APPENDIX 8
Memorandum from FinnForest UK Ltd
GENERAL COMMENTS
Finnforest UK Ltd. is part of an international
Finnish co-operative the Metsäliitto Group owned by 131,000
forest owners. In the UK we are the largest timber importer and
distributor of timber and timber products. We supply DIY, merchant
and construction companies so very often one step removed from
the final consumer.
Wood is the only construction material that
can be classed as truly sustainable and renewable; if it is sourced
from well managed sources. As such our company is the largest
supplier of certified timber products in the UK and we welcome
market drivers that support and promote legal and sustainable
timber.
We would like to offer the following comments
based on our experience of having representation on CPET as part
of Finnforest's Presidency of the Timber Trade Federation and
being at the front line as the UK Government Procurement Policy
has been implemented.
SUMMARY
— UK Government Policy has had a very
positive impact on the demand for legal and sustainable timber
and will help support those countries in the developing world
to implement forestry improvements.
— CPET is an excellent initiative to
encourage harmonisation in the UK market place is terms of mutually
recognising schemes and setting standards for Category B evidence.
— The trade is keen to work with CPET
to educate the market, improve reporting and advise on the availability
of legal and sustainable timber.
— Welcome the decision to revise CPET
assessment criteria to continually improve and take account of
future requirements; but this must done as to not dramatically
change the goal posts.
— Finnforest UK Ltd supports the FLEGT
initiative and as an international company coupled with the fact
the main certification schemes are international, we would encourage
the UK Government to advocate harmonisation of Government Procurement
Policies across the EU.
1. How useful has the work of CPET proved?
How should its role develop to ensure further progress on the
issue of sustainable timber procurement?
The timber trade is very competitive and as
such has historically been price sensitive. Finnforest UK support
the UK Government Policy and the formation of CPET as the largest
market driver for legal and sustainable timber in the UK. This
is a very welcome development in our view as it supports suppliers
and protects our and their investments in activities to move towards
sustainability. This is particularly welcome in developing countries.
In our experience a year ago suppliers in the Far East and Brazil
were not interested in certification. Now there is more demand
and more of a unified message from the UK; attitudes are changing
and this is ultimately having a positive impact on forestry in
countries where illegal logging and deforestation are rife.
We believe the market is very often confused
on what are the contract requirements, what is chain of custody
what is legal and sustainable; this is based on our enquiries
we receive and discussions with other traders. Invariably we would
deduce that at this present time Government contract requirements
will be very often not met as both the supplier and customer does
not understand what to look for. CPET's remit is to address this
but the task is huge. Finnforest UK has already had positive discussions
with CPET/DEFRA on closer working to educate the market place
to utilise resources on both sides.
The role of CPET should be broadened to become
a UK advisory body on legal and sustainable timber. It essentially
could become commercial and sell its service as the Government
recognised it didn't have the in house expertise to assess legality
and sustainability; many local authorities, companies and organisations
are in the same position. This would mean that interpretations
and examples of evidence for category B evidence are uniform across
the market so there would be no need for duplication. On this
basis we believe the CPET process which has representation from
TTF and WWF should be broadened with equal representation from
industry and eNGO's.
CPET is certainly impacting the market and we
believe is helping to go someway into addressing the mutual recognition
issue between the certification schemes; something the trade is
extremely keen to have. Many of our customers are using CPET as
the market requirement and many now request legal and sustainable
timber in line with the CPET assessment. This is vital for the
timber industry as the controversy is turning some potential customers
away from timber to use less sustainable materials such as steel
and concrete.
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?
The CPET process was simple to understand and
covered the issues very well. We welcome the decision for CPET
to revise assessment criteria and believe this should be done
to continuously improve and take account of future requirements.
However, time should be given to settle the process first and
any changes should not be done radically which effectively changes
the goal posts dramatically.
The certification schemes ultimately have the
same objectives but have been developed from different beginnings;
FSC developed for countries where governance is difficult in the
tropics or where the forests are large. PEFC on the other hand
was developed and is much more suited to the many small forest
owners that are very common in Europe. Sweden is the classic example
of this, all state owned or corporation owned forests are FSC;
in contrast all the forests that are owned by small forest owners
are PEFC. CPET has and should continue to embrace differences
in certification schemes as forestry is different in different
countries. Finnforest UK supports all certification schemes and
believes that the schemes currently endorsed provide a sound basis
for legality and sustainability.
3. Is there sufficient data available to
determine where and how timber purchased by Government is sourced?
No. Many of our customers are not often aware
that they deal with a Government contract or even Local Authority.
In some cases they do not understand the way Central and Local
Government works in others they are a sub-contractor. The UK Government
Policy has raised this issue as many of our customers/trade feel
for the first time they are actually being asked information;
this has rarely been witnessed before. This is perhaps an area
that the industry could work more closely with the Government
on in terms of reporting and the availability of legal and sustainable
timber. Could this be made a KPI for both Central Government departments
and perhaps this is a way to push this policy in to local Government;
in terms of Best Value reporting and targets on legal and sustainable
timber as currently happens with reporting on others such as percentage
recycled in each authority?
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?
No—certification only covers 7% of the
world's forests. However they are the easiest way to prove legality
and sustainability through the audited Chain of Custody. Forest
certification has proved difficult in developing countries and
there are other step wise systems being developed such as tracking
systems for timber that should be merited. As such UK Government's
decision to consider Category B evidence for legal and sustainable
timber is welcomed.
5. How satisfactory are the EU proposals
for FLEGT? Will they be stringent enough to have an impact?
The FLEGT proposals are very good as it recognises
that the issue of illegal logging is not just about the exporting
countries but the importing countries need to share some of the
responsibility. Finnforest UK as part of the Timber Trade Federation
supports the concept of legislation as long as this does not incur
large costs on what is a low value product. Other legislation
has already impacted our industry such as CE marking, Heat Treatment
as well as Certification and Chain of Custody that require considerable
investment. The success of the Voluntary Licensing Scheme will
depend on the participation of some of the major supplying countries
such as Russia and Far East.
One concern would be how EU deals politically
with countries such as Indonesia. Their Government has promoted
its own BRIK system as a way to combat illegal logging; the system
has been proved beyond doubt to be ineffectual. What would happen
(politically) if the Indonesians put this forward as their proposal
for licensing?
6. Should the social impacts of forestry
be taken into account within certification schemes? Would it be
legal to do so?
Yes, as forests cannot be sustainable if the
local community is not part of the management. CPET has included
some social aspects in that social law is inherent in the laws
of that country and includes multi-stakeholder engagement as part
of the assessment. Generally most certification schemes cover
social issues to varying degrees. Broadly speaking, in Europe
social aspects are covered by existing laws and there are no issues
of governance. However, in developing countries sometimes social
well-being is not covered in the law or if it is, it is ignored.
On that note it is important to take into account the laws of
any country.
7. 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?
Finnforest UK helped shape the Timber Trade
Federation's Indonesian initiative. In our view to combat the
issue on Indonesia it needs to be done at the political and the
local business level. The political level opens the doors whilst
offering some financial incentive allowing the business to business
negotiations to go ahead. If the political will hadn't been there
in Indonesia many of the mills would have been reluctant to move
forward due to political threats of closure.
September 2005
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