc. 

Process 

Doc. 

Yes 

Yes 





Annex 1 



Annex 1 

En proceso 


Doc. 

Yes 


Standards for chain of custody certification 

Questions relating to scheme specific 

Chain of Custody standard 








Conforms 


Conforms 


Conforms 


Conforms 


Conforms 


Conforms 


Conforms 


Conforms 


Conforms 


Conforms 


Conforms 


Conforms 


Conforms 


Conforms 


Conforms 


Conforms 


Conforms 


Conforms 


Conforms 





Pilot Testing 



No. 

Question 

Reference 


Council 

doc. 

35 Have the first results on the testing 

of the final drafts for national/subnational 

forest certification 

standards and their implementation 

arrangements been available prior to Annex 2, 5 

PEFC Council endorsement and 

mutual recognition? [*7] 

submission of the scheme for the 

Assess. 

Basis* 

Doc. 

Process 

Yes/ 

No* 

Yes 

Yes 

Reference to 

application 

documents 



Annex 2 and 3 




Conforms 

(Section 3.3) 

Conforms 

(Section 3.3) 

36 Has appropriate action been taken 

to incorporate improvements and 

recommendations prior to 

submission of the scheme for the 

PEFC Council endorsement and 

mutual recognition process? [*7] 

Annex 

2, 5 

Doc. 

Process 

Yes 

Yes 



Annex 1 

Conforms 

(Section 3.3) 

Conforms 

(Section 3.3) 

37 Have the standards on forest and 

chain of custody certifications been 

reviewed at least every 5 years or is 

it foreseen to review these standards 

at least every 5 years? 

38 Does the scheme documentation 

indicate which organisation is 

responsible to initiate the revision 

work? 

Review of Standards 

Annex 

2, 6.1 Doc. Yes 

Annex 2, 6.1 



Conforms 


Process No Not applicable Not applicable 


Yes 



Conforms 


39 Has the revision procedures been 

participatory, fair and transparent? 

[*8] 

Annex 2, 6.1 

No 




40 Has the PEFC National Governing 

Body appropriately considered the 

revisions of the general PEFC Annex 2, 6.2 

requirements for standard setting 

and implementation in the national 

standards? [*8] 

Yes 





41 Has the PEFC National Governing Annex 2, 6.2 No Not applicable Not applicable 

Body indicated to the PEFC Council 


the appropriate considerations of the 

revisions induced by the PEFC 

Council in national standards? [*8] 

Application documentation 

The application for the endorsement and mutual recognition as defined in Chapter 5 of Annex 7 (Endorsement 

and Mutual Recognition of National Schemes and their Revision) shall include information which enables the 

assessment of the applicant scheme’s compliance with the PEFC Council requirements. 

The application documentation should identify and make reference to other detailed documentation such as 

minutes, internal procedures and rules, reports, etc. which do not need to create a part of the application 

documentation. 



Asses. basis* 

YES/NO* 

The standard setting is assessed against the PEFC Council requirements in two stages (i) 

compliance of written standard setting procedures (Doc.) and (ii) compliance of the standard 

setting process itself (Process). 

If the answer to any question is no, the application documentation shall indicate for each 

element why and what alternative measures have been taken to address the element in 

question. 

[*1] Includes a description of an organisation responsible for co-ordination and decision making in the forest 

management standard setting process; details on organisations and/or individuals who participated and/or who 

were invited to participate in the standard setting process including their status (forest owners, industry, E-NGO, 

etc.); creation of a Forum and representation of different stakeholders. 

Questions: 1, 3, 5, 6 

[*2] Includes information on written procedures for forest management standard setting process adopted by the 

Forum 

Questions: 7, 11, 12 

[*3] Includes a description of the forest management standard setting process including measures for ensuring 

transparency and credibility of the standard setting process; details on meetings and other events; public 

availability of draft documents; consultation process and time periods. 

Questions: 8, 9, 13, 14, 15, 16, 17, 18, 19 

[*4] Includes a description of a organisation responsible for co-ordination and decision making of the chain of 

custody standard setting process, details on organisations and/or individuals who participated and/or who were 

invited to participate in the standard setting process including their status (forest owners, industry, E-NGO, etc.); 

creation of a Forum and representation of different stakeholders. 


[*5] Includes a description of the chain of custody standard setting process including measures for ensuring 

transparency and credibility of the standard setting process; details on meetings and other events; public 

availability of draft documents; consultation process and time periods. 

Questions: 24, 25, 29, 30, 31, 32, 33, 34 

[*6] Includes information on written procedures for chain of custody standard setting process adopted by the 

Forum. 


[*7] Includes information on pilot project(s) for the testing of forest management and/or chain of custody 

standards; scope of the pilot projects; details on organisations/ individuals participated in the pilot projects; 

results of the pilot projects and follow up actions. 

Questions: 35, 36 

[*8] Includes a description of the process of review and revision of the national standard(s) 




PART II: MINIMUM REQUIREMENTS CHECKLIST FOR CERTIFICATION SCHEMES AND THEIR 

IMPLEMENTATION (ANNEX 3) 

SCOPE: 

Part II covers requirements for certification schemes and their implementation given in Annex 3 

of the PEFC Council Technical Document (Basis for certification schemes and their 

implementation). 

No. 

Question 

Reference to 


Council doc. 

YES / NO* 

General requirements for certification criteria 

1 Are the criteria relevant to all types Annex 3, 3.6 

of forests and management 

systems, which exist in the 

nation/region they have been 

elaborated for? 

2 Do the criteria clearly express the Annex 3, 3.6 

objectives for forest management 

that can be unambiguously verified 

by different auditors? 

Reference to scheme 

documentation 

Consultant 

comment & 

reference to 

assessment 

report 

Conforms 

(Section 4.1.1 

Conforms 


3 Are management and performance 

requirements applicable at the level 

of a forest management unit? 

Annex 3, 3.6 

Conforms 


Annex 3, 3.6 Conforms 

4 Are management and performance 

also at group and regional levels? [*5] 

requirements applicable optionally 


Other requirements for Forest management criteria 

5 Does the scheme require that 

property rights and land tenure 

arrangements shall be clearly 

defined, documented and 

established for the relevant forest 

area? 

6 Does the scheme require the 

clarification, recognition and respect 

of legal, customary and traditional 

rights related to the forest land in 

compliance with chapter 3.5 of 

Annex? 

7 Does the scheme require that a 

summary of the forest management 

plan or its equivalent, which 

contains information about the 

forest management measures to be 

applied, is publicly available, except 

for confidential business and 

personal information? 

8 Are the national certification criteria 

in compliance with national laws 

programmes and policies? 

9 Are the references to national laws, 

programs and policies indicated in 

Annex 3, 3.5 

Annex 3, 3.5 

Annex 3, 3.5 

Laws and regulations 

Annex 3, 3.2, 

3.6 

Annex 3, 3.6 

Conforms 


Conforms 


Does not 

Conform 


Conforms 


Conforms 




No. 

Question 

Reference to 


Council doc. 

YES / NO* 


documentation 

Consultant 

comment & 

reference to 


report 

the scheme documentation when 

relevant, e.g., if the requirement of 

the PEOLG is not addressed in the 

certification criteria but is included 

in normative regulations? 

10 Does the scheme include the 

requirement that any apparent 

violation of the legislation shall be 

taken into consideration in internal 

and external audits? 

Annex 3, 3.2 

Conforms 


ILO Conventions 

11 Are the Core ILO Conventions 

ratified by the country and 

implemented through the legislative 

framework? 

Annex 3, 3.3 

Conforms 


12 Do the national certification criteria 

address the core elements of those 

Core ILO Conventions, which have 

been not ratified by the country? 

Annex 3, 3.3 

Conforms 


13 Has the ILO Code of Practise on 

Safety and Health in Forestry Work 

been considered in development of 

national and regional certification 

criteria? 

Annex 3, 3.3 

Conforms 


Other international conventions 

14 Are the international conventions 

relevant to forest management and 

ratified by the country and 

respected through the legislative 

framework? 

Annex 3, 3.4 

Conforms 

(Section 4.154) 

15 Are the requirements agreed upon 

in the conventions, even if they are 

not ratified by the country, 

respected in the certification criteria 

to the degree that they are covered 

in PEOLG or other reference 

documents basis approved by the 

PEFC Council? 

Annex 3, 3.4 

Conforms 


Level of application – general 

16 Are the applicants, the certified 

areas and participating forest 

owners/managers/others actors 

clearly identified in the scheme 

documentation? 

Annex 3, 4.1 

Conforms 



require that all actors involved in or 

operating on the certified area 

comply with the certification 

requirements? 

Annex 3, 4.1 

Conforms 



require that all actors individually 

certified or participating in 

regional/group certification are 

Annex 3, 4.1 

Conforms 




No. 

Question 

responsible for ensuring that 

contractors’ activities and 

operations meet the respective 

forest management criteria? 

Reference to 


Council doc. 

YES / NO* 


documentation 

Level of application – regional certification (only for schemes which include regional certification) 

19 Does the national definition of 

regional certification comply with 

the PEFC Council definition? 

20 Does the forest certification 

standard include criteria for the 

regional and also for forest 

management unit level? 


require that the assessment of the 

certification criteria defined for the 

regional level covers the whole 

region to be certified? 


require that sampling for the 

assessment of the certification 

criteria defined for the forest 

management unit level cover forest 

owners/managers/other actors 

participating in the regional 

certification? 


require that the applicant 

organisation shall be a legal entity? 


require that the applicant 

organisation should represent more 

than 50 % of forest area of the 

region? (This does not need to be 

fulfilled by the time of the start of 

certification – see reference) 


describe the applicant’s 

responsibility to assure the 

compliance of all participants with 

the certification requirements? 



responsibility to ensure that credible 

registers of participants to 

certification and certified forest area 

are kept? 



responsibility to implement rules for 

regional certification? 


define the responsibilities and 

authorities of the applicant and 

Annex 3, 4.1, a 

Annex 3, 4.1, a 

Annex 3, 4.1, a 

Annex 3, 4.1, a 

Annex 3, 4.1, a 

Annex 3, 4.1, a 

Annex 3, 4.1, a 

Annex 3, 4.1, a 

Annex 3, 4.1, a 

Annex 3, 4.1, a 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

Consultant 

comment & 

reference to 


report 



No. 

Question 

participating 

forest 

owners/managers for the inclusion 

of new participants and to inform 

the certification body thereof? 




participating 

forest 

owners/managers for the internal 

control of conformity and follow up 

corrective and preventive 

measures? 


describe that forest management 

certificate is issued to the applicant 

(certificate holder)? 


describe that participants in regional 

certification shall receive either a 

copy of the regional certificate 

including the appendix (when 

applicable) listing all participating 

forest owners or an individual 

attestation issued by the 

certification body or the applicant 

which refers to the main certificate? 


require that forest 

owners/managers/other actors can 

participate in the regional 

certification either by (i) entering 

into an individually signed 

commitment, or (ii) based on the 

majority decision of a forest owner’s 

organisation on behalf of forest 

owners they represent in the 

region? 


require that only participating forest 

owners / managers shall be 

considered as certified; their area 

counted as certified area and the 

forest raw material coming from 

thereof will be considered as 

certified raw material? 


describe that forest owners should 

submit all the forest area under his 

management in the region for 

certification? (not obligatory to be 

met but should be aimed at) 

Reference to 


Council doc. 

Annex 3, 4.1, a 

Annex 3, 4.1, a 

Annex 3, 4.1, a 

Annex 3, 4.1, a 

Annex 3, 4.1, a 

Annex 3, 4.1, a 

YES / NO* 


documentation 

Level of application – group certification (only for schemes which include group certification) 

35 Does the national definition for 

group certification comply with the 

Annex 3, 4.1 b Yes Uruguay Forest Certification 

Scheme DG 07. 

NA 

NA 

NA 

NA 

NA 

NA 

Consultant 

comment & 

reference to 


report 

Conforms 




No. 

Question 

PEFC Council definition? 


clearly define who the applicant is 

for group certification? 



responsibility to assure the 

compliance of all participants with 

the certification requirements? 



responsibility to ensure that credible 

registers are kept of participants to 

certification and certified forest 

area? 



responsibility to implement the 

rules for group certification? 


require that total forest area 

participating in group certification is 

recorded? 


describe that forest owners should 


management in the catchment area 

for the group certification? (not 

obligatory to be met but should be 

aimed at) 




participating 

forest 

owners/managers for the inclusion 

of new participants and to inform 

the certification body thereof? 




participating 

forest 

owners/managers for the internal 

control of conformity and follow up 

corrective and/or preventive 

measures? 


describe that the forest 

management certificate is issued to 

the applicant (certificate holder)? 


describe that participants in group 

certification shall receive either a 

copy of the regional certificate 

Reference to 


Council doc. 

YES / NO* 


documentation 

Consultant 

comment & 

reference to 


report 

Annex 3, 4.1 b Yes DG 07: Section 3 and 4 Refer to Section 

4.2.3 

Annex 3, 4.1 b Yes DG 07: Section 4.2 Conforms 










Annex 3, 4.1 b Yes DG 07:Section 4.8 and 4.11 Conforms 


Annex 3, 4.1 b Yes DG 07: Section 4.3 and 7.3 Conforms 


Annex 3, 4.1 b Yes Uruguayan Forest Certification 

Scheme 

DG 07:Section 4.10 

Conforms 


Annex 3, 4.1 b Yes DG 07: Section 4.10,6.2 and 6.3 Conforms 




No. 

Question 

including the appendix (when 

applicable) listing all participating 

forest owners or an individual 

attestation issued by the 

certification body or the applicant 

which refers to the main certificate? 

Reference to 


Council doc. 

YES / NO* 


documentation 

Level of application – individual certification (only for schemes which include individual certification) 

Annex 3, 4.1 c 


describe that forest owner should 


management in the catchment area 

of the certification scheme in the 

certification? (not obligatory to be 

met but should be aimed at) 

Implementation of changes to the scheme 

47 Does the scheme documentation Annex 3, 5 

define transition period(s) for 

implementation of changes to the 

endorsed scheme in compliance 

with chapter 5 of Annex 3? 

(This is not applicable to the initial 

endorsement of a scheme) 

Appeals, complaints and dispute procedures 


Body set up or appointed an 

impartial and independent dispute 

settlement body on a permanent 

basis or does it have written 

procedures for the establishment of 

a dispute settlement body on an ad 

hoc basis? 


Body established and have 

documented procedures for an 

independent dispute settlement 

body, either permanent or ad hoc, 

that takes care of those complaints 

arising from forest management or 

chain of custody scheme 

implementation that cannot be 

addressed in the dispute settlement 

procedures of the relevant 

certification or accreditation body? 

50 Can the dispute settlement body 

also resolve possible grievances in 

chain of custody certification that do 

not exclusively concern an applicant 

and a certification body? 


require that the accredited 

certification body has procedures 

for dispute settlement for all 

grievances between the applicant 

and the certification body? 

Consultant 

comment & 

reference to 


report 

Conforms 


NA 


Annex 3, 6.1 Yes GD 06: Section 3 Conforms 

(Section 4.3) 

Annex 3, 6.1 Yes DG 06 Conforms 

(Section 4.3) 

Annex 3, 6.1 Yes DG 06 – DG 03: Section 13 Conforms 

(Section 4.3) 

Annex 3, 6.2 Yes DG 03: Section 13 Conforms 

(Section 4.3) 



No. 

Question 


require that the relevant 

accreditation body, whose 

accreditation covers the 

certification, deals with disputes and 

complaints concerning observance 

of the accreditation requirements? 

Reference to 


Council doc. 

YES / NO* 


documentation 

Consultant 

comment & 

reference to 


report 

Annex 3, 6.2 Yes DG 03: Section 13 Conforms 

(Section 4.3) 



PART III: 

MINIMUM REQUIREMENTS CHECKLIST FOR SCHEME COMPLIANCE WITH PEOLG 

(ANNEX 3, CHAPTER 4.2) 

SCOPE 

Part III covers requirements for certification criteria (forest management standards) for all 

schemes except those which are covered by ATO/ITTO PCI and by ITTO process. 

No. 

1 

2 

Question 

Reference 


Council doc. 

YES / 

NO* 

Reference to scheme documentation 

Basis for criteria development (only for schemes based on MCPFE) 

Are certification criteria 

used in the national or 

sub-national scheme 

Annex 3, 

based on Pan European 

3.1.1 

Criteria and Indicators 

for SFM as a common 

framework? 

Have the Pan European 

Operational Level 

Guidelines (PEOLG) 

formed the reference 

base when the national 

and regional criteria 

Annex 3, 

3.1.2 

Consultant 

comment & 

reference 

to 


report 

Refer to 


Report 

Refer to 


Report 

were elaborated, 

amended or revised? 

Basis for criteria development (only for schemes based on inter-governmental processes other than MCPFE, ATO/ITTO 

and ITTO) 

The UFCS 

Are the certification 

certification 

criteria based on the 

criteria are 

inter-governmental 

based on 

3 

process other than 

Montreal 

Annex 3, 

MCPFE, ATO /ITTO and 

Process 

3.1.5 

ITTO process (only for 

Criteria. 

process)? [*2] Section 5 of 

countries which 

participated in this 

Refer to 

Report 

Compatibility with the PEOLG (only for schemes to be assessed against the PEOLG) [*1] 

4 

PEOLG 1.1.a 

Conforms 

5 Criterion 1: Maintenance PEOLG 1.1.b Conforms 

6 and appropriate PEOLG 1.1.c Conforms 

7 enhancement of forest PEOLG 1.1.d Conforms 

8 and their contribution to PEOLG 1.2.a Conforms 

9 global carbon cycle PEOLG 1.2.b Conforms 

10 PEOLG 1.2.c Conforms 

11 

PEOLG 2.1.a 

Conforms 

12 PEOLG 2.1.b Conforms 

13 Criterion 2: Maintenance PEOLG 2.1.c Conforms 

14 of forest ecosystem PEOLG 2.2.a Conforms 

15 health and vitality PEOLG 2.2.b Conforms 


17 PEOLG 2.2.d Conforms 

18 

PEOLG 3.1.a 

Conforms 

19 Criterion 3: Maintenance PEOLG 3.1.b Conforms 

20 and encouragement of PEOLG 3.1.c Conforms 

21 productive functions of PEOLG 3.2.a Conforms 

22 forests (wood and nonwood) 

PEOLG 3.3.c Conforms 

PEOLG 3.2.b Conforms 

23 


25 Criterion 4: Maintenance, PEOLG 4.1.a 

Conforms 

26 conservation and PEOLG 4.1.b Conforms 

27 appropriate 

PEOLG 4.2.a Conforms 

28 enhancement of PEOLG 4.2.b Conforms 

29 biological diversity in PEOLG 4.2.c Conforms 



No. 

Question 

Reference 


Council doc. 

YES / 

NO* 

Reference to scheme documentation 

Consultant 

comment & 

reference 

to 


report 

30 forest ecosystems PEOLG 4.2.d Conforms 

31 PEOLG 4.2.e Conforms 

32 PEOLG 4.2.f Conforms 

33 PEOLG 4.2.g Conforms 

34 PEOLG 4.2.h Conforms 

35 PEOLG 4.2.i Conforms 

36 Criterion 5: Maintenance PEOLG 5.1.a 

Conforms 

37 and appropriate PEOLG 5.1.b Conforms 

38 enhancement of PEOLG 5.2.a Conforms 

39 protective functions in PEOLG 5.2.b Conforms 

forest management 

40 

(notably soil and water) 

PEOLG 5.2.c 

Conforms 

41 

PEOLG 6.1.a 

Conforms 



Criterion 6: Maintenance 


of other socio-economic 

45 PEOLG 6.1.e Conforms 

functions and conditions 

46 PEOLG 6.2.a Conforms 



[*1] 

For the purposes of PEFC assessment and endorsement of national or sub national forest 

certification schemes the terms “should” used in the PEOLG shall be interpreted as “shall”. 



PART IV: 

MINIMUM REQUIREMENTS CHECKLIST FOR SCHEME COMPLIANCE WITH ATO / ITTO 

PCI (ANNEX 3, CHAPTER 4.3) 

SCOPE 

Part IV includes requirements for certification criteria (forest management standards for 

schemes which are covered by ATO/ITTO PCI. 


PART V: 

MINIMUM REQUIREMENTS CHECKLIST FOR SCHEME COMPLIANCE WITH ITTO 

GUIDELINES (ANNEX 3, CHAPTER 4.4) 

SCOPE 

Part V included requirements for certification criteria (forest management standards) for forest 

management of natural tropical forests and planted tropical forests for scheme developed in 

ITTO member producing countries except those which are covered by ATO/ITTO PCI (as per Part 

IV). 




PART VI: 

MINIMUM REQUIREMENTS CHECKLIST FOR SCHEME SPECIFIC CHAIN OF CUSTODY 

STANDARDS (ANNEX 4) 

The UFCS does not have a Scheme specific CoC. The UFCS utilizes PEFCC Annex 4 for CoC 

certification under the UFCS. As a consequence Part VI of Checklist is Not Applicable. 

SCOPE 

Not applicable. 



PART VII: 

MINIMUM REQUIREMENTS CHECKLIST FOR CERTIFICATION AND ACCREDITATION 

PROCEDURES (ANNEX 6) 

SCOPE 

This document covers requirements for certification and accreditation procedures given in 

Annex 6 to the PEFC Council Technical Document (Certification and accreditation procedures). 

No. Question Reference to 

PEFC Council 

doc. 

Certification Bodies 

YES / 

NO* 

Reference to 

scheme 

documentation 

Consultant comment 

& reference to 

assessment report 

1. Does the scheme documentation require that 

certification shall be carried out by impartial, 

independent third parties that cannot be 

involved in the standard setting process as 

governing or decision making body, or in the 

forest management and are independent of 

the certified entity? 


certification body for forest management 

certification or chain of custody certification 

against a scheme specific chain of custody 

standard shall fulfil requirements defined in 

ISO Guide 62, or ISO Guide 66, or ISO Guide 

65? 


certification body chain of custody 

certification against Annex 4 shall fulfil 

requirements defined in ISO Guide 65? 


certification bodies carrying out forest 

certification shall have the technical 

competence in forest management on its 

economic, social and environmental impacts, 

and on the forest certification criteria? 


certification bodies carrying out C-o-C 

certifications shall have technical 

competence in forest based products 

procurement and processing and material 

flows in different stages of processing and 

trading? 


certification bodies shall have a good 

understanding of the national PEFC system 

against which they carry out forest 

management or C-o-C certifications? 


certification bodies have the responsibility to 

use competent auditors and who have 

adequate technical know-how on the 

certification process and issues related to 

forest management or chain of custody 

certification? 

Annex 6, 3.1 Yes DG 03: Section 

5c and 5d 


5n and 5o 


5o 


5m 

DG 04 


5m 

DG 04 


4 

DG 04 

Conforms 


Conforms 


Conforms 


Conforms 


Conforms 


Conforms 


Annex 6, 3.2 Yes DG 04 Conforms 






doc. 


the auditors must fulfil the general criteria of 

ISO 19011 for Quality Management Systems 

auditors or for Environmental Management 

Systems auditors? 

9. Does the scheme documentation include 

additional qualification requirements for 

auditors carrying out forest management or 

YES / 

NO* 

Reference to 

scheme 

documentation 


4 and 9 


5.1, 5.2, 5.3, 8.1 

and 8.3. 

Certification procedures 




Conforms 


Conforms 



certification bodies shall have established 

internal procedures for forest management 

and/or chain of custody certification? 


applied certification procedures for forest 

management certification or chain of custody 

certification against a scheme specific chain 

of custody standard shall fulfil or be 

compatible with the requirements defined in 

ISO Guide 62, or ISO Guide 66, or ISO Guide 

65? 


applied certification procedures for chain of 

custody certification against Annex 4 shall 

fulfil or be compatible with the requirements 

defined in ISO Guide 65? 


applied auditing procedures shall fulfil or be 

compatible with the requirements of ISO 

19011? 


certification body shall inform the relevant 

PEFC National Governing Body about all 

issued forest management and chain of 

custody certificates and changes concerning 

the validity and scope of these certificates? 


certification body shall carry out controls of 

PEFC logo usage if the certified entity is a 

PEFC logo user? 

Annex 6, 4 Yes DG 03: Section 

5q 


3c and d 


3d 


5q 


5w 


5x 

Conforms 

(Section 8.2) 

Conforms 

Section 8.2) 

Conforms 

Section 8.2) 

Conforms 

Section 8.2) 

Conforms 

Section 8.2) 

Conforms 

Section 8.2) 

16. Does a maximum period for surveillance 

audits defined by the scheme documentation 

not exceed more than one year? 

17 Does a maximum period for assessment audit 

not exceed five years for both forest 

management and chain of custody 

certifications? 

18 Does the scheme documentation include 

requirements for public availability of 

certification report summaries? 

19 Does the scheme documentation include 

requirements for usage of information from 

external parties as the audit evidence? 

Annex 6, 4 Yes DG 03: Section 5p Conforms 

Section 8.2) 


5p2 


9g 


10 

Conforms 

Section 8.2) 

Conforms 

Section 8.2) 

Conforms 

Section 8.2) 





doc. 

YES / 

NO* 

Reference to 

scheme 

documentation 

20. Does the scheme documentation include Annex 6, 4 Yes DG 03: Section 

additional requirements for certification 

11 

procedures? [*1] 

Accreditation procedures 




Conforms 

(Section 8.2) 


certification bodies carrying out forest 

management and/or chain of custody 

certification shall be accredited by a national 

accreditation body? 


an accredited certificate shall bear an 

accreditation symbol of the relevant 

accreditation body? 


the accreditation shall be issued by an 

accreditation body which is a part of the 

International Accreditation Forum (IAF) 

umbrella and which implement procedures 

described in ISO 17011 and other documents 

recognised by the above mentioned 

organisations? 


certification body undertake forest 

management or/and chain of custody 

certification against a scheme specific chain 

of custody standard as “accredited 

certification” using one of two options 

recognised by the PEFC Council? 


certification body undertake chain of custody 

certification against Annex 4 as “accredited 

certification” based on ISO Guide 65? 

26. Does the scheme documentation include a 

mechanism for PEFC notification of 

certification bodies? 

27. Are the procedures for PEFC notification of 

certification bodies non-discriminatory? 


3a 

Annex 6, 5 Yes GD 03: Section 

3d 


3a 


3c and d 


3d 


3 e 


4 

Conforms 

(Section 8.3) 

Does not conforms 

(Section 8.3) 

Conforms 

(Section 8.3) 

Conforms 

(Section 8.3) 

Conforms 

(Section 8.3) 

Partly Conforms 

(Section 8.4) 


(Section 8.4) 



Annex 4. Assessment of the Uruguayan Forest Certification Scheme - Panel of Experts review 

Issues raised by the Panel of Experts and Consultants’ responses are detailed in the following table. 

Report 

chapter/ 

page 

Consultant’s report 

statement 

PoE member comment 

SUMMARY OF PoE review 

As a summary of my review of the evaluation report, I 

cannot consider that the information provided by the 

consultant has provided the objective evidence to provide 

the consultant’s positive assessment of the UFCS. 

Consultant’s response 

General 

There is no doubt that a positive evaluation is achievable, 

on the basis of the UFCS documentation, provided the 

consultant addresses to issues I have identified in my 

consideration. 

There are definitely more than 3 issues as identified by the 

consultant, in my opinion, and any recommendation for 

endorsement of the UFCS would definitely be a conditional 

one with agreed work required within timelines. 

Comments noted. Additional text has been 

added to justify Consultants’ assessment with 

conclusions modified accordingly. 

General 

Having read relevant sections of the UFCS documentation to 

back up the assessment by the consultant and 

acknowledging that English is a second language for PEFC 

Uruguay, the review of the UFCS by an English as a first 

language would be beneficial for the UFCS if it is to be 

maintained on the PEFC website. 

The assessment is based on the normal documentation (desk 

work) and a 4-5 days field visit with various meetings. Since 

ITS Global is from Australia there are no linguistic 

deficiencies. It is clearly structured and its 

recommendations can be fully supported. 

A few major and minor items, however, need further 

clarification (following the pages of the report): 

Comments noted. 



General 

A lot of evidence of the assessment is based on findings 

during the field visit (from documents or/and oral sources?), 

the total absence of cooperation of ENGOs is certainly a 

major weakness of the scheme (the Department of the 

Environment being part of government!) Would there not 

have been a possibility during the field visit to meat at least 

one of them (f.e. WWF, IUCN, Friends of the Earth, 

Greenpeace or the Uruguyan Umbrella organisation)? 

Comments valid. 

During Field Visit attempts to contact Group 

Guayubira (Uruguayan umbrella organisation) 

were unsuccessful. 

1 Executive Summary, 2 Introduction, 3 History and structure of the UFCS 

3 Preface, 2 nd Para 

UFCS was … 

As the UFCS is basically an object, it need to be identified 

properly i.e. 

The UFCS was … 

6 Acronyms A check of the UNIT website indicates its spelling as 

Instituto Uruguayo de Normas Técnicas 

IEC is missing from the list 

Why is ‘management systems’ in lower case for QMS? 

7 Recommendation to PEFC 

Council Board of Directors, 

1 st Para 

… of the Program for the … 

Why is ‘forest management’ in lower case for SD? 

Incorrect term for PEFC – it is Programme 

Comments valid. Report has been amended 

accordingly. 


accordingly. 


accordingly. 

7 Summary of Findings, 1 b. Spelling of UNIT – see above for correct spelling Comments valid. Report has been amended 

accordingly. 

p.8 ... comments received from PEFCC members and “other 

stakeholders”. Who were they, please identify. 

8 1. Introduction 

… to PEFCC (Program for 

Endorsement of Forest 

Certification Council) for … 

Incorrect term for PEFC – it is Programme for the 

Endorsement of Forest Certification schemes Council 

One submission was received (after the public 

consultation phase had closed) from Cassie 

Phillips, Vice President, Sustainable Forests 

and Products, Weyerhauser (Refer to Annex 

1). 


accordingly. 

8 Assessment Process and Expression: Comments valid. Report has been amended 

Methodology for Report, 1 st accordingly. 



Para 

… reviewed during Field 

Visit. 

8 Assessment Process and 

Methodology for Report, 3 rd 

Para 

… PEFC consultants 

assessing forest 

certification schemes. 

9 2. History and Structure of 

the Uruguayan Forest 

Certification Scheme 

(UFCS), 2 nd Para 

… of the organisational 

structures and process … 

9 2.1 Evolution of Sustainable 

Forest Management 

Standard, 1 st Para 



Standard, 1 st Para 



Standard, 1 st Phase, 1 st Para 



Standard, 1 st Phase, 3 rd 

Para 

The STC-SFM … 

… reviewed during the Field Visit. 

Clarification 

… PEFC consultants assessing national forest certification 

schemes. 

Do these words relate to PEFC Uruguay? 

Clarification: 

… of the organisational structures and implementation 

processes … 

Use of Evolution in heading and in 1 st Para – surely the 

correct word in the context of standardisation is 

‘Development’? 

Having read the full report and some of the UFCS 

documentation, I would make it explicit in this paragraph 

that the standard only covers plantations and not any native 

forests in Uruguay. 

Incorrect spelling of UNIT – see Page 6 comment above 

There is no information on Uruguayan Society of Forestry 

Producers – a short footnote to describe them would be 

helpful 

Is this body the standard setting body? I believe this is a 

better expression 

Does the Code of Good Forest Practice (2004) have a URL? 

An annex indicating the Uruguayan Government forestry 

policies would be useful for UFCS to have as part of its 

documentation 

… as reference documents to develop the sustainable … 

Comments noted. Report has been amended 

accordingly. 


accordingly. 


accordingly. 

Comments noted. Explanatory phrase added 

to text. 

Comment noted. Report has been amended 

accordingly. 

Comments noted. Explanatory phrase stating 

that STC-SFM is the standard setting body 

referred to in PEFCC document has been 

added to text. 



… as reference document to 

develop sustainable … 



Standard, 1 st Phase, 4 th 

Para 

… (Spanish forest 

management standard). 



Standard, 1 st Phase, 5 th 

Para, 1 st and 2 nd dot points 

The document … 

Clarification 

… (Spanish forest management standard which is endorsed 

under the Spanish scheme). 

This document … 

It is STC-SFM not SFC-SFM! 

UNIT 1152 is before UNIT 1151 – it is normal to have 

documents listed in numerical order even though 1152 is the 

actual SFM standard 

p.10 are all the necessary documents for evaluation in English? 

Yes or no. )last but one sentence; see also page 17, 15 Doc.) 

p.10 the non-conformity with public consultation (53 instead of 

60 days minimum) may be tolerated under the existing 

circumstances, but the total absence of responses is not 

encouraging. Less important is the issue of the accreditation 

symbol (p.42, 8.5, 22) because it is not a mandatory 

requirement. 

10 2.1 Evolution of Sustainable There is more than 1 requirement in Annex 4! 


Standard, 1 st Phase, 5 th … the use of the requirements specified … 

Para, 3 rd dot point 

… the use of requirement 


accordingly. 


accordingly. 

1. All necessary documents are not in English. 

2. As noted in the body of the report, five 

organisations commented during public 

consultation phase (April-May 2009). 

Comments noted. Additional text added for 

further clarification. 


accordingly. 

Clarification Comments valid. Report has been amended 

specified … 


Standard, 2 nd Phase, 1 st 


accordingly. 



Para 

… gaining PEFC membership 

in 2009 … as PEFC 

Governing Body … 



Standard, 2 nd Phase, 2 nd 

Para 

… PEFC Uruguayan 

Associations Assembly on 15 

December 2009 … 

8 th Para 

… PEFC Uruguayan 

Associates Assembly on 15 

December 2009 … 

… gaining PEFC Council membership in 2009 … as PEFC 

National Governing Body … 

Please indicate the timing of the pilot testing to place it in 

perspective with dates in paragraph 

… PEFC Uruguayan Associations Assembly on 18 December 

2009 … 

- need to clarify the organisation’s name as 

‘Associates’ is used on pages 10 & 11 and 

‘Associated’ is used on page 21 

- the 18 th is used in 2.2 on page 11 


1. Additional text added to clarify the 

sequence of pilot testing. 

2. Text standardized to PEFCC Uruguayan 

General Assembly. 



Standard, 2 nd Phase, 8 th 

Para 

As documented, the UFCS 

uses these standards 

together with … 

11 2.2 Organisational Structure 


1 st Para 

… to align to requirements 

of PEFCC for mutual 

recognition. … 

… Assembly approved UFCS 

… 

11 2.2 Organisational Structure 


2 nd Para 

As documented above, the UFCS uses these forest 

management standards together with … 

… to the align with the requirements of PEFCC for mutual 

recognition of the UFCS. … 

… Assembly approved the UFCS … 

Use of ‘Revised’ – usually means the re-endorsement 

documentation i.e. after 5 years. Why use revised here? 


accordingly. 

Comments valid. Text amended accordingly. 

In this context ‘revised’ refers to the process 

of developing the UFCS (rather than its 

application for endorsement under PEFC) 



11 2.3 Documentation, 1 st Para This isn’t a review – it is a conformity assessment! 

It should be noted that the … 

Please note that the … 

11 2.3 Documentation, 2 nd Accordingly, PEFC Uruguay’s forest certification … 

Para 

Accordingly the PEFC 

Uruguay certification … 

11 General Documents (GD) Why is there a full stop after the document identifier? See 

the SD listing which doesn’t have the full stop! 

11 System Documents (SD) – These are labelled DG in the relevant folder of the UFCS. 

PEFC Uruguay 

Need to ensure the correct identifier is used! 

What is ‘Organism’ in SD03 – it usually is the Spanish 

translation of ‘Organisation’ 

11 2.3 Documentation, 4 th Para 

The UFCS also refers to 

documentation which is 

referenced to support 

Scheme documentation 

including: 

12 2.3 Documentation, 4 th Para 

3 rd dot point 

5 th dot point 

The UFCS also refers to documentation from other sources 

which are referenced to support the UFCS documentation 

including: 

It should be noted that ISO G 62 and 66 are no longer 

applicable as replaced by ISO 17021! 

The full name of the document should used especially for a 

Montreal Process country. 


accordingly. 


accordingly. 

Comments valid. Full stops removed. 

The consultants intentionally used this 

labelling system (SD) to reduce confusion (ie 

between DG and GD). 

“Organism”, not “organisation” is used in the 

PEFC Uruguay document list submitted for 

assessment. 

Comments are valid. Report amended 

accordingly. 

Comments were noted and text amended 

accordingly. Reference to ISO Guides 62 and 

66 removed. 

3 Assessment of the Standard Setting Procedures for UFSC against PEFCC requirements 

13 3.1.1 Independence, 3) This set up is similar to Spain if I recollect – need to show 

the coordination role if UNIT undertook it. See 1) iii of 

Annex 2 

I am unsure as to the Conforms rating for this question in 

light of my comment. 

The work of the Specialized Technical 

Committee of Sustainable Forest Management 

was co-ordinated and performed consistent 

with UNIT’s procedures and processes. UNIT is 

internationally recognised standard setting 

body for Uruguay. Conform rating is 

considered appropriate. 



p.14 

(bottom 

line) 

How many of the 36 organisations and individuals invite 

actually participated in the process? A list would clarify 

(physically present or by writing) 

14 3.1.1 Independence, 5) Some documentation would be preferable e.g. a URL to 

back up the pers comm. 

14 3.1.2 Participatory Process 

6) 

Documentation 

… of letter of invitation and 

minutes … 

Practice 


7) 


8) 

Practice 


9) 

Clarification 

… of letter of invitation to participate on the STC-SFM and 

minutes … 

Do the 36 organisations cover the environmental, social and 

economic interests in Uruguay? 

This question is about representation – 9) is the question for 

consensus. It should relate back to 6) for representation. 

I am unsure as to the Conforms rating for this question in 

light of my comment. 

Are the ‘Project Meetings’ the committee meetings of the 

STC-SFM? Whether it is or is not, it needs to be explained. 

Are the ‘UNIT’s operating procedure’ in fact the ISO/IEC 

Directive Part 1? 

A review of Minutes of STC-SFM meetings 

maintained by UNIT indicates that majority of 

organisations were represented, although not 

consistently, over the 40 meetings held by 

STC-SFM to develop the Standards. 

Text modified to clarify the report. 

Unfortunately PEFC Uruguay could not locate 

original documentation. 

The list of organisations and persons invited 

to participate in STC-SFM (held by UNIT) was 

sighted during Field Visit and covers 

environmental, social and economic interests 

in Uruguay. Clarification text has been added. 

Text clarified to confirm that STC-SFM used 

consensus building procedures to provide 

balanced representation by diverse 

participants. 

Project meetings refer to STC-SFM. Wording 

of text has been clarified. 

UNIT’s operating requirements are consistent 

with ISO/IEC Directive, Part 1. 


10) 

Documentation 


12) 

Documentation 

… in relation to standard 

setting procedures. 


13) 

Is there a specific document(s) which is/are the ‘UNIT’s 

standard setting processes’? 

Are the ‘UNIT statutes’ part of the other documents at 2.3, 

4 th Para? If so, they need to be mentioned 

Clarification 

… in relation to STC-SFM’s standard setting procedures. 

This is a very specific means of communication. The 

general public is a much wider reach and there is no 

Refer to www.iso.org for standard 

development processes used by UNIT. Text 

clarified. 

Comments noted. Reference to UNIT’s 

statutes incorporated in text. 

Consultants agree that this is restricted 

communication. Nonetheless it still 



Documentation reference to any other type of communications. demonstrated communication to public. 

Are the ‘UNIT regulations’ in fact the operating procedures Comments noted. Text has been clarified to 

– see Q 6)? 

clearly state that UNIT processes require 

It is ISO/IEC not ISO/ICC. 

conformity with ISO/IEC Directive, Part 1. 

The name of the document should be included – it is 

‘Procedures for the technical work 2008’ 


14) 

Documentation 


15) 

Documentation 


17) 

Practice 

… were arrived at after … 

p.18, 18 


18) 

Practice 


19) 

Documentation 

However documentation 

does state … 


19) 

Practice 

19 3.3 Pilot Testing 35) 

Documentation 


Practice 

From documentation 

presented … third pilot 

audit by consultant in 

UNIT 1152 was approved in march 2007 but UNIT 1151 was 

approved in May 2006 – need to have correct approval 

dates. 

As 2 documents ‘was’ should be ‘were made’ 

How does (April/May 2009) fit in with the Practice of 1 April 

2009 to 28 June 2009? 

… were finalised after … 

It would be preferable to stick with standard as the correct 

terminology in this context rather than use ‘norms’. 

Does public availability on request (!) satisfy PEFCC? (see 

also p. 23, 4.1.2, 7) 

The (see below) is really 3.3, so why not indicate it 

specifically? 

However, documentation does state … 

- the documentation is GD 2 and SD08, so why not indicate 

it to assist others who want verification. 

The question posed here is did the STC-SFM start its work 

after May or after June – if it is June, the 60+ days would 

possibly be OK in intent. 

The 4 th sentence could reference back to Q 18). 

Based on documentation presented … third pilot audit by a 

consultant in March 2009 … 

Is the consultant known – it would lend weight to the pilot 

testing phase even if only the firm’s name was used. 

Dates are correct. Text modified to more 

clearly identify the final draft made available 

to interested parties. 

Comments were noted. Report has been 

amended accordingly. 

Comments noted. Wording of text has been 

clarified. 



Comments were valid. Report has been 


Comments were noted. Additional text 

included. 



Comments were noted. Additional text has 

been added. 



March 2009 … 


Documentation 

… of pilot testing in final 

approved … 

19 3.4.1 Periodic Review 37) 

Documentation 

… of pilot testing within the final approved … 



It is SD08 not SG08. 

Comments valid. Text modified as suggested. 

Also, GD2 is applicable for documentation 

… PEFCC Annex 4 requirements and it will be PEFCC’s 

… PEFCC Annex 4 

responsibility to review this standard. 

requirements. 

20 3.3 Pilot Testing 38) Why not indicate the UFCS documentation – GD2 and GD8? The consultants did not asses GD8 as relevant 

in this context. 

20 3.5 Overall Assessment Comment: I have a real concern on the assessment for 3), 7) 

and 19) – I would seek further evidence to justify the 

current assessment. 

20 3.5 Overall Assessment, 1 st 

dot point 

Firstly the announced … 

20 3.5 Overall Assessment, 2 nd 

Para 

As noted in response to 

Question 19 the final draft 

of forest management 

standards was available … 

Further letters informing … 

21 3.5 Overall Assessment, 3 rd 

Para 

21 3.5 Overall Assessment, 4 th 

Para 


dot point 

The first issue relates to the announced … - to be consistent 

with the 2 nd dot point 

As noted in the response to Question 19, the final drafts of 

forest management standards were available … 

Furthermore, letters informing … 

It is assumed that ‘technical standards’ are the same as 

‘national standards’? 

This is only focussed on forest management – there is a need 

for a sentence to cover off on CoC standard as part of the 

UFCS package. 

It would be preferable to indicate that the invitation was 

sent to it (and to others) – dated letters sighted in Field 

Visit. 

Assessment modified to address nonconformities 

associated with: 

1. Lack of evidence to demonstrate 

environmental NGOs were invited to 

participate in deliberation of STC-SFM. 

2. Public consultation being less than 60 days. 





Comments noted. Additional text added to 

provide further clarification. 

Comments noted. Text has been amended 

accordingly. 

Comments valid. Additional text added. 



4 Assessment of the implementation of UFCS against PEFCC requirements 

p.21 (SD 

13, 

Section 

4) 

21 4. Assessment of the 

Implementation of UFCS 

against PEFCC 

Requirements, 1 st Para 

Performance requirements 

for UFCS are detailed in 

PEFC Uruguay system 

documents (SD01 to SD09, 

and GD2). 

Does the “general society’s well being” include the 

ecological components? 

Performance requirements for the UFCS are detailed in 

PEFC Uruguay system documents (SD01 to SD09) and GD2. 

“general society’s well being” is interpreted 

to incorporate economic, social and 

environmental components. Text expanded to 

reinforce SFM requirements. 

Comment valid. Text has been amended 

accordingly. 

21 4. 3 rd Para Change case for Document ie document Comments noted. Report has been amended 

accordingly. 

21 4 th Para 

Incorrect reference – it is GD2, 5.3 (it hasn’t been labelled Correct reference SD03 added. 

(refer to GD3, Section 5.4) as 5.4 in the document) 

21 5 th Para 

The Forest Management 

System … 

It refers to planification – not normally used in English 

(French for planning). An FMS is much more than planning! 

There is no such document in 2.3. Is it in fact GD13? 

Comments noted. Clarification text added to 

state that General Plan of Management is a 

component of Forest Management System. 

(refer to SD13, Section 4) 

21 6 th Para 

(refer to GD13) and (refer 

to GD12) 

… by PEFC Uruguay 

Associated Assembly … 

… based on Montreal 

Process … 

21 7 th Para 

… based on Montreal 

(referred to as GD13) and (referred to as GD12) 

See comment for Page 11, 2.2 

… based on the Montreal Process … 

… based on the Montreal Process … 







Process … 

p.22, 

4.1.1., 1 

22 4.1.1 General Requirements 

1) 

(refer to GD 13) 

“...relevant to all forests and management systems ...” 

(vice versa plantations)? 

The FM standard is applicable for forest plantations only! 

The consultant should identify the relevant section/chapter 

which indicates compliance – this is s general comment for 

much of the rest of the assessment ie refer to 1 of GD13 

22 2) Clarification 

… by different auditors based on the justifications as the 

normative requirements. 

22 3) 

(refer to 1, 4 of GD 13) 

(refer to GD 13) 

23 7) I cannot confirm the consultant’s conclusion – GD13 

provides for the FMP – there is no indication of availability 

23 8) Clarification 

5 of GD2 applies! 

23 10) I cannot confirm the consultant’s conclusion – it isn’t 

explicit. There is basically an inference rather than 

evidence! 

23 11) Comment – ratification implies application through national 

legislation 

24 13) Query – was it sighted in the Field Visit i.e. confirmed in the 

minutes of meetings 

24 14) 

The signing of this Protocol can’t be verified on 

bch.cbd.int/protocol/parties 

The Biosafety Protocol The Cartagena Protocol on Biosafety 

25 17) Comment – can delete text after SD07 and GD2 as have 

already established text in 4.2.1! 

Agree for SD07 but it isn’t explicit in GD2 to indicate 

conformance 

Comments were noted. Text clarifying that 

criteria apply to plantations has been added. 

Refer to above comment. 

Comments are valid. Suggestion to identify 

relevant section/chapter has been 

implemented. 

Comments are valid. Additional text has been 

added. 

Additional text added. 

Comments are valid. Text has been modified 

to recognise that while the practice of forest 

companies is to make copies of FMP publicly 

available, this is not explicitly required by 

documentation. 

Comments valid. Additional reference added. 

Comments noted. Additional reference to 

GD02, Section 2 added. 


Confirmed in discussions with members of 

STC-SFM. Refer to Annex 1. 

Uruguay’s country profile indicates that the 

Protocol was signed on 1/2/2001 (cited in the 

conformity assessment). Profile accessible at: 

http://bch.cbd.int/about/countryprofile.sht 

ml?country=uy 

Comments valid. Additional reference to 

GD02, Section 5.1 added. 



25 4.2.3 Group Certification This introduction relates in fact to the SFM system which 

relates to 5.3 of GD2 

25 35) 

The criteria and requirements for group certification as set 

The criteria and 

out in SD07 comply with PEFCC requirements. 

requirements for group There is no need to repeat the PEFCC reference! 

certification within UFCS 

(SD07) comply with PEFCC 

requirements detailed in 

Annex 3, 4.1b. 

26 43) Comment – Under 7, it is explicit for the member but it is 

implicit for the Group Administrator! 

... forest area under his/her management should be added 

by PEFCC 

Comments noted. Text amended accordingly. 

Comments valid. Text amended accordingly 


p. 27, 

4.2.4, 46 

The consultants agree with the comment. The 

consultants used the exact wording of the 

PEFC Council Minimum Requirements 

Checklist (GL 2/2010), but would recommend 

that PEFCC considers amending the 

documentation so that it does not contain 

gender specific references. 

27 45) The shading is missing for the Conforms Comments valid. Report has been amended 

27 48) 

… on ad hoc basis … … on an ad hoc basis … 

28 49) 

… on ad hoc basis … … on an ad hoc basis … 

28 4.4 Overall Assessment Comment: I have a real concern on the assessment for 7), 

10), 14), 17) and 43) – I would seek further evidence to 

justify the current assessment. 

5. Assessment of UFCS Forest Management Standards against PEOLG 

accordingly. 


accordingly. 


accordingly. 

Comments noted. Assessment modified to 

recognise non-conformity associated with a 

lack of documentation requirements for 

making summary of FMP publicly available. 

29 5.1 Assessment Framework, 

1st Para 

UFCS utilizes Norm 

(Standard) 1152: 2009 … 

The UFCS utilizes Norm (Standard) UNIT 1152: 2009 … 

The conformity of the Criteria and Indicators of Standard … 

It is the C&I which provide the equivalence with the 



Text amended. 



3rd Para 

The conformity of the 

Standard … 

29 5.2 Compatibility of the ME 

with PEOLG 

… with PEOLG Criteria are 

coded as C and associated 

relevant indicators coded 

as I 

29 Table heading - UFCS 

p.30, 1.2 

c 

compliance 

PEOLGs! 

Comment: There are no requirements per se in UNIT 1152 – 

it is comprised of Criteria and Indicators 

… with PEOLG Criteria are coded as C eg C 1 and associated 

relevant indicators coded as I eg I 6.1.1. – this provides 

guidance to a reader. 

Query: Are these the consultants words or are they PEFC 

Uruguay’s words? 

“... expansion of plantations where benefit to general 

society’s well being ...”. ENGOs are clearly a part of the 

general society! Who decides whether society benefits or 

not, and what kind of benefits...? (not very satisfactory!) 

29-35 General Comments 

I cannot understand how a Criterion or a number of Criteria 

can specifically provide conformity with a PEOLG – it must 

be the Indicator under the Criterion which provides the 

conformance. The PEOLG is at the operational level but the 

Criteria in UNIT 1152 are based on the Montreal Process at 

the highest level of SFM. 

There is a lack of normative language in the Indicators 

which is the means to provide assurance of the outcome for 

the Criterion. Must is mostly used but it is no substitute for 

shall. 

I cannot understand how reference to Section 4.1 of UNIT 

1152 provides explicit conformance as in many cases, it is 

implicit and there is an onus on explicit evidence for 

conformity assessment. 

PEOLGs 1.2c, 2.2b, 2.2d indicate that there is not the 

required evidence but there is a ‘conforms’ assessment! 

I cannot agree that a proper evaluation of UNIT 1152 

Comments valid. Clarification text has been 

added to the document. 

Consultant’s comments. Table heading 

changed to ‘Evidence’. 

In Uruguay plantation projects are required to 

be approved by Ministry of Agriculture and 

Ministry of Environment. 

Ministry of Environment has specific 

responsibilities to evaluate benefits to society 

for specific plantation projects. 

1. Comments noted. To strengthen the 

assessment the specific indicators for each 

criteria have been added in cases where 

indicators were not previously specified. 

2. In relation to comment of normative 

language in Indicators, it is relevant to 

note that each indicator is supported by an 

indicator and specific framework of 

justification, objective, parameters, 

procedures, documents and registers. 

3. In relation to interpretation the use of 

“must” in Standard has been considered 

equivalent to “shall” under PEFC 

requirement. 

4. Reference to Section 4 of UNIT 1152 has 

been labelled as ‘General’ while reference 

to criteria and indicators has been labelled 

‘Specific’ to strengthen evaluation 




sentence 

provides adequate conformity assessment against the 

PEOLGs – there is a greater need to indicate specific 

Indicators to provide the conformity. 

If this is the assessment wouldn’t it be a ‘partial 

conformity’? 

The policies – are they the Uruguayan Government policies? 

If so, it needs to be explicitly stated as it may demonstrate 

compliance with legislation. 

framework. 

Comments noted. Justification text added to 

support consultants’ assessment. 

6. Assessment of UFCS chain of custody standard against PEFCC requirements 

36 6. Assessment of UFCS 

Chain of Custody Standard 

against PEFCC 

Requirements 

Comment: I would expect that GD2 and DG08 are also 

applicable UFCS documentation – all relevant sources should 

be cited. 

Comments valid. Additional references added. 

8. Assessment of UFCS certification and accreditation arrangements against PEFCC requirements 

38 8.1.1 Competence of 

Certification Bodies … (refer to Section 5, SD03) … 

1) 

… (refer to SD03) … 

38 4) and 5) Comment: I would adjudge these as Partial Conformity 

based on matching the documented evidence against the 

39 6) 

… (refer to SD03, Section 3) 

… 

39 7) 


… 

39 9) 


… 

… work experience and 

requirement. 

Incorrect reference 

… (refer to SD03, Section 5, b) … 

Applicable references 

… (refer to SD04, Section 4, 5 & 8) … 

Applicable reference 

… (refer to SD04, Section 5 & 8) … 

… work experience, competence and training. 



Comments noted. Additional text and 

references added to justify consultants 

assessment. 

Comment noted. Reference amended. 

Comments noted. Additional references 

added. 

Comments noted. Additional references 

noted. 



training. 

39 10) 

… (refer to SD04) … 

Incorrect reference 

… (refer to SD03, 5 p) … 

39 11) Comment: As the UFCS uses Annex 4, it is not a scheme 

specific CoC Standard and the response only needs to 

address the FM Standard 

8.2 / 

p.40 

8.2 / 

p.40 

Question 12: 

“…with requirements of ISO 

Guide 65 adjusted to the 

type, range and volume of 

work” 

Question 18: 

“…make available, at 

request, “summaries of the 

certification””. 

40 12) 

… (refer to SD03, Section 

5(n)) … 

40 15) 

… (refer to SD03, Section 

5(x)) … 

40 18) 


… 

What in detail is meant with “adjusted to the type, range 

and volume of work”? And is this enough for conformity? 

Is “at request” enough to satisfy the requirements? 

Applicable reference 

… (refer to SD03, Section 3 & 5(n)) … 

Correct reference: check on 9e! 

… (refer to SD03, Section 9(g)) … 

41 19) Comment: I would adjudge these as Partial Conformity 

based on matching the documented evidence against the 

requirement. 

Comment noted. Reference amended. 

Comment noted. Additional explanatory text 

added. 

Comment noted. The wording is assessed by 

the Consultants as being consistent with 

requirement of ISO Guide 65. 

Comments noted and text clarified. Response 

is assessed by Consultant as satisfying PEFCC’s 

requirements. 







Comment noted. Clarifying text added to 

support assessment. 

41 21) Not referenced so lacks consistency – should be SD03, 3a! Comments were noted. Report has been 


41 23) 


… 

… (refer to SD03, Section 3(a)) 



42 26) This is a non-conformity as there is no PEFC Notification 

document in the SD series. GZD2 doesn’t have ‘notified’ or 

‘notification’ in the whole document. Maybe the reference 

is SD03, 3e? 

Comments were noted. Text clarified to 

support conformity assessment. 



42 27) Impartial and non-discriminatory are not mentioned at all in 

the statutes – I would asses this as a non-conformity! 

42 8.5 Overall Assessment I do not agree with the consultant’s assessment as it is a 

3 rd para 

requirement of the PEFC for accredited certification of an 

organisation. The certificate must (shall) have the 

accreditation symbol, so it not in the UFCS, it is a nonconformity 

which requires corrective action by PEFC 

Uruguay 

Comments valid. Text has been amended 

accordingly. 

Comments noted. Text and recommendations 

have been modified. 

Annex 1, 2 and 3 

44 Annex 2, 2) 

Correct spelling for UNIT – see Page 6 comment 

… individually targeted letters … 

vi) … individually target 

letters … 

45 3 rd Para 

However none were However, none were received. 

received. 

45 4) 

… Directory … 

… Director …! 

46 6) iii) The statement needs to end with ‘based on … …’ to indicate 

the basis of the procedures. 

46 7) iii) 

… successfully implement … successfully implement the UFCS. 

Scheme. 

47-50 PART I 

I cannot locate any document labelled Annex 1 in 2.3. 

Nos. 1 -19 and 35 – 41 There is no Annex 1 to GD2 which is the implication of the 

response to the Process in No. 1 and wherever referenced in 

the PEFCC requirements. 

It is only by looking through the UFCS documentation that 

an Annex 1 can be found! 

Also, there seems to be no Annex 3! 

The only visible document with an Annex label is Annex 2 

which is GD6. 

Having the name used as reference and having it visible in 

the report need matching if in fact Annexes 1 and 3 are 



Text changed. 



Comments noted. Text amended accordingly. 



Comments noted. Additional text and table 

added to clarify the equivalence of 

documents cited by PEFC Uruguay as 

reference document, and document numbers 

used in Consultants’ assessment. 



Annex 3, 

Part I / 

48 

Question 12: 

No, No, VER CON UNIT 

contained in 2.3 

The answers do not fit to main assessment report. 

48 No. 12 Whilst the Consultant has indicated No, the response in the 

text at Pg 16 is Conforms which to my understanding is a 

Yes! 

Annex 3, 

Part I / 

49 

Annex 3, 

Part I / 

49 

Annex 3, 

Part II / 

52 

Question 16, 17: 

No answers / “En proceso” 

in columns 5, 6 

Question 37: 

Missing answer in column 5 

Questions 1 –18, 46: 

Columns 4 and 5 are not 

completed 

52-53 PART II 

Nos. 1 - 34 

Answers missing 

The answer should be “yes”? 

Anwers are missing. If the answers are not necessary this 

should be mentioned somewhere. 

The whole point of the Checklist is to indicate in a concise 

manner the relevant documentation of the scheme which 

the consultant has assessed as satisfying the PEFCC 

requirement (or in the case of partial or non-conformity, 

indicating that assessment). All the blank sections need to 

be completed as the main document is also light on specific 

references to documents especially to the relevant sections 

of the documents. 

57 No. 46 Surely GD2, 5.1 is the specific reference even noting the 

PEFCC comment. 

59 PART III 

There are more than one Criterion for the Montreal Process 

No. 3 

Criteria! 

59-60 PART III 

No. 4 – 48 

This is definitely not good enough fore an evaluation – see 

my comment above for pages 52-53. 

The FM standard is the essence of any forest certification 

scheme and it must be well articulated in the checklist to 

As noted in the report, boxes shaded in red 

are answers provided by PEFC Uruguay. The 

Consultant’s assessment is located in the final 

column. The Consultants’ assessment 

corresponds to discussion found in the body of 

the report. 

The appeal mechanisms for handling 

complaints against STC-SFM are specified by 

UNIT. Text has been revised to provide 

further explanation. 

PEFC Uruguay did not file answers for these 

questions 



PEFC Uruguay did not provide answers to 

these questions in their application for 

endorsement 

As noted above, PEFC Uruguay did not provide 

responses to these questions. Consequently 

the column is blank. 

Comment valid. PEFC Uruguay did not 

document specific references. 

Comment valid. Report has been amended 

accordingly. 

Comments noted. Consultants’ conformity 

assessment has been added. 



Annex 3, 

Part III / 

62 

Column 4 is not completed 

indicate compliance or equivalence. 

As I have raised substantial queries in the body of the 

report, it must be completed in unison with consideration of 

the body of the report. 

Answers are missing. If the answers are not necessary this 

should be mentioned somewhere. 

62-64 PART VI The consultant hasn’t read the heading for this part – it is 

ONLY applicable to a scheme specific CoC standard. This is 

not the case for the UFCS as it uses PEFC’s Annex 4. The 

correct response would be Not applicable! 

As noted above, PEFC Uruguay did not provide 

responses to these questions. 


accordingly.

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