APPENDIX 9
Memorandum from the Forest Products Association
of Canada (FPAC)
BACKGROUND ON
FPAC
The Forest Products Association of Canada (FPAC)
consists of Canadian forest products companies who manage more
than 70% of the managed forest land in Canada. In January 2002,
FPAC was the first national forest industry association in the
world to commit its members to achieving 3rd party sustainable
forest management (SFM) certification on lands under their direct
management. Members have until December 2006 to achieve 3rd party
SFM certification to the CSA, FSC or SFI certification standards.
New members have five years from the date of joining FPAC. This
commitment has resulted in substantive certification progress
across our membership, and has positioned Canada as the global
leader in SFM certification (See Annex 1). In fact, Canada has
currently more 3rd party certified forest land (113 million hectares)
than any other country. Hence buying from Canada makes purchasing
of forest products from certified sources easier than in most
nations.
FPAC'S VIEWS
ON CPET
FPAC is pleased that many buyers of Canadian
forest products (companies and governments alike) are increasingly
recognizing the credibility of the CSA, SFI and FSC SFM standards
and the rigor of their requirements. FPAC is also pleased that
CPET recognizes all three SFM certification standards in use in
Canada. FPAC has done many comparisons of the CSA, SFI, and FSC
standards. [2]
FPAC believes that those 3 SFM standards promote
key public values and sustainability. Many comparisons consider
standards based on what they once were, rather than reflecting
the changes made to those standards through revision processes.
FPAC believes that many of the concerns once raised about those
certification standards have now been addressed through revisions.
FPAC also feels that the Programme for Endorsement
of Forest Certification schemes (PEFC) is a strong forest certification
endorsement program. We are very pleased to see that the recent
DEFRA announcement stated that "CPET has now endorsed PEFC
and SFI, alongside formerly endorsed CSA and FSC as providing
assurances of both legal and sustainable timber". Indeed,
PEFC has grown to endorse 123 million certified hectares and it
is interesting to note that over half of those endorsed hectares
can be attributed to recognition of the CSA SFM Standard.
We understand that as part of the CPET initiative,
the CSA, FSC, SFI, PEFC, and Malaysian schemes were assessed against
specific criteria (not specific to one standard) , and that the
relevant standards bodies were given several opportunities to
clarify their standards. This is commendable as there is not just
one path to sustainability. We believe that all certification
standards promoting sustainable forest management should be given
serious consideration.
It is also important to note that many endorsement
schemes (ie FSC and PEFC) recognised that standards' requirements
must reflect the various national and regional contexts. Both
PEFC and FSC have common level thresholds for endorsement based
on specific criteria, but then the standards they endorse should
never be considered to be equivalent. What the PEFC and FSC approaches
have in common is that the standards they endorse all meet minimum
common thresholds. If an analysis were undertaken, it would become
clear that in many of the FSC standards across the world, the
treatment of chemical use, clear-cutting, and other hot button
issues such as old growth varies dramatically as it is also the
case for PEFC. This is raised because some FSC proponents believe
inaccurately that FSC does not certify forests that have been
clear-cut, that have old growth harvested, or that have chemicals
applied to them. This is simply not the case. This is not a criticism
of the FSC, but rather an expression of the variance and values
across regions and nations that come to be recognised. Hence,
those conducting the inquiry should understand that no standard
is a golden standard, but that all four of those standards currently
ranked "sustainable" under CPET are indeed leaders in
promoting sustainable forest management through transparency,
public input, forest management objectives, and an independent
3rd party audit.
FPAC cannot comment on the Malaysian standard
as it is not one that we have familiarity with. However, FPAC
hopes that developing nations will be given the opportunity for
endorsement based on a phased approach to certification with clear
benchmarks and timeframes. Many developing nations with institutional
and enforcement challenges need incentives to keep improving,
and not barriers from the marketplace.
CPET should be proud of its accomplishments
and the positive changes it has encouraged. For example, as a
result of CPET initial rankings of legal for SFI and PEFC, the
proponents behind these standards quickly responded to address
the shortcomings as set out by CPET. SFI moved quickly to endorse
an internationally recognised chain-of-custody standard to track
certified content in forest products, and PEFC moved for more
transparency in the audit process and audit reporting. Nobody
knows for sure whether these changes would have occurred without
the leadership of CPET, but the swift response by these standards
organisations to revise their certification program in the exact
areas where CPET raised concerns, is indeed an indicator that
CPET is promoting positive changes. CPET is not only endorsing
certification programs that meet its requirements, but is also
promoting SFM by bringing about improvements in forest certification
programs whose proponents wish to be recognized in CPET and gain
preference in UK timber procurement purchases.
FPAC trusts that the government of the United
Kingdom will continue to work with all standards bodies and stakeholders
involved to ensure CPET sends the right incentives to both reward
and promote positive change. If you have any questions concerning
the material in this letter, please do not hesitate to contact
the undersigned.
Annex 1
2 You can see a copy of the most recent study "Certification
Similarities and achievements" on the following link: http://fpac.thinkup.com/en/resource_centre/PDFs/certification_similarities_E.pdf Back
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