21-1111 Cork Flooring Imperative 14
We are seeking an exception under Imperative 14 - Responsible Sourcing, to clarify whether it is appropriate for our tenant improvement project to include Cork Flooring in the FSC percentage requirement for new wood or whether it could be considered an agricultural product or "wood-containing materials" which are excluded from FSC calculations.
We are requesting this clarification as we have not found mention of cork anywhere in the Petal Handbook or the LBC Dialogue. On the FSC website, we could not find the cork tree Quercus suber in the list of regulated species. We understand that cork is harvested on a ten-year cycle that does not kill the tree and is considered one of the most sustainable choices for building insulation and other products. We also have found the EU Timber Regulation exempts Cork from its scope of regulations, along with other some other wood products such as wood wool and wood flour, printed books and newspapers, pencils, tools, brooms, and furniture. See https://preferredbynature.org/certification/timber-regulations/eutr-which-products-are-covered.
Since our tenant space is in an existing historic building, we have limited options for flooring. The existing condition of the 100+ year-old lightweight concrete topping slab with intermittent wood sleepers precludes a warrantable installation of many common floor finishes which bind to the slab. Demolishing the 8000 SF existing slab and repouring with new concrete is not an appropriate choice. We are left with a floating floor as our best option which leads us to either cork flooring, or wood laminate. We selected cork flooring since cork harvest does not require cutting down trees, has a lower embodied carbon, aligns with our Biophilic design goals, and can be more resilient and durable than wood.
The current flooring we have specified, Capri EcoClicks, has a Declare label that lists its I14-Responsible Sourcing status as 'low risk wood'. Although we have found a few FSC-certified cork products, our searches for a cork flooring product with a FSC certification have revealed very few products currently available and none are listed in compliance with Imperative 14.
While we understand that Imperative 14 allows us to use 20% low risk wood, the quantity of cork for our flooring exceeds that percentage since as a tenant improvement we are have no wood structural members or framing. Given these project constraints, the lack of FSC and EU regulation regarding cork, and the limited market for and availability of FSC certified cork flooring in the current market, would it be reasonable to exclude cork flooring from the scope of new wood requiring 80% FSC certification?
While cork is classified by the Forest Stewardship Council (FSC) as a Non-timber Forest Product, it does offer certification for Quercus suber woodlands and has certified many.
Notwithstanding the availability of FSC certification for cork, the Institute finds that because harvest of the cork involves lower impact extraction methods that do not require felling of the tree, cork components do not need to be included in calculations towards meeting the FSC sourcing requirement. However, project teams are advised that many cork building products are composites of several materials, and any product that contains a component containing non-cork wood fibers, such as wood fiberboard, is considered a wood-containing product and must be included in FSC calculations.