APPENDIX 17
Memorandum from the United Kingdom Forest
Products Association
How useful has the work of CPET proved? How should
its role develop to ensure future progress on the issue of sustainable
timber procurement?
We consider the work of CPET to be invaluable.
Authoritative information is welcomed by specifiers, suppliers
and users of wood and wood products in the UK. CPET can usefully
continue to monitor the performance of the principal forest certification
schemes which provide wood and wood products to the UK market.
Given the increasing awareness of the importance of certification
of forest management and chain of custody, CPET could provide
information and guidance to the private sector, in addition to
the current service to public sector procurement officers. We
are uncertain about the level of awareness amongst public sector
procurement officers in relation to the information and advice
available from CPET.
How reliable are the certification schemes for
timber endorsed by the CPET? Are there any concerns regarding
either the legality or sustainability of any of them?
The four forest certification schemes which
have been assessed by CPET and its consultants as providing assurance
of legal and sustainable supplies (ie CSA, FSC, PEFC and SFI)
are considered to be very satisfactory. There are no concerns
about the legality or sustainability aspects of the four certification
schemes endorsed by CPET. At present, CPET assessment of the Malaysian
(MTCC) scheme confirms assurance of legality of supply, it is
hoped that this scheme can in due course offer assurance of both
legal and sustainable supply.
Is there sufficient information available to determine
where and how timber purchased by Government is sourced?
Whilst there is sufficient information available
from such sources as CPET and elsewhere in the supply chain, it
is questioned whether public sector procurement officers in central
Government Departments, local government and government agencies
are fully aware of the subject and the availability of independent
information. It is feared that many specifiers and users may not
be aware of the extent of the choice of certified products, especially
as at least one certification scheme (FSC) may have been promoted
in some quarters as being the only reliable scheme, which is patently
not the case. It is suggested that DEFRA/CPET could usefully promote
their findings more widely to ensure greater awareness.
Government procurement officials must ensure
value for money and ensure that the product or material purchased
is fit for purpose. We have seen examples of wholly inappropriate
specifications being issued, simply because a product has a certification
label but without due regard of its suitability; this is wasteful
and foolish in the extreme. In terms of timber procurement, the
specification of a single certification system, not only contravenes
public procurement rules, but also restricts choice and may reduce
value for money.
Is the use of certification schemes enough to
ensure that the timber requirements of the UK and EU countries
do not have detrimental impacts on forests and biodiversity in
developing countries? What other approaches should be used?
The use of independently verified certification
schemes provides the absolute assurance that the forests are being
managed in a sustainable manner, in accordance with standards
set by the certification schemes. All the major schemes are founded
on the absolute requirement that the production of wood from certified
forests does not have any adverse impact on the forest, indigenous
peoples, or the environment; this is the raison d'etre of forest
certification. Provided that credible certification schemes are
implemented and independently monitored, there is no requirement
for additional safeguards to be devised.
How satisfactory are the EU proposals for FLEGT?
Will they be stringent enough to have a significant impact?
The development of FLEGT represents a significant
development; it is perhaps too early to say whether it will have
a significant impact, but the hope is that it will, although we
aware of some criticism from imported timber interests. Close
monitoring and review of progress will be required to ensure maximum
effectiveness and benefit.
Should the social impacts of forestry be taken
into account within certification schemes? Would it be legal to
do so?
Social impacts are already an integral part
of the principal forest certification schemes encountered in the
UK. As sustainably managed forests provide social, environmental
and economic benefits, it is therefore right that certification
schemes should encompass social issues. Having said that, there
must be reasonableness and balance in the requirements if the
scheme is to be credible. As social aspects are already included
in the major schemes it would very unlikely that it is illegal
to do so, otherwise this matter would already have been challenged.
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?
As the trade association responsible for UK
produced timber interests, we are unable to comment comprehensively
on this matter and would recommend that comments be sought from
the Timber Trade Federation. However, from intelligence that we
receive, it would appear that such agreements have not had the
desired effect. It has also been suggested to us that there is
a significant trade in illegal timber from Indonesia to China
and thence to the World market. This is very disturbing. It is
encouraging to note that many reputable businesses in the UK have
ceased trading in wood and wood products from Indonesia because
of continued uncertainties about legality and sustainability.
It is suggested that urgent efforts must be focussed on the World
Trade Organisation to try and address this matter.
Does the inclusion of forestry projects in the
Clean Development Mechanisms within the Kyoto Protocol have any
implications for certification schemes?
We are unable to comment on this matter.
GENERAL COMMENTS
The forestry and forest products sector in the
UK has made significant progress in the field of sustainable forest
management and the implementation of chain of custody certification.
With the entire public sector forest estate (Forestry Commission
and Northern Ireland Forest Service) certified to the UK Woodland
Assurance Standard and FSC Standard and many major private sector
timber growers having also embraced certification, a very large
proportion of the UK forest resource is now independently certified
as producing legal and sustainable timber. However, the cost of
certification of forest management systems is expensive and this
presents a barrier for smaller owners of forests/woodlands, who
may not be regular suppliers of logs to the market. The development
of group certification schemes has assisted some, but there remains
concerns from some private sector woodland owners that certification
is too costly for occasional producers of wood.
With regard to the wood processing sector in
the UK (sawmillers etc) producers of sawn UK timber have invested
significant time, effort and money in implementing third party
chain of custody systems, but remain disappointed that demand
for certified wood and wood products still remains at a relatively
low level in the UK, although this is very slowly improving. It
is suggested that the Government could and should do more to ensure
the increased use of sustainably produced wood and wood products,
after all, wood is the only truly renewable construction material
and at the same time, well managed forests can provide economic,
social and environmental benefits indefinitely.
It is very important that timber specifiers
and users realise that they have a choice of sources certified
wood; CPET's review of five major certification schemes has already
confirmed the "legal and sustainable" credentials of
four schemes (CSA, FSC, PEFC, SFI).
There is a need for greater recognition of the
fact that for some developing countries that supply wood and wood
products to the UK may not have achieved certification of their
forests and woodlands yet, but this should not automatically deny
them access to the UK market, as they may have far more urgent
issues to address, such as famine, disease, debt, conflict etc.
Countries that are making genuine efforts towards forest certification
should receive some recognition of their efforts towards to the
objective of certification. A hierarchical approach to timber
procurement has been considered by CPET and is to be encouraged.
Of course, the material of choice should be certified wood where
appropriate products are available for specific end uses. However,
it must be recognised that not every certification scheme can
necessarily provide wood that is suitable for every end use in
the UK at present and until that time comes, then just because
a product does not have a certification label, should not lead
to its condemnation; as specialist timber suppliers can supply
detailed information about the sourcing of their products, which
in the absence of a certification label, may be sufficient to
assure specifiers and users of the credentials of the material
in question. Perhaps there could be a role for UK Government,
via DfID, to assist developing countries towards forest certification.
September 2005
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