Common Chain of Custody Non-Conformities (and How to Avoid Them)

Across years of Chain of Custody auditing and consulting work, the same handful of non-conformities come up again and again — across different sectors, different company sizes, and different certification bodies. Most are entirely avoidable with the right day-to-day habits.

1. Certified claims that don’t reconcile

The material balance between what’s purchased as certified, what’s produced, and what’s sold as certified doesn’t add up. This is usually caused by informal or delayed record-keeping rather than deliberate misclaiming — but it’s treated seriously regardless of intent.

2. Outdated or missing supplier certificates

Using a supplier’s certificate number on your own paperwork without checking it’s still valid is a recurring finding. Certificates lapse, get suspended, or change scope — and that responsibility sits with you, not just your supplier.

3. Incorrect logo or claim use

Using an FSC or PEFC logo, claim, or licence code that doesn’t match what your certificate actually permits — wrong claim type, expired licence number, or logo used on non-certified products by mistake.

4. Gaps in staff understanding

A well-written manual that the person on the goods-in desk has never actually read. Procedures need to be trained, refreshed periodically, and understood by the people actually doing the work — not just filed.

5. Missing or incomplete transaction records

Delivery notes, purchase orders or invoices missing the certification details needed to support a claim — often because a system change (new supplier, new product line, a busy period) wasn’t reflected in the paperwork process at the time.

6. Scope creep

Selling a product as certified that was never actually within the certified scope — sometimes because a new product line was added to the business without anyone checking whether it needed adding to the certification scope too.

7. No internal monitoring between audits

Systems that are only looked at again the month before the next audit. Non-conformities compound when nobody’s checking in between.

The pattern behind most of these

Nearly all of the above come down to the same root cause: a system that exists on paper but isn’t genuinely embedded in day-to-day operations. The fix is rarely more paperwork — it’s making the correct way of doing things the easiest way, so staff don’t have to think about compliance separately from doing their job.

If any of these sound familiar, get in touch — most are straightforward to put right →