Memorandum from Programme for Endorsement
of Forest Certification schemes (PEFC)
INTRODUCTION
PEFC (Programme for the Endorsement of Forest
Certification schemes) is an independent, non-profit, non-governmental
organisation, which promotes the sustainable management of the
world's forests through independent, third party certification.
Sustainably managed forests are those whose management implements
performance standards based on internationally agreed environmental,
social and economic requirements that form the cornerstones of
sustainability. Since its inception in 1999, PEFC has become the
world's largest forest management programme umbrella organisation
for national forest certification schemes; providing an open and
transparent assessment and endorsement scheme for national forest
certification schemes with the same high level of standards and
credibility. Currently millions of tonnes of wood are being delivered
to the processing industry and then on to the market place from
over 123 million hectares of certified forests.
PEFC greatly welcomes the opportunity provided
by the sub-committee of the Environmental Audit Committee to submit
evidence to their Inquiry on Sustainable Timber. Momentum to promote
the use of sustainably produced products is growing around the
world. Overall, wood products have a better environmental record
than competitor materials such as concrete and steel in sustainable
construction. A uniquely renewable material, wood has the lowest
energy consumption and the lowest level of carbon dioxide emissions
than most widely used building materials.
PEFC would like to make the following comments
to the specific questions raised by the sub-committee.
1. How useful has the work of the CPET proved?
How should its role develop to ensure further progress on the
issue of sustainable timber procurement?
PEFC believes that the work of CPET has helped
to raise awareness of certified wood-based products. PEFC welcomes
any initiative that assures that the legality and sustainability
of forest management and its resultant products.
CPET has sought to involve interested stakeholders
in the government's decision-making process. However, the process
could benefit from:
— Broadening the range of representation
of stakeholders in CPET to reflect the wider range of interests
in sustainable forest management including its down stream entities
such as processing industries.
— Broadening the scope to cover all
wood-based products including paper and board based products.
— A standardised and published set
of procedures, covering all aspect of CPET's work, including complaints
procedures, to ensure that the assessed schemes as well as any
other interested parties, understand their roles, responsibilities
and their opportunities to participate.
PEFC recognises that there is an ongoing need
to achieve continuous improvement in the measurement and monitoring
of sustainable timber procurement. However, PEFC also believes
that market will need time to absorb change and that the CPET
process should not attempt to continually change existing definitions.
Rather, they should work in consultation with all involved parties
to agree new judgement criteria and should then give all the interested
stakeholders in the supply chain sufficient time to adapt to new
criteria and to implement necessary change and enable experience
of its application to be obtained. Ideally, such reviews should
be periodic such as every five years for example, as is common
practice with all standards setting processes rather than on an
ad hoc basis. This would provide structure and additional confidence
in CPET's work.
In addition, as a leader in public procurement
for wood based products, the Government should engage with other
EU governments to work towards harmonisation of public procurement
policies to ensure no artificial trade barriers are created in
the largely international wood flows.
An enormous amount of progress has been made
in recent years in improving the quality of forest management
systems, but CPET should not ignore the very considerable investment
in terms of time, resources and money to achieve change and should
recognise the efforts being made by credible certification schemes,
such as PEFC, to substantially increase the supply of credibly
certified timber products. In addition, CPET should recognise
the need for its suppliers to adapt to new contract conditions
including bedding-in time to allow the transmission of changed
requirements to their suppliers to supply them with legal and
sustainable timber.
2. How reliable are the certification schemes
for timber endorsed by CPET? Are there concerns regarding either
the legality or sustainability of any of them?
PEFC considers that the CPET process was very
rigorous. PEFC believes that there should be no concerns regarding
either the legality or sustainability of any of the schemes endorsed
by the CPET.
Since it is necessarily the case that different
certification schemes will involve different implementation processes,
albeit sharing the same basic objectives and criteria, no two
schemes will appear to be identical. It should also be noted however,
that schemes adherence to international (ISO) standards and international
agreements on sustainable forest management create a sufficient
basis for comparing the compatibility of those schemes. The differences
found in such schemes should rather be celebrated, as they are
best adapted to local conditions and needs.
We believe that the CPET process has been rigorous
in establishing clearly defined criteria and in measuring different
schemes against them.
3. Is there sufficient data to determine
where and how timber purchased by Government is sourced?
PEFC does not believe that there is currently
sufficient data available and would welcome more information being
made available from procurement bodies. However, it notes that
HMG has recently appointed ProForest to run a timber procurement
advisory service—the Central Point of Expertise on Timber
(CPET) helpline. The portfolio of services proposed (training
workshops, guidance and case studies) should assist those procuring
timber products on behalf of HMG to purchase and supply legal
and sustainable timber.
It is important that a competitive free market
is allowed to operate to ensure that there is fair competition
between endorsed certification schemes. It is therefore of vital
importance that Government purchasing procedures are transparent
and open to scrutiny.
In this context, PEFC would welcome the opportunity
to work with CPET and with the recently announced Defra hotline,
to be run by ProForest, in creating greater transparency in this
area.
PEFC believes that it is vital that procurers
are given as much information as possible regarding the availability
of credibly certified supply systems.
Finally there is a need by government to be aware
of the availability of the types of timber it requires, when developing
its criteria. Therefore, the government together with industry
groups should closely monitor the availability of certified products
on the market.
4. Is the use of certification schemes enough
to ensure that the timber requirements of the UK and EU countries
do not have detrimental effects on forests and biodiversity in
developing countries? What other approaches should be used?
PEFC firmly believes that the processes adopted
by credible certification schemes take into account the impacts
on forests and biodiversity in developing countries. In this context,
PEFC, in common with other credible certification schemes, recognises
that there will need to be flexibility in matching certification
criteria to individual needs of different forest environments,
including those in developing countries.
It is important that whilst overall criteria
and objectives must remain the same, this should not mean a "one
size fits all" approach to implementation. PEFC believes
that this is taken into account in the policies of both Defra
and the CPET and that there are adequate assurances in the ongoing
review process to ensure successful implementation of the CPET
endorsement.
As in any other sector the third party accredited
certification includes sufficient safeguards to ensure the credibility
of and customers' confidence in its results.
It should be noted that whereas certification
schemes can provide assurances of management on the ground anywhere
in the world, they are no substitute or replacement for sovereign
governments' responsibilities to ensure good forest governance;
national legislative frameworks for law enforcement; reduction
of corruption and combating poverty and other social issues in
developing countries. All of which can have a significant impact
on the usage of forest resources. The UK Government decision on
sustainable procurement should complement all its other efforts
in promoting good governance in developing countries.
5. How satisfactory are the EU proposals
for FLEGT? Will they be stringent enough to have a significant
impact?
PEFC believes that the FLEGT process provides
a possible basis for the achievement of a common approach to forest
law enforcement, governance and trade.
PEFC recognises that different interested parties
may have individual views about the relative stringency of individual
components of the FLEGT process, and is concerned that the FLEGT
process does not have sufficient consensus to be able to guarantee
any real impact.
PEFC believes that forest certification will
play a role in the FLEGT process as one of the already established
and functional mechanisms to ensure the FLEGT objectives.
6. Should the social impacts of forestry
be taken into account within certification schemes? Would it be
legal to do so?
PEFC firmly endorses the SFM approach as defined
by the UN Conference in Rio and the following intergovernmental
process, which are based on the three pillars of Social, Environmental
and Financial Sustainability, with equal weight being given to
each element. In other words social criteria are already equitably
catered for within the forest certification of SFM and CPET should
be aware that the balance between the three elements achieved
by the multistakeholder dialogue within the intergovernmental
processes could be undermined if the holistic approach were replaced
by additional or undue focus on one of the pillars.
Thus, PEFC maintains that social aspects are
already a vital part of any credible forest certification process.
However, any analyses of social impacts must
necessarily take into account the prevailing legal regimes in
individual countries and the need for certification systems to
recognise the sometimes inconsistent conclusions of the democratic
process.
7. Does the inclusion of forestry projects
in the clean development mechanism within the Kyoto protocol have
any implication for certification schemes?
PEFC believes that the existing global certification
schemes have sufficient impetus and delivery mechanisms to achieve
significant expansion of global SFM. The inclusion of clean development
mechanisms with forest certification should therefore be further
developed and pursued.
As the PEFC is using international (ISO) standards
for the conformity assessment, which ensures compatibility with
any other certifications across all industry sectors, the results
of PEFC certification could be used as one of tools within the
clean development mechanism.
September 2005
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