Innovia Films - Chain of Custody Certification
Innovia Films is a leading global manufacturer and supplier of two ‘families’ of speciality products for the packaging, labelling, tobacco overwrap and securities markets – Biaxially Oriented Polypropylene (BOPP) and Cellulose-based films.

The company, formerly known as UCB Films and headquartered in Wigton, Cumbria, has an annual turnover in excess of €400m with a total annual film production capacity of more than 120,000 tonnes. Its films, which include the famous Cellophane™ brand, are sold to converters, brand-owners and end-users across the globe, and are utilised as part of the packaging, labelling or overwrap solution for some of the world’s best known brands across a wide variety of everyday consumer goods include chocolates, perfume, cheese, tea, shampoo, cigarettes, beer and biscuits. 

The business is committed to optimising the sustainability of the raw materials sourced for its products and reducing their environmental impact, whilst maintaining the functional properties of those products and their cost-effectiveness. In 2004, the company saw an opportunity in the market to develop a new range of flexible biodegradable films made from renewable wood pulp. The innovative and unique brand, NatureFlex™, take the Cellophane concept “to the next level” by being fully renewable and certified compostable according to various industry standards, contributing to waste reduction throughout the packaged-goods supply chain.
 
Innovia Films has been working with world-leading multi-sector certification body Exova BM TRADA to gain both FSC® (Forest Stewardship Council) and PEFC™ (Programme for the Endorsement of Forest Certification) certification - the most widely recognised chain of custody (CoC) certification schemes. By doing so, it has become the first certified Cellulose plant operating in the UK, further cementing its reputation for best environmental practice and setting a glowing example to other firms across the world.

The decision to pursue chain of custody certification was driven by a growing awareness and need within their markets to have demonstrable environmental responsibility for their NatureFlex products, as Lucy Cowton, Products Sustainability Manager, Innovia Films explains. She said: “We decided to go ahead with chain of custody certification because we were getting lots of enquiries from our customers over our pulp suppliers. Our market for NatureFlex is targeted towards people who are more environmentally conscious and they ask a lot more questions about where the wood pulp comes from, and whether or not the pulp supplied comes from responsibly-sourced plantations.
 
“As we do a lot of work with composability we like to be able to substantiate any claims we make. The best way of doing that was by becoming certified, and FSC and PEFC were the most reputable and recognised CoC certifications available – the gold standard.”
 
WHY EXOVA BM TRADA?
 
Cowton says that when it came to exploring multi-site certification, Exova BM TRADA – which has branches in America as well as more than 30 other countries worldwide – stood out from its competitors. She said: “We had a timeframe in mind for having multi-site certification in place and we were very impressed with how quickly Exova BM TRADA responded to us.
 
“They understood what we needed straight away, which made the whole process as painless as it could be, and this allowed us to put things in place within our timeframe and achieve our objective.”
 
THE BENEFITS OF CERTIFICATION
 
Demand for FSC/PEFC certified packaging continues to increase, driven by a greater concern for the environment and minimising the environmental impact of industry. By implementing and maintaining a robust chain of custody system, Innovia Films is able to send out the right reputational messages concerning the company’s commitment to environmental responsibility, providing assurances to customers that their products are sourced and produced in compliance with an internationally recognised third-party standard.

Cowton said: “Having certification gives customers additional confidence in our products and means that we don’t have to spend time justifying our claims, answering lots of questions and long surveys. When everything is certified, it’s a nice and simple story to share. “Because of the unique nature of our films, that they are forestry-sourced, we don’t face the same issues that other companies in the bioplastics world do over land issues and GM crops, but we still need to clearly demonstrate that we are doing the right thing, not chopping down trees in the Amazon or causing any other environmental issues.”
 
THE JOURNEY TO CERTIFICATION
 
Innovia Films have production sites in the UK, USA, Belgium and Australia and operate a network of sales offices, agents and distributors throughout the world, employing a global workforce of 1,350 people. The certification process commenced in 2012 with the CoC certification of one of Innovia Film’s two cellulose production plants, situated in Wigton.
 
Certification was awarded within 12 months, in December 2013. The decision was then made to expand the programme to multi-site certification. The multi-site approach to CoC certification is ideal for companies that operate multiple facilities, allowing the certification body to evaluate sites based on audit sampling in recognition of common, centrally administered and monitored control and reporting systems. This enabled Innovia Films to save money through reduced direct auditing costs. Each certification programme took approximately 12 months to complete.
  
For multi-site certification, Innovia Films first opted to transfer their UK chain of custody certification to Exova BM TRADA. They then worked with Exova BM TRADA to add certification for two sites in the USA: a second cellulose production plant in Tecumseh, Kansas, and their sales office in Atlanta, Georgia. The auditing process is split into two stages. The stage one audit comprised an on-site evaluation to review Innovia Film’s chain of custody system, and the procedures and processes covering all activities related to this system; an evaluation of whether Critical Control Points (CCPs) had been identified and the risk of product mixing eliminated or minimised; a review of the record keeping process; evaluation of all outsourced processes and verification of the company’s use of appropriate FSC and PEFC trademarks for onproduct labelling and off-product market communications and claims.
 
As with all companies operating a CoC system, Innovia Films was required to define and put in place a ‘Control System’ to demonstrate how certified products would be identified throughout all stages of production. They chose to operate under the “credit” control system, which involves the mixing of certified and non-certified raw material. The credit system is based on the monitoring of the volume or weight of certified raw material that is purchased to manufacture a batch of products, as this value will determine the total amount of finished product that can be sold as certified.
 
For Innovia Films, the credit system was the best fit as the global wood pulp market is noted for its volatility and challenges faced in maintaining continuity of supply. The credit system allows the company to satisfy their CoC requirements while remaining flexible enough to deal with a fluid market where the supply of certified wood pulp is constantly in flux. An added benefit of the credit system was that Innovia Films did not need to change its factory production control system to allow for segregated batch production systems.
 
Lucy Cowton says that gaining certification was a “cross-functional” collaboration both internally and externally with suppliers. She said: “We undertook an immense amount of work before deciding to kick-start the certification process. Before anything else we assessed what we had in place already, and what we needed to put in place, including a GAP analysis.
 
“Once we had sign-off from the company board to proceed we embarked on a programme of awareness sessions for staff as we needed to ensure that everyone knew what certification was about and what they needed do.
 
“Training included a wide range of people on site including staff working in environmental, sales, marketing, regulatory and production departments. We were not asking them for a dramatic change in how things operated on site, but would still be a slight change and as we were putting additional steps into their working process it was important that everyone understood why we were asking them to do these things.
 
“We disseminated what we had learnt through the certification process in Wigton and replicated it onsite in Tecumseh and Atlanta. “For the credit system we already had thorough accounting and volume control records in place, so it didn’t demand any data that we didn’t already collect as standard, but we did need to pull it together into a package so that the auditors could clearly see our inputs and outputs, and ensure everything was traceable.”
 
She added: “We’d love to be able to say that all our pulp suppliers are certified, and even before certification we had been asking them to get themselves certified. Historically, though, there have been few producers of dissolving pulp and they weren’t that concerned with certification as their main markets were for textile companies, which didn’t tend to push for certification.
 
“But the landscape is changing, with paper producers who already have forestry certification moving their assets to dissolvable pulp, so we are making good progress. When all pulp we use is from certified suppliers then we will be happy.”
 
Innovia Films received dual FSC and PEFC certification for their sites in Tecumseh, Kansas, and their sales office in Atlanta, Georgia, in April 2015. Certification is valid for five years and is maintained through a programme of annual surveillance audits and a recertification audit in the fifth year before the certification expires. As a certified company, Innovia Films has permission to use the schemes’ internationally recognised trademarks for on-product labelling and off-product marketing.

CHAIN OF CUSTODY CERTIFICATION — THE FACTS
 
Chain of custody certification is for companies who process, manufacture or trade in timber-derived products including manufacturers, wholesalers, retailers, sawmills, printers and paper merchants.

By implementing and maintaining a robust chain of custody system, companies can provide assurances to suppliers and clients that their products are sourced and produced with respect for the highest ecological, social and economic standards.
 
Certification works throughout the entire supply chain to provide proof of traceability back to well-managed forests, controlled or recycled sources. For a product to qualify for certification, all entities along the supply chain must possess a chain of custody certificate. Only then are companies eligible to use the FSC or PEFC label on their products and in product marketing to identify the responsible sourcing of the raw material. Companies taking legal ownership of FSC or PEFC certified products and processing, trading or repacking them need to be FSC certified in order to make a claim.
 
FSC
 
Forest Stewardship Council (FSC) is an independent, international organisation that promotes the development of environmentally compatible, socially beneficial and financially sound, practices for management of the world’s forests. FSC has established 10 fundamental principles and 56 criteria for responsible forest management. These call for protection and preservation of biological diversity and other natural resources but also support economically sound forestry operations that contribute to the development of the local community. The FSC label guarantees the products come from sustainable forestry and controlled recycling processes.
 
PEFC
 
PEFC was formed in 1999 and is an international, non-governmental umbrella organization dedicated to the assessment and mutual recognition of national forest certification systems for sustainable forest management through independent third-party certification. As such, PEFC leaves enforcement of the standard to respective national bodies.