Memorandum from WWF
1. EXECUTIVE
SUMMARY
1.1 WWF has worked on the global problem
of deforestation and the underlying drivers of environmental decline
since 1992. We have a network of forest officers covering 75 countries
and have developed a body of experience on credible certification
as well as managing a global network of both producers and buyers
committed to the purchase of timber from well managed forests
as guaranteed by the Forest Stewardship Council (FSC) timber certification
scheme.
1.2 WWF has welcomed the Central Point of
Expertise on Timber (CPET) as an important step forward for the
Government policy on timber procurement. However, there is room
for considerable improvement and for CPET to remain credible it
should develop in a number of ways, such as allowing the inclusion
of social criteria, establishing a programme of annual, independent
monitoring and providing guidance on how to measure the assessment
criteria so that the scoring system is open and transparent. It
should also apply across all government departments, all public
authorities, as well as being encouraged across the private sector.
In addition, it should only endorse those certification schemes
with the highest standards of good forest management and the strongest
legal requirements, including the delivery of a chain of custody.
1.3 Of the four schemes endorsed by CPET,
WWF believes that only the FSC scheme is capable of delivering
consistently high standards of good sustainable forest management
and only the FSC has the strongest legality requirements in place.
WWF has expressed serious concerns to DEFRA Ministers with regards
to the recent "provisional" acceptance of the Programme
for Endorsement of Forest Certification (PEFC) and the Sustainable
Forestry Initiative (SFI) as being able to deliver legal and sustainable
timber. DEFRA's decision to accept PEFC and SFI certified timber
severely undermines the role and credibility of the CPET in guaranteeing
the legality and sustainability of timber products.
1.4 WWF believes that there is insufficient
data available to satisfactorily allow the Government to determine
where and how its timber is sourced. FSC is the only international
certification scheme which can track timber through every step
of the supply chain to the point of purchase. Therefore WWF believes
that the Government should insist that all timber certification
schemes deliver mandatory chain of custody, subject to independent
monitoring and independent, third party verification.
1.5 Certification schemes are just one tool
in an incomplete kit to help protect the world's forests. On their
own they will never be enough to eliminate the detrimental impacts
that the UK and EU have on forests and biodiversity in developing
countries. To help reduce the footprint of the UK and EU in timber
producing countries we should adopt comprehensive legislation
that will prohibit the import of all illegally sourced timber
and wood products into the EU, regardless of the country of origin,
and which promotes socially and ecologically responsible forest
management worldwide. The UK's current Presidency of the EU provides
the Government with a unique opportunity to initiate progress
in this respect.
1.6 WWF has been fully supportive of the
EU FLEGT Action Plan from the outset, but has a number of reservations
with regards to its successful implementation. It is our opinion
now that the current version of the Licensing Regulation (as of
19 September) will fail to have a significant impact on the trade
in illegal timber.
1.7 WWF strongly believes that the social
impacts of forestry should be taken into account within certification
schemes. Credible certification schemes such as the FSC scheme
already take the social impacts of forestry into account and WWF
has recently sought legal opinion to confirm that European Directives
in fact do not exclude the inclusion of social criteria.
2. INTRODUCTION
2.1 WWF, the global environmental network,
welcomes the opportunity to contribute evidence to the Environmental
Audit Sub-committee inquiry into sustainable timber. WWF has been
working on the global problem of deforestation and the underlying
drivers of environmental decline since 1992. We have focused our
international forest targets on the protection, management and
restoration of the earth's forests. We have a network of forest
officers covering 75 countries and have developed a particular
body of experience on credible certification, the tracking of
timber flows between producer and consumer countries and the management
of a global network of both producers and buyers committed to
the purchase of timber from well managed forests as guaranteed
by the Forest Stewardship Council (FSC) timber certification scheme.
2.2 WWF works closely with the international
and EU institutions, national governments, and in the UK, local
authorities and the devolved governments in Wales and Scotland
to put into practice sustainable policies for timber. WWF's written
evidence to this inquiry focuses on those areas where we can contribute
perspectives derived from these specific areas of competence.
We would welcome the opportunity to elaborate on any of these
points either through the provision of oral evidence or submission
of further papers, should the Committee find this helpful.
3. How useful has the work of the CPET proved?
How should its role develop to ensure future progress on the issue
of sustainable timber procurement?
3.1 WWF has welcomed the Central Point of
Expertise on Timber (CPET) assessment as being an important step
forward for the Government policy on timber procurement. Over
the last few years we have seen significant progress in the UK
market, as a growing number of companies develop and implement
responsible purchasing policies. This has led to real improvements
in many producing countries. We acknowledge the UK Government's
procurement policy as an important driver underpinning this progress,
in that it has demonstrated to other countries, both in the EU
and outside, that practical implementation of timber procurement
policies by governments is possible. This is particularly important
in the light of the ongoing discussions on the Forest Law Enforcement
Governance and Trade (FLEGT) Action Plan in the EU, and at the
recent G8 meeting, as procurement is acknowledged as a key part
of any strategy to tackle illegal logging.
3.2 However, WWF has expressed reservations
about the criteria used by CPET to assess certification schemes,
most notably the absence of social criteria, and the lack of guidance
on how to interpret the CPET criteria themselves. Having set up
the CPET, it is crucial that the UK Government remains proactive
in promoting the CPET as a part of a suite of solutions, which
exist to tackle illegal and destructive logging. The UK Government
will need to ensure that the CPET approves only those schemes
clearly demonstrating positive change on the ground and real improvements
in forest management. WWF has already made clear to Government
Ministers at DEFRA our serious concerns with regards to the recent
"provisional" acceptance of two certification schemes,
the Programme for Endorsement of Forest Certification (PEFC) and
the Sustainable Forestry Initiative (SFI). We believe that this
is a serious backward step. A large number of studies carried
out for industry and NGOs[21]
have clearly shown that PEFC, in particular, is unable to deliver
environmentally and socially responsible forest management on
the ground, across the range of national schemes endorsed by the
PEFC Council and that SFI lacks a mandatory chain of custody.
We believe that DEFRA should be fully aware that its decision
to accept PEFC and SFI certified timber severely undermines the
role and credibility of the CPET in guaranteeing the legality
and sustainability of timber products.
3.3 It is also our opinion that the CPET
process is in need of some fine-tuning. WWF, Greenpeace, FERN
and Friends of the Earth have challenged the current scoring system
and consider that more guidance is needed on how to interpret
the CPET criteria. Furthermore, without proper field audits, it
is impossible to check whether certification schemes actually
lead to improvement in forest management on the ground, or even
whether they are properly implemented in practice. If the CPET
process has accepted certification schemes which permit bad practice
on the ground, the adopted criteria would have to be re-examined
to ensure that this cannot happen again. Failure to do so would
undermine the stated aims of CPET and with them the UK Procurement
Policy.
3.4 DEFRA must also recognise the key role
environmental and social NGOs play in being able to demonstrate
the credibility of a certification scheme in delivering the key
elements of sustainable forest management and thereby give it
legitimacy. It is our view that for CPET to remain credible in
its assessment of schemes, it must develop in the following way
in order to ensure future progress on the issue of sustainable
development:
(a) The CPET criteria should allow for the
inclusion of social criteria in assessing credible certification
schemes (please see also question 6.)
(b) The CPET should establish a programme
of annual, independent monitoring to assess the performance of
certification schemes on the ground. Do they improve forest management
on the ground for the benefit of the economy, the environment
and the local people?
(c) The UK Government should ensure the full
integration of its policy on timber procurement across all government
departments and within all public authorities.
(d) The CPET should develop clear guidance
on how to measure the assessment criteria so that the scoring
system is open and transparent.
(e) The CPET should set up an annual consultation
with all key stakeholders and interest groups.
(f) The CPET should undertake a fully inclusive
process of reviewing its criteria and developing guidelines on
how to implement these criteria to prevent certification schemes
which permit bad forest management practices slipping through
the net and being accepted under the CPET assessment procedure.
(g) The UK Government should facilitate the
application of the CPET within the private sector and extend the
requirements for sustainable forest management to cover all timber
and wood products entering into the EU.
(h) The UK Government must ensure that the
CPET ultimately endorses schemes that deliver sustainable practices
on the ground in timber-producing countries.
(i) DEFRA must ensure that Government policy
on CPET is applied in practice.
(j) The UK Government must hold the PEFCC
to their commitment to have all national schemes adopt the revised
international criteria by October 2005 (six months from April
2005) and carry out a re-assessment of all certification schemes
using CPET criteria no later than the end of 2005.
(k) In reassessing the PEFC, the CPET must
look in detail at a number of PEFC endorsed national schemes,
notably those that are known not to comply with the CPET criteria
at present.
(l) The acceptance of the SFI should be limited
to timber coming from those companies which have established a
proper chain of custody and only apply to timber labelled according
to the SFI percentage based labelling scheme (at a level of 70%
plus).
(m) In all its communications, DEFRA should
clearly state that acceptance of the SFI scheme by the CPET for
UK Public Procurement Policy is limited to timber that has been
labelled according to the SFI percentage based labelling scheme
and where over 70% of the timber is from SFI certified sources.
4. How reliable are the certification schemes
for timber endorsed by the CPET? Are there concerns regarding
either the legality or sustainability of any of them?
4.1 Currently the CPET endorses four schemes
as delivering both legal and sustainable timber—the Forest
Stewardship Council (FSC), the Canadian Standards Association
(CSA), the Programme for Endorsement of Forest Certification (PEFC)
and the Sustainable Forestry Initiative (SFI). The Malaysian Timber
Certification Council (MTCC) is considered to deliver legal timber
only. WWF in partnership with the World Bank, has recently undertaken
an assessment process ourselves (the Questionnaire for Assessing
the Comprehensiveness of Certification Schemes/Systems). This
found that only the FSC scheme is capable of delivering consistently
high standards of good forest management, which meet the principles
of the WWF/World Bank Alliance, across different countries. This
was supported by the findings of two further studies undertaken
by WWF and by UPM Kymmene (a Finnish timber company). In addition
WWF, together with FERN, Greenpeace and Friends of the Earth undertook
a full assessment of the PEFC and SFI using the CPET and found
that we disagreed with the assessment of PEFC across 13 of the
CPET criteria and with SFI across 18 of the CPET criteria. These
findings underwrote our decision not to support the recent decision
by the UK Government to give provisional approval to both the
SFI and PEFC schemes. We believe that the CPET must approve schemes
on their proven merit in terms of meeting the CPET criteria and
not on their unproven, provisional merit.
4.2 With regards to the ability of certification
schemes to meet legal requirements. WWF believes that certification
schemes may not be the most appropriate and comprehensive solutions
to the illegal logging problem. They are quality assurance systems
and have not been designed as tools to enforce the law and to
be made compulsory. They are not based on regular and unannounced
audits and on continuous sampling. Given this, certification schemes
do not provide the level of confidence that is likely to be required
to demonstrate legal origin. In addition improving "current
rules and regulations" may not be adequate to detect illegal
logging and to prevent fraud. With regards to certification in
Africa, by design, certification cannot be used as a detection
tool. Certification audits do not involve probing, in-depth investigation
for fraud. Legality is not the primary concern: assessors are
not policemen. Certification is a quality assurance approach and
demands trust and goodwill. Initial assessments and surveillance
visits are limited in time, frequency and area. Current chain-of-custody
requirements and audit systems are therefore vulnerable to abuse.
4.3 It is clear however that certification
schemes are being considered as a possible means of delivering
legality. The current FLEGT licensing regulation is considering
the possibility of using certification as an alternative means
of verifying that timber imports into the EU are legal. WWF would
have strong concerns if this were to happen without imposing mandatory
spot checks and unannounced audits as a requirement for verifying
the legality of certified timber.
4.4 WWF believes that only the FSC is currently
capable of implementing these additional requirements. It already
has the strongest legality requirements in place (having recently
tightened these requirements still further) and is the only certification
scheme with monitoring and verification systems in place which
could be easily modified to deliver the necessary guarantees.
4.5 At the Forest Management Unit level,
FSC requires a forest management plan, accompanied by maps delineating
certified forest areas. Annual monitoring visits from an independently
verified Certification Body (CB) check how the management plan
has been carried out on the ground, using the maps as a reference.
Under these conditions it is impossible to hide large scale illegal
logging if it has occurred within the certified area. Where illegal
logging has occurred, FSC certificates have been withdrawn.
4.6 With regards to the ability of the FSC
Chain of Custody to eliminate illegal timber, this is a little
more complicated, but rules have been tightened and FSC continues
to operate the most reliable international system that exists
today on the global market. For the unknown wood portion of any
certified timber supply/product, FSC operates a controlled wood
standard[22]
where it is incumbent upon the supplier at each step of the supply
chain to prove that the timber being supplied is legal. Companies
have to have systems in place which can be audited by the CB.
The company has to be able to trace the timber back to the District
of Origin. In addition the company also has to evaluate whether
the district in question is at a high or low risk of illegal logging.
In parts of the world where the District of Origin is identified
as being high risk, then an independent, third party audit at
a forest management unit level is mandatory to prove that the
Forest Management Unit (FMU) meets the controlled wood standard.
[23]
4.7 The problem with certification schemes
is that spot checks and unannounced audits are not permitted.
The FSC scheme appears to be the exception in that Certification
Bodies are free to carry out spot checks and unannounced audits.
However, they hardly ever do, hence the need to make these a mandatory
part of the certification scheme.
5. Is there sufficient data available to
determine where and how timber purchased by Government is sourced?
5.1 The ability to track timber back to
the forest from which it was extracted has been a priority for
NGOs since the early 1990s and is the main reason why WWF became
involved in the setting up and implementation of the FSC certification
scheme. It is critical if the illegal trade in timber and destructive
logging practices are to be controlled to be able to have a system
which not only guarantees good forest management on the ground
but which can also track the timber from that well managed forest
through every step of the processing and supply chain to the point
of purchase. It is WWF's belief and formal position that FSC is
the only international certification scheme that can do this.
There are obvious limitations with using certification as a means
of determining where and how timber is sourced, in that, given
that it is a market driven, voluntary process, it does not have
universal coverage. Therefore it is up to Government to ensure
that they insist on timber certification schemes or tracking systems
which deliver mandatory chain of custody, subject to independent
monitoring and independent, third party verification.
6. Is the use of certification schemes enough
to ensure that the timber requirements from the UK and EU countries
do not have detrimental impacts on forests and biodiversity in
developing countries? What other approaches should be used?
6.1 Certification is a voluntary process
which requires the cooperation of the forest owner and concession
holder. Certification schemes are just one tool in an incomplete
kit to help protect the world's forests. Credible certification
such as the FSC (currently the only certification scheme endorsed
by WWF as delivering good forest management) has the potential
to minimise the detrimental impacts on forests and biodiversity
in developing countries. However its coverage is far from universal
and given that it is market driven will never be enough to eliminate
the detrimental impacts that the UK and EU have on forests and
biodiversity in developing countries.
6.2 The EU developed the FLEGT Action Plan
in order to find a way forward on the issues of legality and sustainability
in the forest sector. WWF have supported this Plan from the outset
but have made clear that there are serious gaps in its coverage.
WWF, together with other key stakeholders has identified some
potential solutions and consider that they could help reduce the
footprint of the UK and EU in timber producing countries:
(a) The submission without further delay,
of a comprehensive legislative proposal that will prohibit the
import of all illegally sourced timber and wood products into
the EU, regardless of the country of origin, and the promotion
of socially and ecologically responsible forest management worldwide
as the final objective.
(b) In addition to the proposals within the
draft EU Licensing Regulation, there should be mandatory licensing
of all timber and wood exports to all destinations. This should
be a pre-condition of a partnership agreement between a producer
and consumer country.
(c) The EU Licensing scheme should include
all timber and timber products, including pulp and paper.
(d) Independent verification of legality
prior to the issuing of a licence and independent monitoring of
the licensing system are fundamental to the success of the EU
Licensing Scheme. The European Commission must ensure that both
the verification and the monitoring procedures adopted by all
partner countries are effective and transparent. Criteria for
effective verification and monitoring must therefore be written
into the Commission's negotiating mandate. Independent spot checks
by civil society groups should be part of the process.
(e) Partnership agreements must commit producer
countries to a time-bound action programme that will tackle the
weaknesses in forest sector governance and that will lead ultimately
to Sustainable Forest Management (SFM). The EU's continued acceptance
of FLEGT licences must be tied to satisfactory progress by partner
countries towards implementing the action programme.
(f) Weaknesses and injustices in a partner
country's laws must be identified and proposals for change developed
in a process that involves all stakeholders. Transparency and
participation in legislative reform are conditions for good governance.
The Commission's negotiating mandate must specify that the programme
of activities set out in a partnership agreement will include
as the first step a participatory review of all the partner country's
forest related laws (including human rights law, customary law
etc) to identify weaknesses and injustices. The review should
conclude with proposals for changes to address identified weaknesses
and injustices.
(g) Partnership agreements must be developed
through a full stakeholder process. Therefore it is essential
that partnership agreements are developed through a process of
broad engagement with non-state actors and favourable towards
community forestry and are aimed at creating public accountability
and transparency in forest management. The negotiating mandate
should lay out clear conditions for the process of developing
partnership agreements and should make adoption of partnership
agreements conditional on the support of a representative range
of non-state actors.
(h) The review of existing national legislation
and further legislative options which could be applied with a
view to addressing the illegal logging issue and related trade
issues.
(i) The establishment of an EU network to
facilitate the exchange of information on the illegal trade in
timber for customs, administrative and judicial authorities.
(j) Ensure that the voluntary partnership
agreements incorporate partnership principles committing producer
countries to a time-bound action programme and involving measures
to tackle the weaknesses in forest-sector governance, contribute
to socially and ecologically responsible forest management and
an end to biodiversity loss, and promote social equity and poverty
alleviation."
(k) Ensure stronger, effective and meaningful
participation of civil society and democratically elected representatives
in the negotiation and implementation of FLEGT partnership agreements,
as well as in the process of reviewing the partner country's forest-related
laws to identify weaknesses and social and environmental injustices
and, where necessary, the drafting of proposals for change.
(l) Change the legal basis for the current
Licensing Regulation and insist that the European Parliament be
fully involved and informed of the progress made at every stage
of negotiations on FLEGT partnership agreements.
(m) Insist that the Commission and the Member
States integrate forest law enforcement, governance and trade
into the planning and implementation of the next round of Country
Strategy Papers (CSPs), in particular in regions and countries
with significant forest resources, and provide adequate funds
from geographic budget lines in order to build capacity and support
implementation of key reforms.
(n) Make use of the flexibility in the revised
Public Procurement Directives to implement a national public procurement
policy which procures only legal and sustainable timber.
(o) Explore other legislative options for
controlling the trade in illegal and unsustainable timber such
as money laundering legislation, criminal law and CITES. In 1998,
TRAFFIC published a report which highlighted that as many as 99
different tree species were highly threatened, many of them as
a result of over exploitation. It was feasible for many of these
to be given a CITES listing under either Appendix I or Appendix
II.
(p) Work through the G8 and other international
process to win support from other key consuming countries such
as Japan, US, China and India in tackling illegal and destructive
logging.
7. How satisfactory are the EU proposals
for FLEGT? Will they be stringent enough to have a significant
impact?
7.1 WWF has been fully supportive of the
EU FLEGT Action Plan from the outset, but had a number of reservations
with regards to its successful implementation. These concerns
have been expressed continuously at both an EU and Member State
level since the publication of the Action Plan in 2003. WWF has
continued to follow the development of some of the key elements
of the Action Plan, including the three phases of the Sustainable
Impact Assessment (SIA) undertaken by DG Trade in 2004. Unfortunately
there appears to have been no attempt whatsoever to tackle concerns
expressed by the timber industry, social and environmental NGOs,
the Agricultural Council and the European Parliament. [24]It
is our opinion now that the current version of the Licensing Regulation
(as of 19 September) is so weak as to be meaningless and will
consequently fail to have a significant impact on the trade in
illegal timber.
7.2 Vital elements including the issue of
exporting timber via third countries, product coverage and the
focus on sustainable forest management have been stripped out
of the draft regulation. If it is passed in its current form it
will not lead to meaningful improvements on the ground, will fail
to encourage further development of credible certification schemes
such as the FSC which are capable of delivering good forest management
and perhaps key, from an EU perspective will undermine legitimate
business.
7.3 WWF believes that a tougher approach
should be adopted to ensure the UK and EU Countries do not have
a detrimental impact on forests and biodiversity in developing
countries. Legislation which ensures the import of timber from
well managed sources and allows customs authorities to seize illegally
sourced timber and wood products at the point of entry into the
EU and prosecute those that trade in them should be adopted at
an EU level. This should also encompass measures to ensure good
governance, a chain of custody, protection of the poor and disenfranchised
and the provision of aid and technical assistance. Such legislation
would ensure that the root causes of forest crime (including poverty
alleviation) can be addressed and that illegal logging can be
brought to a stop. The UK's current Presidency of the EU provides
the Government with a unique opportunity to initiate progress
in this respect. However, WWF is extremely concerned that pushing
the Regulation through before the end of the Presidency will come
at the expense of any meaningful content.
8. Should the social impacts of forestry
be taken into account within certification schemes? Would it be
legal to do so?
8.1 If by "social impacts" the
Committee is referring to social issues with regard to environmental
protection and sustainable forest management (such as protecting
the rights, well being and livelihoods of indigenous peoples),
then it is our view that not only must they be taken into account,
but it is entirely legitimate to do so. Credible certification
schemes such as the FSC scheme already take the social impacts
of forestry into account. WWF has followed the revision of the
Public Utilities Directives from the outset and is firmly of the
opinion that the Directives do not exclude the inclusion of social
criteria. Therefore, European governments are free to procure
not only environmentally responsible but also socially responsible
timber. To confirm the validity of this position, WWF sought legal
opinion from Barrister Paul Lasok of Monckton Chambers, who confirmed,
[25]
". . . the general proposition that "social"
criteria (of the sort here under consideration . . .) cannot be
taken into account in a public procurement exercise is unfounded
whether one approaches the matter from a high level (that of the
principles underlying the EU public procurement regime|.) or from
the lower level of the application of contract award criteria."
This position has been supported by the Social
Platform of NGOs in Brussels.
9. How successful has the bilateral agreement
with Indonesia been in reducing the imports of illegal timber
into the UK? What progress has there been on negotiating agreements
with further countries?
9.1 WWF is currently monitoring the progress
of EU governments made in existing bilateral agreements such as
the one that exists between Indonesia and the UK, as well as progress
made in negotiating agreements with further countries. With regards
to the agreement with Indonesia, it is a bit too early to say.
It has certainly highlighted some interesting issues, in that
both the UK and Dutch Timber Trade Federations have found that
no member company could guarantee that the timber they were importing
from Indonesia was legal and that illegal timber as a percentage
of overall timber exports from Indonesia is estimated at running
at more than 80%.[26]
9.2 Information with regards to negotiating
further agreements with other countries is as follows:
| UK and Ghana | Promising developments. There has been a national workshop, together with an action plan on finalising the VPA.
|
| Germany and Cameroon | Promising developments. National workshop together with an action plan on finalising the VPA.
|
| France and Congo Brazzaville and Gabon. |
Slow. France have funded a feasibility study and are looking to second a national expert to the regional team
|
| The Netherlands and Malaysia | Slow. The Dutch delegation has undertaken two missions to Malaysia. One technical and one at a ministerial level. They have agreed a set of minutes.
|
| European Commission and Indonesia | Just starting. There have been staffing difficulties in the Commission delegation (not enough of them). They are currently looking to hire a consultant to assist with progress and provide technical assistance.
|
| Spain and Latin America | Just starting. Spain has been supportive and has brokered meetings with Bolivia, Mexico and independently with Ecuador. There has been some progress although no information available as to what this progress is.
|
| |
9.3 With regards to negotiations with Brazil, no discernible
progress has been made due to the mixed messages emanating from
the Brazilian Government. There has been a meeting between the
EC and the Ministry of Foreign Affairs, where the customary criticism
with regards to the Trade part of the FLEGT action plan has been
raised (ie they want nothing to do with it). However, they are
potentially interested in governance assistance. The Brazilian
Environment Ministry on the other hand is interested in all aspects
of the action plan. The European Commission considers it important
to get Brazil involved in the regional Latin American FLEG(T)
process. The World Bank together with a small group of donors
from the US, UK, EC, Switzerland, France and Germany has expressed
an interest in assisting this process. The World Bank is the recipient
of a substantial grant from the Tropical Forest Development funding
line (Multi Donor Trust Fund). The US also has funds ready to
use and both the US and UK Governments have lobbied the Brazilians.
The question now is whether Brazil will participate in the Latin
American FLEGT process and if not, whether the process can go
ahead without them. A possible partnership priority for Brazil
could be governance at the frontier of Brazil's agricultural estate.
In order to bring them on board however, it may be that key donors
such as the World Bank and the US will have to take a low profile
in the Latin American FLEGT process and allow others to coordinate
activities.
9.4 Further information that WWF has on progress dates
back to September 2004, when we carried out our last EU Government
Barometer exercise. This showed unequivocally that European governments
were ineffective in combating illegal logging. The report rated
12 countries on nine different steps[27]
needed to tackle illegal logging and found that none of them had
achieved a satisfactory performance overall.
9.5 According to the study, the UK came out best—rated
moderate to good—and was ahead of Denmark, Germany and Sweden,
which were credited with an overall moderate performance. Austria,
Finland, France, Greece, The Netherlands, Spain, Italy and Portugal
were all rated poorly. WWF are particularly concerned by the poor
performance of Portugal and Italy on this issue given the scale
of their tropical timber markets. The survey shows that most governments
support efforts at the European Union (EU) level to outlaw imports
of illegal wood, tackle illegal logging in accession and candidate
countries, and follow through with a proposed voluntary mechanism
to keep illegal timber out of the EU. However, they are failing
to implement strong measures in their domestic markets.
9.6 For example, while EU governments purchase about
20% of all wood products sold in the EU for public works, only
six countries (Austria, Denmark, France, Germany, Greece, and
the UK) have committed to buying wood from legal and sustainable
sources. Of these, only the UK is monitoring implementation of
its public procurement policy.
9.7 The UK is also the only country to have a partnership
with a wood-producing country (Indonesia) to combat illegal logging
and related trade. According to WWF, similar initiatives launched
by other EU countries don't include clear targets to actively
reduce the import of illegal wood to the participating EU country
and cannot be seen as real partnerships.
10. CONCLUSION
In conclusion, whilst WWF welcomes the progress that has
been made in the Government's timber procurement policy and recognises
the added value that the CPET has the potential to bring, we are
concerned that in its current form the CPET is flawed. If the
Government continues to accept certification schemes which lack
some of the fundamental elements of legality and sustainability
and if the CPET fails to develop some of its key criteria and
guidance, it is our opinion that the CPET, and with it the UK
procurement policy, will fail in its stated objective.
Similarly, efforts to govern the trade in timber products
at the European level are to be welcomed, however, it is becoming
increasingly clear that industry pressure and Member State inaction
has led to a watering down of the proposed Licensing Regulation
and the effectiveness of the EU FLEGT Action Plan. Urgent action
is needed to ensure that the proposed Regulation serves to ensure
the delivery of legal and sustainable timber and wood products
and does not put legitimate business at an economic disadvantage.
Finally, on their own, certification schemes and voluntary
licensing are not enough to help reduce the detrimental impact
that the UK and EU have on forests and biodiversity in timber
producing countries. WWF is calling for further measures to be
adopted at both national and EU level to help tackle illegal logging,
along with its associated problems, including the introduction
of tougher legislation that will prohibit the import of all illegally
sourced timber and wood products into the EU, regardless of the
country of origin, and the promotion of socially and ecologically
responsible forest management worldwide as the final objective.
The UK's current Presidency of the EU provides the Government
with a unique opportunity to initiate progress in this respect.
September 2005
1. Position on the development of a voluntary licensing scheme
on timber.
2. Position on an EU legislation that would outlaw the import
and marketing of illegal wood.
3. Position on an EU initiative that would stop illegal logging
in EU accession and candidate countries.
4. Level of collaboration across government departments on
the FLEGT action plan.
5. Commitment to ensure public procurement of legal and sustainable
wood products.
6. Implementation of commitments on public procurement of
legal and sustainable wood products.
7. Participation in partnerships on combating illegal logging
and related trade
8. Effect of participation in partnerships on combating illegal
logging and related trade.
9. Level of priority for projects in wood-producing developing
countries to reduce illegal logging.
21
Fern, "Footprints in the Forest," Jan 2004; Proforest,
"WWF/World Bank Alliance QACC Study," July 2005; WWF
CAR Request Study, June 2005; DNV, "UPM Kymmene Forestry
& Wood Sourcing. Parallel Testing of Certification Schemes."
2005. Back
22
Contolled wood standards FSC STD 40005, "Controlled wood
for manufacturers." Back
23
FSC STD 30010, "FSC standard for forest enterprises supplying
non FSC certified controlled wood." Back
24
Text showing concerns expressed, eg parliamentary statements,
conclusions, industry statement etc. Back
25
Full legal opinion attached to this submission. Back
26
Hirschberger, P, "Illegaler Holzeinschlag und Oesterreich."
WWF Austria Study 2005. Back
27
The 9 steps to combat illegal logging used to rate the 12 countries: Back
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