COMPLAINTS

FILING A COMPLAINT OR DISPUTE ON ISSUES CONCERNING THE MALAYSIAN TIMBER CERTIFICATION SCHEME (MTCS)

The Malaysian Timber Certification Council (MTCC) serves as the scheme owner of the Malaysian Timber Certification Scheme (MTCS). This voluntary national initiative is dedicated to advancing Sustainable Forest Management (SFM) across Malaysia while ensuring a transparent and traceable supply chain. As the National Governing Body (NGB) for Malaysia under the Programme for the Endorsement of Forest Certification (PEFC), MTCC is responsible for the comprehensive oversight of the Scheme, specifically regarding the development and periodic review of certification standards.

Overview of the MTCS

The MTCS is structured into two core certification components which are the Forest Management Certification involves an independent, third-party assessment of forest management practices within a specific Forest Management Unit (FMU). The objective is to verify that operations align strictly with prescribed SFM standards, and for Chain of Custody (CoC) Certification, this process involves auditing timber product manufacturers and exporters. It ensures that the timber materials utilized in their products are sourced exclusively from sustainably managed forests.

The integrity of the forest management and chain of custody certification processes is maintained by four independent entities operating within the MTCS Institutional Arrangement, as illustrated below:

Institutional Arrangement of MTCS

The Two-Step Way to File a Complaint, Dispute or an Enquiry

In the implementation of the various processes under the MTCS, misunderstanding, dissatisfaction, or disagreement may arise, resulting in the need to submit a complaint or dispute. While constructive engagement among the parties concerned is always preferred, mechanisms are in place to address any issue that may arise.

Step 1 – Identify the nature of the complaint or dispute in relation to the various processes under MTCS.

Complaints and disputes under MTCS may relate to different parts of the Scheme from the development of certification standards to the conduct of an audit, to the decision to grant, suspend, or withdraw a certificate. Each of these falls under the responsibility of a different independent entity.

Understanding which entity is responsible for the matter you wish to raise is important, as each entity has its own mechanism for handling complaints and enquiries. The following outlines the roles and responsibilities of the four independent entities involved in the implementation of MTCS to help you identify the appropriate party:

  1. The Scheme Owner – MTCC
    • Develops and reviews certification standards and oversees the overall implementation of MTCS;
    • Processes applications from accredited Certification Bodies (CBs) to become PEFC notified CBs;
    • Grants logo usage license on the use of MTCS and PEFC logo by certified organisations.

Examples of complaints:

  • Dissatisfaction over the conduct of standards review process and its decision;
  • Misuse of PEFC logo by any party.

  1. National Accreditation Body (AB) – Department of Standards Malaysia (Standards Malaysia):
    • Evaluates and monitors the competency of Certification Bodies.
    • Investigates failures in the auditing process itself.

Examples of complaints:

  • Dispute on the accreditation decision by AB over qualification of CB;
  • Complaints that the CB did not engage with local communities in their verification audit.

  1. Accredited CBs – Auditing Companies
    • Receive and process applications for certification.
    • Conduct audits and make decisions to grant, suspend or withdraw MTCS/PEFC certificates.

Examples of complaints:

  • Disagreement on the certification decision;
  • Disagreement in the conduct of audit by auditors which is seen as impartial;
  • Public Summary was written wrongly/ making reference to wrong facts/ documents.

  1. MTCS/PEFC-certified Organisations – FMUs, Timber Companies, Sawmills, Plywood Mills, etc:
    • Manage and ensure that their activities and practices are in compliance with MTCS standard and requirements.
    • Primary respondent for operational grievances.

Examples of complaints:

  • Dissatisfaction over any management practices conducted by a certified organisation or its personnel. Such complaints shall be copied to the CB that had granted certification to the certified organisation;
  • Did not undertake community engagement process;
  • Did not address grievances raised to the Forest Manager.

Step 2 – Submit a Formal, Written Complaint/Dispute/Enquiry

Each of the four independent entities has its own complaint/dispute resolution mechanism to address any issues relating to its role in MTCS. Please write a formal complaint, dispute or enquiry and send it directly to the appropriate organisation as illustrated below:

Enquiry / Complaint

Scheme Owner

Malaysian Timber Certification Council (MTCC)

Scope of Responsibilities:
Implementation and review of MTCS

Submit a Complaint to MTCC

National Accreditation Body

Department of Standards Malaysia (Standards Malaysia)

Scope of Responsibilities:
Accreditation of Certification Bodies

Submit a Complaint to Standards Malaysia

Accredited Certification Bodies

Auditing Companies

Scope of Responsibilities:
Applications for MTCS certification and auditing

Submit a Complaint to Certification Bodies

MTCS/PEFC-certified 
Organisations

Forest Management Units, Timber Companies, Sawmills, Plywood Mills, and others.

Scope of Responsibilities:
Implementation of MTCS forest management and chain of custody certification

To submit a complaint about a certified organisation, please identify the organisation from the directories below and contact them directly using the details provided.

Forest Management:

MTCS/PEFC-Certified Forest Management Units

Chain of Custody:

MTCS/PEFC-certified Chain of Custody Companies

For complaints directed at MTCC, MTCC manages complaints and disputes in accordance with MTCS GD 3003:2026 – Complaints Handling and Dispute Resolution Mechanism – Guide for Stakeholders.

Before submitting your complaint to MTCC, please ensure that it is:

  • Relevant – the issue is relevant to MTCC, its operations, vision, and mission;
  • Specific – the complaint is specific to the matter — avoid general references that may cause confusion or misunderstanding;
  • Clear – make clear statements so that MTCC can understand the issues without confusion;
  • Evidential – there must be evidence of the issue being complained about;
  • Verifiable – it should be possible to verify the complaint and the evidence provided;
  • Actionable – it should be possible for MTCC to act on the complaint — avoid matters from the distant past or that cannot be acted upon due to legal limitations, government policies, social sensitivity, or other valid reasons.

Please note that if the matter is not related to MTCC, you will be informed and redirected to the relevant party.

What to Include in Your Submission

To ensure your complaint is processed, it must be submitted in writing, whether physical or digital. Your submission should include the following:

  • Your contact details – including your full name and a direct contact point, so MTCC can follow up with you directly.
  • Description of issue – clearly describe what you observed and why it may not align with the applicable MTCS standard.
  • Location – provide the site name or area where the issue occurred, including GPS coordinates (latitude and longitude) where available.
  • Date and time – indicate when the incident was observed.
  • Parties involved – name the certified organisation, certification body, or individuals concerned.
  • Evidence – attach supporting documents, photographs, or GPS data

Evidence Requirements

To ensure a fair and effective review, complaints must be supported by clear and verifiable evidence. MTCC cannot act on hearsay or vague allegations. Providing complete and verifiable information will significantly improve the effectiveness and timeliness of the review process.

Your evidence should include one or more of the following:

  • Geospatial data – GPS coordinates or maps that can be independently checked against official forest boundary records maintained by the relevant State Forestry Departments.
  • Visual proof – clear, dated, and geo-tagged photographs or videos of the alleged issue.
  • Official records – reports, letters, or government documents that can be cross-referenced against verified certification records.
  • Witness statements – written accounts from affected parties that include contact information for follow-up verification.

Complaints may be submitted to MTCC via:

  1. Email: [email protected]
  2. Online Complaints Form: https://mtcc.com.my/submit-a-complaint/
  3. Hardcopy: Address your written complaint to the Complaints and Nonconformity Secretariat, Malaysian Timber Certification Council, C-8-5, Block C, Megan Avenue 2, No. 12, Jalan Yap Kwan Seng, 50450 Kuala Lumpur, Malaysia. Please ensure your submission includes all required information as outlined above.

What Makes a Valid Complaint?

The following examples illustrate the level of specificity and evidence required for a complaint to be properly reviewed, explaining what makes a complaint actionable, and what does not.

Address to: Certificate Holder, copy to Certification Body
Example of a valid complaint
“On [date], I observed logging activity at [Forest Management Unit Name], GPS coordinates [latitude, longitude], which I believe falls within a riparian buffer zone that must be protected under MTCS ST 1002:2021, Criterion [X]. I have attached dated and geo-tagged photographs taken on-site, an official land use map obtained from the relevant State Forestry Department, and a written statement from a witness present at the time. The certified organisation is [State Forestry Department/FMU Name], audited by [CB Name].”
Why this works
It references the current applicable standard and a specific criterion, identifies the location by FMU name and GPS coordinates, names the relevant parties, and provides evidence that can be independently verified against official records.
Example of an invalid complaint
“I have heard that logging is happening in protected areas in [State]. The company involved is probably certified. Someone told me they saw heavy machinery near a forest reserve last month.”
Why this does not work
There is no specific location, date, company name, or supporting evidence. The information is second-hand and cannot be independently verified.
Address to: Certificate Holder, copy to Certification Body
Example of a valid complaint
“I am a timber buyer who received a delivery from [Company Name] on [date]. The shipment was invoiced as MTCS/PEFC-certified timber, but the certificate number on the accompanying documentation does not match the valid COC certificate listed for [Company Name] on the PEFC public database. I have attached the invoice, the accompanying documentation, and a screenshot of the relevant database record.”
Why this works
It is traceable, references specific documentation, and identifies a verifiable discrepancy in the certification chain.
Example of an invalid complaint
“I received a delivery of timber from [Company Name] on [date]. No certification documentation was included with the shipment.”
Why this does not work
Before submitting the complaint, the complainant should first request the certification documentation from the supplier and verify the company’s COC certificate on the PEFC public database. A complaint is actionable when a specific discrepancy has been identified between the documentation provided and the official certification records.
Address to: Certificate Holder, copy to Certification Body
Example of a valid complaint
“On [date], I observed that [Company Name] appeared to be using non-certified timber in a product line marketed as MTCS/PEFC-certified. I have attached the product labelling, a copy of the relevant transaction certificate, and a comparison against the certificate details listed on the PEFC public database, which shows a discrepancy.”
Why this works
It identifies a specific product, a specific company, and a verifiable discrepancy supported by documentation.
Example of an invalid complaint
“I saw the MTCS/PEFC label on products from [Company Name] but I suspect they might not actually be certified.”
Why this does not work
The complaint does not include the date of the observation, the location where the product was seen, the label number displayed, or a comparison against the COC certificate listed for the company on the PEFC public database. Without these details, there is nothing specific that can be verified.
Address to: Certification Body
Example of a valid complaint
“I believe the recent audit of [Company Name] by [CB Name] did not adequately assess harvesting practices observed at [location] on [date], which may not comply with the requirements under MTCS ST 1002:2021, specifically Criterion [X]. I have attached the relevant section of the standard, photographs from the site visit, and an official document from [authority] confirming the protected status of the area.”
Why this works
The complaint references the current applicable standard, identifies a specific criterion, and supports the concern with verifiable documentation.
Example of an invalid complaint
“Based on the 2014 Guidelines for the Interpretation of Requirements in MC&I and PEFC ST 1003:2018, I believe this forest operation is not compliant.”
Why this does not work
This does not meet the standard because both documents have been superseded. Concerns must be assessed against MTCS ST 1002:2021, the standard currently in force. References to obsolete requirements do not establish a valid non-conformance under the scheme as it currently operates.
Address to: Certification Body
Example of a valid complaint
“During the most recent audit of [Company Name] conducted by [CB Name] in [month/year], I have reason to believe that required stakeholder consultations were not carried out in accordance with MTCS procedures. I have attached the published audit summary and a written account from a community representative who was not contacted despite being a directly affected party.”
Why this works
It identifies a specific audit, a specific procedural concern, and is supported by a verifiable account from an affected party.
Example of an invalid complaint
“I feel that the certification body is too close to the companies it audits and cannot be trusted to be impartial.”
Why this does not work
A general perception of bias, without specific documented instances, procedural evidence, or named incidents, does not constitute a verifiable complaint.
Address to: Department of Standards Malaysia, DSM (National Accreditation Body)
Example of a valid complaint
“I am writing to raise a concern regarding the qualifications of the auditor assigned to the most recent certification audit of [FMU/Company Name] conducted by [CB Name] in [month/year]. Based on publicly available information, the auditor does not appear to hold the qualifications required under [CB Name]’s accreditation terms with DSM. I have attached the published audit report identifying the auditor, and the relevant section of [CB Name]’s accreditation scope for comparison.”
Why this works
It identifies a specific CB, a specific audit, and a specific concern about auditor qualifications that can be verified against DSM’s accreditation records.
Example of an invalid complaint
“I do not think the auditors sent to certify this forest know enough about the local environment to do their job properly.”
Why this does not work
A general opinion about auditor competence does not constitute a verifiable complaint about accreditation requirements. Concerns must identify a specific qualification gap that can be checked against the CB’s accreditation terms.
Address to: MTCC
Example of a valid complaint
“I am writing to raise a concern about [Company Name], which has a history of environmental violations in [location]. I believe the CB responsible for their certification, [CB Name], should review whether the company continues to meet the requirements under MTCS ST 1002:2021. I have attached news reports, government enforcement records, and photographs documenting the violations, dated [date].”
Why this works
It identifies a specific company, a specific concern, and provides verifiable documentation that the CB can cross-reference against the company’s certification records.
Example of an invalid complaint
“MTCC should not have certified [FMU/Company Name] because the company has been embroiled in many environmental scandals and is known for greenwashing.”
Why this does not work
The complaint does not identify a specific concern, name the CB responsible, or provide any supporting documentation. Reputation alone is not verifiable evidence. To be actionable, the concern must reference specific incidents supported by documentation.
Address to: MTCC
Example of a valid complaint
“I submitted a formal complaint to MTCC on [date] regarding [brief description of concern]. As of [date], I have not received acknowledgement within the 10 to 20 working day timeframe stated in MTCC’s complaints procedure. I have attached a copy of my original submission and the relevant correspondence to date.”
Why this works
It identifies a specific procedural concern within MTCC’s own administration, references the applicable timeframe from MTCC’s published procedure, and is supported by documentation that can be verified against MTCC’s records.
Example of an invalid complaint
“MTCC failed to act on my complaint about logging in [State] despite the concerns I raised. The certification should have been suspended by now.”
Why this does not work
This does not identify a specific procedural failure on MTCC’s part. A complaint about MTCC’s administration must reference a specific process, such as an unacknowledged submission or an unexplained closure, rather than dissatisfaction with an outcome.
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