EU’s Illegal Timber law demands a risk based approach
By: Rupert Oliver in Technical Information
The challenges faced by retailers in implementing the requirements of the EU’s new Illegal Timber Law (ITL) before the deadline of March 2013 are becoming increasingly apparent.
At the latest Chatham House Illegal Logging Update meeting in January, a representative of the UK’s John Lewis Partnership highlighted the practical problems faced by a company stocking upwards of 200,000 wood-based product lines to ensure that all these are from sources with “negligible risk” of illegal logging. Even the John Lewis Partnership that has engaged in green timber procurement efforts for the best part of a decade seems daunted by the challenge of achieving this in only two years.
The obvious answer to some people – notably amongst the environmentalist community – is that companies like John Lewis should simply demand that all their wood-based products be independently certified. But however desirable this may seem, the reality is that the neither FSC or the rival PEFC system will be in a position to certify any more than a minority of the total European trade in wood-based products for many years to come.
There is a massive deficit in human resources with capacity to certify forests and monitor chain of custody, and to control labels and claims, on that sort of scale. If too much emphasis is placed on supply of certified materials, the ITL will only create a new problem in the form of a huge increase in numbers of fake certificates. There also remains a heavy bias built in to certification frameworks in favour of larger vertically-integrated forestry enterprises at the expense of smaller family and community-owned forests. An approach based too heavily on certification would soon lead to effective market exclusion for the majority of wood from such ownerships.
To avoid such outcomes, retailers like John Lewis will have to adopt a more measured approach that builds on the ITL’s sensible risk-based provisions. This involves prioritising and demanding certification for those supply chains where there is a clear risk of illegal wood supply. In countries where there is evidence of good forest governance but high numbers of smaller companies and forest owners (like the US and many parts of Europe), the best approach would be for retailers to encourage wood suppliers to adopt risk-based wood procurement systems equivalent to their own.
Equally, trade associations representing companies exporting in the EU should now be looking at developing auditable due diligence procedures for their own members and on communicating these efforts to European retailers.
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