Footprints in the forest
Current
practice
and future
challenges
in forest
certification
Footprints in the forest
Current practice and future challenges in forest certification
1
FERN would like to thank the following organisations and individuals for providing valuable
comments on or contributions to this report. None of these organisations or individuals are, however,
responsible in any way for the analysis or opinions expressed in this report: American Forest & Paper
Association, American Lands Alliance, Australian Forestry Standard Ltd, Canadian Standards
Association, Friends of the Earth Chile, Forest Stewardship Council, IDEAL Malaysia, Malaysian
Timber Certification Council, Programme for the Endorsement of Forest Certification Schemes,
Sierra Club Canada, Taiga Consulting Sweden.
Thank you, also, to the following individuals: Tim Cadman, Mike Garforth, Celia Graham, Kate
Heaton NRDC, Sue Hulme, Leontien Krul, Chris Lang, Nina Grieshammer, Elisa Peter and Cristina
Timmer for providing valuable contributions to, or comments on the report.
FERN; 1C Fosseway Business Centre; Moreton in Marsh; Gloucestershire GL56 9NQ; UK
www.fern.org
Author: Saskia Ozinga, with the support of Leontien Krul
Editor: Eleanor Brunnen
Designer: Daan van Beek, Utrecht, the Netherlands
Printed on recycled paper by Drukkerij Zuidam & Uithof, Utrecht, the Netherlands
Cover pictures: The pristine forests of Perak, Malaysia (photo Carol Young); Lycopodium spec.
(photo Jonas Rudberg); Penola Forest (photo Online Edition Australian Science and Technology
Heritage Centre and Bureau of Meteorology 2001); Clearcutting and conversion of native forests to
plantations, Cumberland Plateau, Tennessee (photo Southwings Flight Survey); FSC Brasil, trees are
numbered (photo Jose Paulo Genari Tezza); Lower Eel clearcuts on Pacific Lumber Company Land
(photo Traci Thiele); Women going home from collecting bamboo from forests in Kg. Gerachi Jaya,
Selangor, Malaysia (photo Carol Young)
FERN promotes the conservation and sustainable use of forests, and respect for the rights of forest
peoples in the policies and practices of the European Union.
© February 2004
2
3
Contents
Foreword
5
Acronyms
7
1
The basics to understand the debate
9
The main elements of a certification scheme
9
Why all schemes appear the same but are not
9
It is all about the standards
10
Conclusion
11
2
Forestry is not a technical matter
13
The need for a credible and balanced
participation of all stakeholders
13
Conclusion
14
3
Internationally agreed norms for
certification schemes
15
Why are these not being followed?
15
Performance on the ground
15
Transparency, participation and access
15
Conclusion
17
4
Assessment of eight different schemes
19
Summary of findings
19
Canadian Standardâs Association (CSA)
20
Forest Stewardship Council (FSC)
21
Programme for the Endorsement of Forest
Certification (PEFC), formerly the Pan
European Forest Certification scheme
22
Sustainable Forestry Initiative (SFI)
23
Australian Forestry Standard (AFS)
24
Sistema Brazileiro de Certificação Florestal
(CERFLOR)
25
CertificaciĂłn Forestal (Certfor)
26
Malaysian Timber Certification Council (MTCC)
26
Comparison
28
5
Is certification possible under WTO rules?
31
Conclusion
32
6
Relevant developments in the debate
33
Mutual recognition
33
Step-wise approach
33
Illegal logging
34
7
Executive summary
37
Eight Forest Certification Case Studies
41
Canadian Standards Association Standard (CSA)
42
1 History and characteristics
2 Quality of the standard
3 Standard-setting procedures
4 Certification process
5 Transparency
6 Label protection and chain of custody
Forest Stewardship Council (FSC)
46
1 History and characteristics
2 Quality of the standard
3 Standard-setting procedures
4 Certification process
5 Transparency
6 Label protection and chain of custody
Programme for the Endorsement of Forest
Certification Schemes (PEFC)
50
1 History and characteristics
2 Quality of the standard
3 Standard-setting procedures
4 Certification process
5 Transparency
6 Label protection and chain of custody
Sustainable Forestry and Initiative (SFI)
54
1 History and characteristics
2 Quality of the standard
3 Standard-setting procedures
4 Certification process
5 Transparency
6 Label protection and chain of custody
The Australian Forestry Standard (AFS)
58
1 History and characteristics
2 Quality of the standard
3 Standard-setting procedures
4 Certification process
5 Transparency
6 Label protection and chain of custody
Sistema Brazileiro de Certificação Florestal (CERFLOR) 62
1 History and characteristics
2 Quality of the standard
3 Standard-setting procedures
4 Certification process
5 Transparency
6 Label protection and chain of custody
CertificaciĂłn Forestal en Chile (Certfor)
65
1 History and characteristics
2 Quality of the standard
3 Standards setting procedures
4 Certification process
5 Transparency
6 Label protection and chain of custody
Malaysian Timber Certification Council (MTCC)
69
1 History and characteristics
2 Quality of the standard
3 Standard-setting procedures
4 Certification process
5 Transparency
6 Label protection and chain of custody
Endnotes
74
4
Foreword
Forest certification is at a crossroads. Awarding a seal of approval to forestry operations that
implement good forest management practices is facing challenges that were not thought of
when the concept was conceived ten years ago. Today, however, these challenges threaten to
undermine the credibility of certification as a tool for raising the standard of forest
management.
When the idea of certification was conceived, many environmental NGOs and some social
NGOs hoped that certification would improve forest management practices. Some also
hoped it would contribute to improving workersâ conditions and solving the land rights
problems that are so prevalent in many countries in the South and North. Today, it may be
too early to be sure of the impacts of forest certification, as the concept is still evolving, but
a few conclusions can be drawn from the evidence that is available.
Certification has led to an increase in demand for timber products from well-managed
sources from retailers and consumers. Certification has slightly improved forest
management practices mainly in the North, and working conditions mainly in the South.
Certification has also highlighted the land rights problems, but not contributed to solving
them. Finally, certification has increased understanding of what constitutes good forest
management â a procedure that needs to be developed jointly by economic, social and
environmental interest groups.
But there are down sides. Certification has, unfortunately, given its âseal of approvalâ to
many companies and forests that have not earned it. As this report shows, the majority of
existing certification schemes certify the current status quo of forest management, which in
most cases does not earn the label âfrom well managed forestsâ. In the worst cases, timber
certified as âcoming from well managed forestsâ originates from old growth forests, forests
under dispute over land rights, or forests that have been converted to GMO tree
plantations. The fact that certified timber can originate from these types of forests has
clearly devalued the concept of certification.
Furthermore, in regions where large areas of forests have been certified, and large volumes
of certified products are on the shelves, such as in Europe, certification is often perceived as
a solution to the forest crisis. Such perception makes it more difficult for NGOs to create
awareness about the many problems that still exist in forest management. Issues such
as reform of forest laws, controlling trade and investment flows and reduction of
consumption of forest products donât always get the attention they need.
FERN believes that certification can only have a positive impact at grass roots level, if it can
harness the market power of consumers â and their concerns about forests â to change the
balance of power. If certification schemes become too closely linked to the forestry
industry, there is little chance they will contribute to a better balance of power.
Unfortunately, as this report shows, in most cases forest certification schemes are currently
too closely linked to the forestry sector, and are therefore reinforcing the status quo of
forest management rather than improving it. There is widespread failure to recognise the
rights of forest-dependent people to participate in decision-making.
Canada
Photo Ian McAllister
Footprints in the forest
Foreword
5
The intellectual argument for certification has been won and the concept of certification
has entered the mainstream. Yet, a serious problem remains, namely, the translation of the
concept of certification into real improvements. The task, therefore, is to uphold the
integrity and credibility of forest certification in the face of intense market pressure for
certified products.
To rescue the credibility of certification and to solve the worldâs forest crisis, it is time to re-
assess. The demand for certified wood, created by buyers-groups, the World Bank, and
others cannot be met in the short term. There is not enough well managed forest on the
planet. As credible certification schemes cannot meet this demand in the short term, simply
satisfying this demand could enforce certification schemes with low or no minimum
standards. We will not solve, but rather aggravate the forest crisis if we continue racing to
meet this demand through certification of near status quo forest management practices.
This report assesses the key strengths and weaknesses of eight certification schemes
currently in operation. It is based on eight case studies describing the procedures of these
eight schemes. Detailed summaries of these case studies are available on page 41 of this
report. The full reports are available at www.fern.org.
Forest certification, however, can only reach its potential if all schemes continue to improve
procedures and practices and implement more rigorous standards, such as those embodied
by the Forest Stewardship Council (FSC). Forest certification schemes that lack an
acceptable and clearly defined minimum threshold of forest management, do not deserve
a consumer label. Unfortunately, this is the case with most existing schemes.
Last, it should be recognised that without addressing the underlying causes of forest loss,
certification can only contribute to better forest management within a limited number of
countries. Demands for reform of forest laws, reduction of consumption of forest products,
and for controlling sources of investment, to name just a few issues, are as crucial to address
the forest crisis.
Saskia Ozinga
February 2004
Footprints in the forest
Foreword
6
Acronyms
ABTN
Association of Technical Norms, Brazil
AFG
Australian Forest Growers
AF&PA
American Forest & Paper Association
AFS
Australian Forestry Standard
BVQI
Bureau Veritas Quality International
CAR
Corrective Action Request
CBD
Convention on Biological Diversity
CERFLOR
Sistema Brazileiro de Certificação Florestal
Certfor
CertificaciĂłn Forestal (en Chile)
CoC
Chain of custody
CONMETRO The National Council of Metrology, Normalisation and Industrial Quality.
CORFO
Development and Innovation Fund of the Industrial Promotion Agency
CORMA
Chilean Wood Manufacturer Association
CSA
Canadian Standards Association
CTE
Committee on Trade and Environment
FAO
UN Food and Agriculture Organisation
FMU
Forest Management Unit
FSC
Forest Stewardship Council
GMO
Genetically Modified Organism
INFOR
Instituto Florestal de Chile
INMETRO
National Institute of Metrology, Normalisation and Industrial Quality, Brazil.
INPACEL
Industria de Papel Arapoti
INN
Chilean State Instituto Nacional de Normalisation
ITTO
International Tropical Timber Organisation
IFIR
International Forestry Industry Roundtable
IPF
Intergovernmental Panel on Forests
ILO
International Labour Organisation
ISO
International Organisation for Standardisation
MC&I
Malaysia Criteria and Indicators
MDIC
Ministry of Development, Industry and Trade, Brazil
MTCC
Malaysian Timber Certification Council
NAFI
National Association of Forest Industries, Australia
NGO
Non Governmental Organisation
OECD
Organisation for Economic Cooperation and Development
PEFC
Programme for the Endorsement of Forest Certification
PEOLG
Pan European Operational Level Guidelines
PPM
Process and Production Method
PTAA
Plantation Timber Association of Australia
SFB
Sustainable Forestry Board
SFI
Sustainable Forestry Initiative
SFM
Sustainable Forest Management
SGS
Société Generale de Surveillance
SPS
Sanitary and Phytosanitary Agreement
TBT
Technical Barriers to Trade
UNFF
United Nations Forum on Forests
WTO
World Trade Organisation
Footprints in the forest
Acronyms
7
8
The basics to understand the debate
The main elements of a certification scheme
1
All certification schemes are made up of three elements:
Standards â These are documents that set out the forest management requirements which
must be met by the forest manager and against which certification assessments are made.
Certification â This is the process of establishing whether or not a standard has been met.
Accreditation â This is the mechanism for ensuring that the organisations that undertake
certification (known as certifiers or certification bodies) are competent and can produce
credible results. This process âcertifies the certifiersâ.
A fourth element is needed if a scheme is to be used as a basis for making a product claim.
In this case, a system for tracing and labelling to guarantee that a product comes from a
certified forest is needed to ensure that claims are clear and credible. This consists of:
Labelling rules â Once a forest is certified, the forest owner obtains the right to label
products from that forest with a name and/or logo of the certification scheme. The certifi-
cation scheme will have to establish a set of labelling rules, specifying the conditions under
which labels can be used.
Chain of custody â There is a long and often complicated path from the forest to the point
of sale: the product supply chain. To be able to guarantee the consumer that a particular
product comes from a well-managed forest, this supply chain needs to be certified as well.
The ownership and control aspect of the product supply chain is referred to as the âchain of
custodyâ.
Why all schemes appear the same but are not
All eight forest certification schemes examined in this report are based on the four elements
listed above to varying degrees. Therefore at first glance all the schemes look similar. But
when the design of the components, which together form an element, differs â as it does â
what is actually delivered will be different as well. It is only by looking at the detail of how
these components are required to be implemented that one can fully understand the
differences between each scheme. For example, âconsultationâ is often a component of the
standard-setting process, and sometimes also a component of the certification process. A
simple comparison of two schemes seeking to assess consultation as part of the certification
process may not, however, reveal differences between:
Scheme A â which requires certification bodies to contact the forest departments and the
local state government to inform them that the certification assessment is under way, and
seek further comments, and
Scheme B â which requires certification bodies to inform a range of local and national
organisations, including governments, academics, industry, NGOs and community groups,
and to hold a series of public meetings to allow anyone interested to have an input.
While both approaches are called âconsultationâ, it is clear that they will deliver very
different outcomes in terms of the objectives they meet. Failure to differentiate between
1
Footprints in the forest
The basics to understand the debate
9
Amazon
Photo: Paolo Genari Tezza
them arises from a lack of precision in defining exactly what the requirements are for the
consultation component. The difference is in the detail. For this reason, even though the
general framework of certification schemes may appear similar, they cannot be readily
compared without analysing their specific components and requirements.
This report examines a number of specific components in detail to understand what the
eight schemes investigated can, and cannot deliver. The questions we ask are:
â Does the standard define the level of forest management that needs to be achieved?
â Who is involved in the standard-setting process?
â What does the certification process entail: field visit or just checking documents and
plans in an office?
â Is the scheme sufficiently transparent?
â Does the scheme provide a consumer label that is honest and trustworthy?
It is all about standards
Of the five questions listed above, the first is the most fundamental. It is also the least
understood. Standards provide the basis for quality in any certification scheme, and all
product claims refer back to the standards. For a forest certification scheme, the standards
define the level of forest management practice that must be achieved. There are two
different types of standards: system standards and performance standards.
System standards
System standards specify the management systems that must be in place within an organi-
sation to ensure it is managing quality and environmental and social performance consis-
tently. System standards can be very powerful tools for helping organisations understand
and improve their performance. However, they do not specify any minimum level of
performance that must be achieved. Instead, they require forest management organisations
to set their own performance targets and to use the management system to ensure they are
reached. For example, a system standard might require pesticide use to be reduced over a
set period of time, or for biodiversity to be monitored. These standards do not limit the
amount of pesticide use that is acceptable or how much biodiversity loss is unacceptable;
they simply require a monitoring system to be in place. The lack of defined performance
requirements means that two forest companies both certified to the same system standard
could achieve very different results in the forest. As a result, system standards do not
provide any guarantee of product quality. Therefore, it is not appropriate to associate a
product label with this type of standard.
Performance standards
Performance standards specify the level of performance or results that must be achieved in
a forest. Since performance standards provide a guarantee of quality, it is appropriate to use
them for product labels. For example, a performance standard might require 10% of a
forest management unit (FMU) to be set aside for conservation, or for no GMO trees to be
used, or for no certification to take place on land where ownership is disputed.
Performance and system standards are both valuable, but each delivers totally different
benefits and cannot be considered equivalent. Things are not black and white either:
Footprints in the forest
The basics to understand the debate
10
performance standards sometimes contain system elements and system standards
sometimes include performance elements.
Conclusion
Despite the discrepancy that a forest certification scheme that is not based on minimum
performance standards is unsuitable for a labelled product, most certification schemes
researched in this report have standards that mainly consist of system-based elements. They
do not have clear minimum performance thresholds for forest management. Such schemes
include MTCC, CERFLOR, SFI, CSA, AFS, Certfor, and most European PEFC schemes. By
contrast, the FSC national standards are all performance-based.
Furthermore, some standards (SFI and CSA) allow an individual forestry company to
customise the standard against which it will be certified. This means that the standard of
these schemes varries on a case-by-case basis, rather than being applied in a consistent and
replicable manner.
Certification schemes that emphasise system-based standards may have a role to play in
improving forest management, but they do not offer clear assurance to consumers about
the level of performance delivered under the standard. Therefore they cannot, and should
not, be linked to a product label for consumers. A system-based standard alone may lead to
better forest management, but it gives no information to the consumer on what standard it
is able to deliver.
An international agreement defining requirements for system standards, with ISO 14001 as
a working model, exists. For a performance-based forest management standard the require-
ments are less clear. There are three main reasons for this: First, from a scientific perspective
there is no clear definition of âsustainableâ forest management. Second, forest standards
have to deal with a high degree of variability between forests across the globe. Third, and
most importantly, defining sustainability is complicated by the need to balance conflicting
social, environmental and economic demands. For these reasons, defining sustainable
forest management performance thresholds is not just a technical matter but a social and
political matter as well.
Footprints in the forest
The basics to understand the debate
11
12
Forestry is not a technical matter
The need for credible and balanced participation of all stakeholders
What is sustainable forest management? This is the question at the heart of the certification
debate. There is universal agreement that sustainable forest management is about more
than sustained yield of timber supplies: it includes all forest values â social, environmental,
economic, cultural and spiritual. But what does this mean in practice? Forest users
including local communities and indigenous peoples, government management agencies,
environmental NGOs, logging companies and timber concessionaires all have diverse, and
often conflicting, interests in how forests are managed.
Each of these groups â and the individuals who represent them â is also rooted within a
variety of cultures that influence the ways they view and interact with a forest. Forests are
often sites where social and political conflicts are played out; these conflicts frequently
derive from conflict over access to the forest, and the formal and informal means by which
people gain that access.
2
Deciding, therefore, what practices qualify as âgoodâ or âsustainableâ forest management is
complex and controversial, with no objective or simple answer. From a scientific
perspective there are no clear data to tell us the exact environmental and social impacts of
certain forest management practices over time. From a sustainable development
perspective, good forest management should be a compromise between ecological, social
and economic interests. Yet, a certification standard defining âsustainableâ forest manage-
ment, will vary greatly according to the interests, the background, values and experience of
the people who define the standard.
Standard-setting for forest management, therefore, involves value judgements that differ
depending on a personâs perspective. This is quite unlike setting standards for motor crash
helmets, light bulbs, and so on. As Markku Simula and Ewald Rametsteiner say:
âThe crux of the international debate centres on credibility for certification schemes and
more deeply about who should define forest management standards and how this takes
placeâ.
3
It is a debate which should be considered in the wider context of forest management. For
too long, forest management has been defined as providing a sustainable yield of timber
with consideration given to some environmental aspects. Yet, forest management should
start with developing a countrywide (or regionwide), broadly supported view of the future
of a countryâs forests â developing a vision. This is the first step towards achieving
sustainable forest management, and is, in essence, a political act. The first and foremost
principle of sustainable forest management, therefore, must be the development of a vision
of what can be considered sustainable forest management in a particular country or region.
This vision needs to be developed with the full participation of all stakeholders and,
particularly, the local people who own or use the forest.
2
Footprints in the forest
Forestry is not a technical matter
13
FSC certified
plantation in Mexico
Photo: Juan Carlos Reyes Garcia
Although one can define general principles of sustainable forest management, how these
principles should be implemented depends on national or regional circumstances.
Developing a certification standard, which is used to certify a forest, is a political process
and should be done with the full participation of all stakeholders in that region or area. No
interest group should be able to dominate the process of developing a certification
standard. To reach consensus on what sustainable forest management consists of in a
particular region requires care and attention; developing a credible national or regional
certification standard, therefore, takes time. Certification is not a quick fix. In countries
where there is no capacity of local stakeholders to participate effectively in the national (or
regional) standard-setting process, capacity building should be a first step. In countries
where some local or national stakeholders cannot freely participate in the development of
a standard, certification is not viable.
Six of the forest certification schemes examined in this report â SFI, PEFC, MTTC,
CERFLOR, AFS and Certfor â are based on national forest standards, but lack the basic
principle emphasised here that a forest certification standard can only be developed with
the full participation of all stakeholders. In each of these certification schemes, forestry
industry interests have dominated the standard-setting process. In the case of CSA the
national standard-setting process was not unbalanced, but the development of the actual
standard used for certification (i.e. the indicators and targets against which performance is
measured) could be dominated by the forestry sector.
In contrast, the FSC does demand equal participation of ecological, social and economic
interests in the standard-setting process. It is, therefore, a clear step ahead. In many
countries, however, FSC certification has proceeded using generic standards developed by
certification bodies based on the FSC Principles and Criteria. In some countries, such as
Indonesia, Thailand and Malaysia, where stakeholder consensus on national standards has
not been secured, such certifications have been criticised for undermining local and
national calls for forestry reform.
A recent case study looking at forest certification in Indonesia concluded that the social
acceptability of certification depends on the quality of the participation in decisions such
as agreeing national standards, carrying out assessments and dealing with complaints. In
Indonesia, for a variety of reasons, participation at all these levels has been poor and as a
result certification decisions have generated disputes rather than led to improved forest
management.
4
Conclusion
Forest certification is most likely to succeed in countries where the certification standard
has been developed with the balanced participation of representatives of different sectors,
involving social, environmental and economic interests. Forest certification in the absence
of national standards is problematic, and should only occur with utmost caution. Forest
certification is problematic where there is no capacity or possibility for stakeholders to
freely and fully participate in the standard-setting process. Certification schemes should,
therefore, refrain from certification in countries where complex social political settings
make it impossible for all groups of civil society to actively participate in standard-setting
processes. Too much emphasis is put on certification as a quick fix for failing forest regimes.
Footprints in the forest
Forestry is not a technical matter
14
Internationally agreed norms for
certification schemes
Why are these not being followed?
Certification is envisioned as a non-governmental and non-regulatory market tool.
Nonetheless, governments have been involved in assessing parameters for credible forest
management and for credible forest certification schemes. Some governments, notably
Australia, Brazil Canada, Chile, and Malaysia have played an active role in establishing
national certification schemes.
Governments, industry and NGOs seem to agree on the key components of a credible certi-
fication scheme. This section outlines the major agreements and statements that have been
made by governments that help us define credible forest certification schemes. Some
contradictions have, however, emerged between theory and practice. Several of the certifi-
cation schemes examined in this report do not reflect the specific requirements â for
standards development, consultation and transparency â laid down by e.g. the United
Nations (UN), the European Union (EU) and the World Trade Organisation (WTO).
Performance on the ground
The first intergovernmental agreement on forest certification was reached within the UN
Intergovernmental Panel on Forests (IPF). In 1997 the IPF adopted a number of Proposals
for Action relating to certification.
5
The Panel made a clear distinction between criteria and
indicators to monitor forest management developed through governmental processes such
as the Helsinki and Montreal processes â see box page 16 â and developing criteria and
indicators that are suitable for use in standards for forest certification. The panel
emphasised:
â[âŠ] the development of criteria and indicators [through governmental processes such
as the Helsinki and Montreal processes] is primarily intended for promoting and
monitoring sustainable forest management, and not for imposing certification schemes
for forest products⊠[These] criteria and indicators are not performance standards for
certifying management at any levelâ.
The message that certification schemes need to be based on performance requirements has
since been repeated in different forums, such as the FAO â see box page 16. Nonetheless, as
outlined in chapters 1 and 4, many certification schemes are either partially or not at all
founded on performance-based standards.
Transparency, participation and access
The IPF Proposals for Action, agreed by all governments, state:
3
Footprints in the forest
Internationally agreed norms for certification schemes
15
âGovernments have a role in encouraging transparency, the full participation of
interested parties; non-discrimination and open access to voluntary certification
schemes.â
6
The Proposal For Action 133, relating to certification and labelling, reads:
ââŠ[the panel] urged countries to support the application to certification schemes of such
concepts as: open access and non-discrimination in respect of all types of forests, forest
owners, mangers and operators; credibility;
7
non-deceptiveness; cost-effectiveness; partic-
ipation that seeks to involve all interested parties including local communities;
sustainable forest management and transparency.â
The International Forestry Industry Roundtable (IFIR) supports this approach in its report
Proposing an international mutual recognition framework. It lists the following criteria for
credible certification schemes: conformity with sustainable forest management standards
and legislation; the influence of all stakeholders shall be balanced and consensus outcomes
Footprints in the forest
Internationally agreed norms for certification schemes
16
Governmental processes
Many governments have worked towards a
common understanding of the concept of
Sustainable Forest Management (SFM) in line
with the Forest Principles agreed at the Rio Earth
Summit of 1992, through the development of
common criteria. They have also agreed on a
number of indicators by which âsustainabilityâ
can be assessed, monitored and reported. This
has resulted in nine international processes
8
,
including the Pan European Process that
developed the Helsinki Criteria and Indicators,
and the Montreal Process that developed the
Montreal Criteria and Indicators.
These criteria and indicators were developed
primarily for identifying the basic parameters
(e.g., water quality and biodiversity impacts) that
need to be monitored and reported at the
national level. They were not intended to assess
the performance of forest management at the
level of the forest management unit (FMU). They
are, therefore, poorly adapted for certification. As
stated by the FAOâs Committee on Forestry these
criteria and indicators âare neutral assessment
tools for monitoring trends and⊠therefore
cannot be used as substitutes for minimum
agreed-upon forest management standards which
underpin certificationâ
9
The European Union
supported this viewpoint when it stated that, âit
is important to recognise the differences between
indicators for sustainable forest management and
certification standards. While indicators are used
to show the state of the art and to monitor
changes with regard to relevant aspects of
sustainable forest management (as defined by
criteria), certification standards lay down a
certain quality level or performance standards
that has to be achievedâ.
10
Nonetheless, CERFLOR, AFS, PEFC and CSA use
these governmental processes, and the criteria
derived from them, as a basis for standard
development. This is problematic; to assess
whether a forest deserves a certificate as âwell
managedâ requires the definition of clear
minimum thresholds before the forest can be
assessed. Yet, these criteria and indicators were
developed primarily for identifying what forest
conditions need to be monitored, and reported at
the national level. They were not intended to set
thresholds of performance needed to assess the
forest management at the level of the FMU. They
are, therefore, poorly adapted for certification.
shall be sought; scientifically supported; continual improvement; non-discriminatory
âaccommodating all forest types, sizes and ownership structuresâ; repeatability, reliability
and consistency; independence and competence; transparency (âprocedures and documen-
tation shall be clear, concise and readily availableâ); SFM claims (âall SFM claims are clear,
unambiguous and substantiatedâ); chain of custody.
11
The Committee on Trade and Environment (CTE) of the World Trade Organisation has
produced a âstatus quoâ report for the Cancun Ministerial meeting.
12
This report states:
ââŠvoluntary, participatory, market-based and transparent environmental labelling
schemes are potentially efficient, economic instruments in order to inform consumers
about environmentally friendly products.â
Finally, the World Bank, when adopting its new Forest Policy in November 2002 states that:
âTo be acceptable to the Bank, a forest certification system must require:
a compliance with relevant laws;
b recognition of and respect for any legally documented or customary land tenure and
use rights as well as the rights of indigenous peoples and workers;
c
measures to maintain or enhance sound and effective community relations;
d conservation of biological diversity and ecological functions;
e
measures to maintain or enhance environmentally sound multiple benefits accruing
from the forest;
f
prevention or minimization of the adverse environmental impacts from forest use;
g
effective forest management planning;
h active monitoring and assessment of relevant forest management areas;
i
the maintenance of critical forest areas and other critical natural habitats affected by
the operation.
âIn addition to the requirements above a forest certification system must be independent,
cost-effective, and based on objective and measurable performance standards that are
defined at the national level and are compatible with internationally accepted principles
and criteria of sustainable forest management. The system must require independent,
third-party assessment of forest management performance. In addition, the systemâs
standards must be developed with the meaningful participation of local people and
communities; indigenous peoples; non-governmental organisations representing
consumer, producer, and conservation interests; and other members of civil society,
including the private sector. The decision-making procedures of the certification system
must be fair, transparent, independent, and designed to avoid conflicts of interestâ.
13
Conclusion
In short, the World Bank, governments and forestry industry all seem to agree on most of
the conditions for credible certification schemes such as balanced participation, trans-
parency, consistency and measurable minimum performance-based standards. Most of the
certification schemes researched here, however, do not meet these demands. This report
will show that no schemes, with the exception of the FSC, and arguably the CSA
14
, require
Footprints in the forest
Internationally agreed norms for certification schemes
17
balanced participation of all stakeholders and no schemes, with the exception of the FSC,
are based on clear and meaningful minimum performance standards. The SFI and CSA
allow individual forestry companies to customise the standards against which they will be
certified. This means that the standards of these programmes vary on a case-by-case basis.
Transparency is a serious problem in most schemes. CERFLOR does not have a certification
standard that is freely available â it needs to be purchased. Until this report went to print,
this was also the case for AFS. Summary reports of audits are only readily and routinely
available with the FSC, CSA, the MTCC, and some national PEFC schemes. Finally,
the World Bank clearly states that certification schemes must be designed to avoid conflict
of interests; this demand is violated by AFS, PEFC, CERFLOR, Certfor and SFI, as the
decision-making structure is clearly dominated by the forestry sector.
Footprints in the forest
Internationally agreed norms for certification schemes
18
Assessment of eight different schemes
Summary of findings
This chapter assesses eight forest certification schemes currently in operation, and updates
FERNâs 2001 report Behind the Logo: An environmental and social assessment of forest
certification schemes. Five of these schemes are national schemes (Brazil, Malaysia,
Chile, Canada and Australia), and a sixth is the US-based SFI scheme, which certifies in
the US and in Canada. The remaining two, the PEFC and the FSC, are different animals
as they are programmes that endorse national certification schemes. The PEFC has
endorsed 13 national European schemes and the FSC operates at a global level and has
endorsed 17 national and regional schemes. The FSC, however, also allows for certification
in the absence of national standards, where the certification body has to develop an interim
standard based on the FSCâs global Principles and Criteria. The PEFC is about to endorse
schemes outside of Europe, and is expected to endorse most, if not all, of the national
schemes listed above.
Below follows a assessments of the eight certification schemes. A detailed description of
these eight schemes can be found in this report pages 41-73. Full reports on which these
summaries are based can be accessed at www.fern.org.
The following assessments focus on what the most important elements are of a certification
scheme by asking the following questions:
â Does the standard define the level of forest management that needs to be achieved?
â Who is involved in the standard-setting process?
â What does the certification process entail: field visits, or just checking documents and
plans?
â Is the scheme sufficiently transparent?
â Does the scheme provide a consumer label that is honest and trustworthy?
Other indicators looked at include monitoring requirements, complaints mechanisms and
whether the scheme certifies at regional or forest management unit level.
Key points
In 2001, only four schemes â FSC, PEFC, SFI and CSA â were considered sufficiently well
developed to warrant detailed investigation in FERNâs report Behind the Logo. Here, these
four well-established schemes are re-examined, and a further four schemes â CERFLOR,
Certfor, AFS and MTCC â are investigated.
4
Footprints in the forest
Assessment of eight different schemes
19
Women going home
from collecting
bamboo from the
nearby forests in Kg.
Gerachi Jaya,
Selangor a resettled
Orang Asli village
Photo: Carol Young
The âoldâ schemes
Canadian Standardâs Association (CSA)
The area certified by CSA has increased from 4,215,000 hectares in May 2001 to 28.4
million hectares in January 2004. The Canadian CSA standard has been revised and now
includes some performance requirements related to forest management. The main good
point about the CSA scheme is a well described public participation process in developing
the local standards (or âtargetsâ) used for the certification of a particular forest management
unit. Furthermore, the CSAâs chain of custody requirements are arguably the most stringent
of all the schemes.
The main problem is that the CSA allows applicant companies to control the development
of the local certification standard (i.e. the indicators and targets against which performance
is measured) used for their own audit â although with broad stakeholder input. Also, since
the performance thresholds are written by each individual applicant on a case-by-case
basis, the CSA does not measure performance against consistent, independently established
benchmarks. This practice allows CSA to award certification to a wide range of forestry
performance. On the other hand positive aspects of the scheme relate to transparency: the
standard and summary reports are freely available. CSA is the Canadian member of the
PEFC Council, presumably with the aim of having its standard endorsed by the PEFC.
Main positive points
â The revised CSA standard does include (some) minimum performance requirements.
â CSA has developed a well described participation process; each certification includes
broad stakeholder participation and consultation.
â The CSA has a very well developed chain of custody system.
Main negative points
â Companies can develop their own certification standard on a case-by-case basis,
thereby not presenting a consistent minimum standard.
â Although local stakeholder processes are well defined they are nevertheless under the
control of the company and their scope is so broad that they may or may not be effective
in truly improving forest management.
â Insufficient procedures for addressing the rights and interests of Indigenous Peoples.
Conclusion
The CSA standard can provide an effective tool to improve relations between the company
and local people. However, the fact that there is no meaningful minimum performance
threshold and that companies can influence the local certification standard (i.e. the
indicators and targets against which performance is measured) used for their audit are
problematic for a scheme that wants to deliver a product label. Broad stakeholder consul-
tation is a good thing, but allowing companies to set their own standards on a case-by-case
basis is not. A standard that does not result in standardised levels of performance is not a
true performance standard. Therefore until the CSA has developed a clear minimum
threshold a product label is not really suitable.
Footprints in the forest
Assessment of eight different schemes
20
Forest Stewardship Council (FSC)
When FERN published its original comparison of forest certification schemes in 2001, the
FSC emerged as the only scheme credible to NGOs. Since then, the area certified by FSC has
increased from 22,165,741 hectares in May 2001, to 40,422,684 hectares in January 2004.
The FSC remains the only scheme that demands a truly performance-based minimum
threshold for forest management practices before a national standard can be endorsed. Its
standard-setting process is not unduly influenced by the forestry sector. Its certification and
accreditation procedures are well defined and thorough in formulation. The scheme is
transparent: standards, procedures and summary reports of the certifications are all
available. The standard does not allow for forest conversion, use of GMO trees, and
includes protection measure for high conservation value forests. Since its conception, the
FSC has both benefited from broad NGO support and received the most NGO scrutiny.
This has led to NGOs reporting that FSC procedures are not always implemented, as they
should be â particularly in those countries where there is no national standard. The consul-
tation processes have not been satisfactory in a number of cases. The ongoing FSC certifi-
cation of large-scale plantations has also raised many concerns and prompted FSC to
undertake a review of its Principle 10 dealing with plantations.
Main positive points
â Balanced participation of economic, social and environmental interests in decision-
making at all levels, including in the development of the standards.
â Thorough and well formulated procedures.
â A credible performance-based standards that qualifies for a consumer label: FSC
certified forests prohibit the clearing of natural forests for replacement by plantations,
exclude the use of GMO trees, includes the protection of high conservation value forests
and afford the clear recognition of Indigenous Peoplesâ rights.
Main negative points
â Certification in absence of national standards is problematic (see chapter 2). Phasing
out of certifiers standards as soon as possible is required.
â Consultation processes are not always implemented as required on paper. Clear
improvement is needed to ensure adequate consultation processes are carried out.
â Current certification of large-scale industrial tree plantations has led to undermining of
local and national campaigns in a number of countries. A revision of Principle 10,
dealing with plantations, is urgently needed.
Conclusion
FSC remains by far the most independent, rigorous and, therefore, credible certification
system. Its national standards are performance-based and their development requires full
participation of all interest groups. The FSCâs baseline prohibits the conversion of forests
to plantations. GMO trees are explicitly excluded and the standard includes forest
protection measures. FSC is also most advanced in recognition of forest peoplesâ rights. It
rightfully uses a consumer label. For the FSC to retain the confidence of the environmental
and social movement for the future, however, it needs to enforce stricter implementation of
its procedures and seriously address the problems associated with the certification of
plantations.
Footprints in the forest
Assessment of eight different schemes
21
Programme for the Endorsement of Forest Certification (PEFC),
formerly the Pan European Forest Certification scheme
The area certified under the PEFC has increased from 32,370,000 ha in May 2001, to 48.6
million ha in January 2004. Although the PEFC has improved in some aspects since our last
assessment, it has not yet changed the fundamentals of the system by embracing equal
participation of different stakeholder groups. It still gives the forestry industry and forest
owners dominance in the development of the programme and in the development of the
standards. It is, therefore, not an independent scheme.
Arguably, the PEFC is the most difficult scheme to assess properly because of the large
variations between the national schemes. It is a great weakness of the PEFC scheme that the
threshold for endorsement is so low, that most certification schemes can qualify. The PEFC
umbrella, therefore, includes certification schemes such as PEFC Sweden, which certifies at
FMU level and has clear minimum performance standards â even though they are seen as
insufficient by environmental NGOs and Indigenous Peoples. The PEFC umbrella also
includes PEFC France, which has no clear minimum performance standards, does not
certify at FMU level and does not require any field visits. This does not bode well for the
forests certified by tropical certification schemes that now want to accede to the PEFC.
Transparency is a problem as summaries of certification reports are in most cases not
available. The certification process itself is also limited, as field visits are not in all cases
required.
Although there are reports that in some countries, such as Finland, the national standard
has slipped backwards, in other countries, such as Sweden, standards have improved. The
adoption of the core ILO standards
15
is a clear recognition of the importance of the social
issue. However, the PEFCâs failure to give full recognition to the land rights of local people
is a serious omission, as is its lack of a requirement for proper consultation with local stake-
holders during the certification process. This is particularly relevant as the PEFC is about
to endorse non-European schemes in countries where the discussion about land rights and
reform of forestry laws holds the key to improved forest management. Without recognising
this issue, the PEFC seriously risks coming under attack from a wide range of social and
environmental organisations in these countries as well as in the North.
Main positive points
â Inclusion of core ILO standards as a requirement for all certification schemes under the
PEFC umbrella.
â Increased transparency in some member countries, notably in Sweden and Germany by
(planning to) publish summary reports of certifications.
â A revision of the national standards is required every 5 years.
Main negative points
â The variability of PEFCâs standards leads to a serious lack of consistency in what the
PEFC delivers and stands for, making it inappropriate for a consumer label.
â The scheme, as well as the development of standards, is governed by forest owners and
the forestry industry; the independence of the schemes is, therefore, questionable.
â The programme does not require certification at FMU level; most PEFC endorsed
schemes certify at regional level.
Footprints in the forest
Assessment of eight different schemes
22
Conclusion
Given the variability in the national programmes admitted, the PEFC does not represent a
consistent and credible performance-based standard for forest certification. It is, therefore,
not suitable for a product label. Lack of participation of other stakeholder groups in
standard-setting procedures and lack of transparency are also problematic. Although PEFC
seems to be trying to improve its procedures and over time, hopefully, its standards, it
remains to be seen whether this process will continue if it starts endorsing many of the less
credible schemes outside Europe.
Sustainable Forestry Initiative (SFI)
The area certified under the SFI has grown from 11.336.032 ha in May 2001, to 30.319.476
ha in July 2003. Unfortunately, this large increase is linked to certification of near status quo
practices, as allowed under the SFI standard. The SFI is probably one of the least credible
of all schemes researched. There is no chain of custody â although they have adopted a
weak policy on wood procurement â and no recognition of social issues. Although SFI has
a set of core indicators that each company is expected to address, individual companies can
customise the standards to assess them with optional indicators that they may write
themselves, thus undermining the consistent application of SFI certification across
companies. Few of the SFIâs mandatory performance measures and indicators require
companies to produce specific on-the-ground outcomes. This open-ended nature of the
SFI standards also calls into question the consistency of SFI certification across companies.
The SFI is, in essence, a certification scheme by the forestry industry for the forestry
industry. Although the American Forest & Paper Association (AF&PA) has broadened
participation in, and independence of, the SFI programme through the development of an
independent board, this board is still dominated by vested forestry interests. The AF&PA
furthermore controls the use of the label and endorses changes to the standards suggested
by the board. Summary reports of the certifications are not consistently available. The
extent to which in depth field evaluations are required during the certification process is
also unclear. SFI is the US member of the PEFC Council, presumably with the aim of
having its standard endorsed by the PEFC.
Main positive points
â Quality of the standard has improved, including some recognition that some critical
forests need conservation.
â An attempt has been made to increase the independence of the SFI and its board from
the AF&PA, and to widen participation on the SFIâs board to include some environ-
mental NGOs.
â If the SFIâs standards are improved, the SFI framework could potentially improve the
practices of many US and Canadian forestry companies.
Main negative points
â Certification of near status quo: there is no meaningful minimum performance-based
standard including preventing conversion of natural forests to plantations, adequately
protecting rare and endangered species and addressing social issues, including
Indigenous Peoplesâ rights and workersâ rights.
Footprints in the forest
Assessment of eight different schemes
23
â Companies can customise the standard used to assess them; certification is therefore
not independent. Furthermore, although there is an âindependent boardâ, this board is
still dominated by forestry industry interests.
â There is no formal chain of custody certification requirement for product labelling, but
rather a weak wood procurement system that allows SFI certified companies to include
certain non-SFI wood sources in their SFI labelled products. As much as 100% of
products carrying the SFI label can originate from forests not even managed to the SFIâs
standards, without any indication of it on the labels.
Conclusion
Because the SFI requires broad participation by AF&PA member companies, it has
considerable potential to influence their forest management practices. However, SFI has no
clear performance requirements, and allows for misleading labelling of products that do
not originate in SFI certified forests. The SFI also gives vested interests considerable
influence over the programme and the certification process. SFI is, therefore, not suitable
for a product label.
The ânewâ schemes
Australian Forestry Standard (AFS)
As a new scheme, only one forestry operation (about 220,000 ha) has been certified under
the AFS.
16
The Australian standard was established by governmental departments and the
timber industry, and covers all types of forests in Australia. There is no label yet, but a
process for labelling and chain of custody standards is under consideration. The standard
is largely system-based with only few performance criteria, making it difficult to be used for
product labelling. The standard allows for clear felling, logging of old growth forests and
the conversion of forests to plantations. The interim certification standard has only just
been made available as this report went to print, but is now freely available on the website.
17
AFS is the Australian member of the PEFC Council, and has presented its standard for
assessment by the PEFC with the aim of having its standard endorsed by the PEFC.
Main positive points
â AFS certification will help reduce illegal logging by encouraging managers to comply
with legal requirements for forestry operations in Australia.
â Chain of custody provisions are on a par with other certification systems.
Main negative points
â No requirement for balanced participation.
â No meaningful performance-based standards.
â The scheme lacks transparency: the certification standard has only just been made
available and it is unclear whether certification reports, or summaries thereof, will be
publicly available.
Conclusion
AFS is a forest certification scheme that suffers from the lack of clear nationally consistent
Footprints in the forest
Assessment of eight different schemes
24
performance-based thresholds. Where minimum thresholds are indicated these are set very
low, allowing near status quo forest management practices to be certified. The lack of
meaningful performance-based standards, lack of participation of environmental NGOs in
the development of the standard, and the lack of transparency make the AFS not suitable
for a consumer label. Environmental NGOs have heavily criticised the standard as a foil for
âbusiness as usualâ.
Sistema Brazileiro de Certificação Florestal (CERFLOR)
CERFLOR is a relatively new industry-dominated and government supported Brazilian
certification scheme. Up until now, only one plantation of 50.000 ha has been certified. The
standard for natural forests is under development and expected to be approved in 2004. No
social groups have participated in the standard-setting process. In a country such as Brazil,
where the discussion over land and user rights is one of the most important issues, a certi-
fication scheme that does not acknowledge this issue is likely to support further
encroachment of peoples land by plantation companies. The lack of transparency of the
scheme is also a serious problem; even the standard itself is not publicly available (needing
to be purchased), and summary reports are only available for a short period of time. Lastly,
the scheme is heavily system-based with very few performance-based requirements.
Existing performance requirements are weak; forest conversion as well as use of GMO trees
are allowed. CERFLOR is the Brazilian member of the PEFC Council, presumably with the
aim of having its standard endorsed by the PEFC.
Main positive points
â There are clear procedures and requirements described in the different documents.
â There is a set of detailed requirements for forest auditors and certification bodies.
â The scheme requires specific training of auditors and certification bodies.
Main negative points
â The scheme lacks transparency: the certification standard is not freely available but
needs to be purchased and a summary report of the existing certification is not freely
available.
â There is no clear minimum performance-based threshold, as the scheme is largely
system-based. There is no clear recognition of Indigenous Peoplesâ rights in line with
ILO 169.
â The standard has been developed in a process dominated by forestry industry and not
with balanced participation of all stakeholders.
Conclusion
CERFLOR is an industry dominated certification scheme. Although it is a requirement of
the system to involve different interests and have a balanced participation of different
sectors of Brazilian society, the certification standard has been mainly developed by
economic interests. Because of a clear lack of minimum performance-based standards, lack
of transparency and no, or insufficient, participation of social and environmental groups,
the CERFLOR scheme does not meet the requirements for a product label.
Footprints in the forest
Assessment of eight different schemes
25
CertificaciĂłn Forestal (Certfor)
As a new scheme Certfor Chile has only certified four forestry operations totalling 900,000
ha. Its goal is to have 8 million ha certified by 2005. Currently, Certfor only certifies
plantations, although its aim is to develop standards for all Chilean forest types. The
plantations standard is mainly system-based, although some principles contain some
performance requirements. The performance requirements are considered weak from an
environmental point of view, as they allow for GMOs and for the conversion of forests to
plantations. Field visits are required in the certification process and summary reports of the
certified plantations are available. Certfor is the Chilean member of the PEFC Council and
has presented its standard for assessment by the PEFC with the aim of having its standard
endorsed by the PEFC.
Main positive points
â Education of forest managers in national and international environmental
commitments the Chilean government has signed, such as the CBD.
â Requirement that land ownership and user rights should be clarified before certification
is possible.
â Summary reports of certifications and standards are freely available.
Main negative points
â There is no clear minimum performance-based threshold, as the scheme is largely
system based. Performance requirements that are available are weak and allow for GMO
trees and forest conversion.
â No requirement for balanced participation in the standard-setting process.
â Unclear procedures in relation to standard-setting, approval of standards and certifica-
tions.
Conclusion
Although Certfor has some positive elements its main weakness is the fact that the standard
is largely system based. The few performance requirements formulated in the standard are
set at such a low level that there is a serious danger Certfor will certify the status quo, rather
than ensure good forest management practices. Furthermore the certification standard has
not been developed in a balanced participatory process, nor are there clear and transparent
rules for decision-making. Because of a clear lack of minimum performance-based
standards and no, or insufficient, participation of social and environmental groups, the
Certfor scheme does not meet the requirements for a product label.
Malaysian Timber Certification Council (MTCC)
The MTCC is the âoldestâ of the ânewâ schemes. 4,111,406 ha of forests in Malaysia have been
certified as of October 2003. The scheme certifies at FMU level, although this is variously
defined in different states. In Peninsular Malaysia, for example, a FMU is the permanent
reserved forest. In Sabah, an FMU will be the area covered by each Sustainable Forest
Management License Agreement, while in Sarawak an FMU is defined as an individual
concession area. The MTCC is more transparent than most other schemes, with the
exception of CSA and FSC. However, its Achilles heel is the lack of performance-based
Footprints in the forest
Assessment of eight different schemes
26
standards, and particularly the lack of recognition given to the rights of local people. In
countries where land disputes are as serious as in Malaysia, certification can only work if
these rights are recognised, and if local communities and NGOs can freely participate in the
standard-setting process.
Main positive points
â Demonstrates a potential legal framework in accordance with various laws, policies and
regulations of the three regions in Malaysia: Sabah, Sarawak and Peninsular Malaysia.
â MTCC has made an attempt to work towards compatibility with FSC Principles,
Criteria and Indicators.
â Procedures, standards and guidelines are clearly documented and freely available.
Main negative points
â There is no clear minimum performance-based threshold.
â There is no full recognition of land rights of local and Indigenous Peoples and no
requirement for full participation of these groups.
â There has been no acceptable participation of environmental and social NGOs and
representatives of Indigenous Peoples in the development of the certification standard.
Conclusion
Although the MTCC has positive aspects in comparison with some of the other schemes,
the standard used for certification is not sufficiently performance-based to allow for a
credible consumer label. Furthermore, there is no clear recognition of land rights and user
rights in the standard, which is a serious omission in the Malaysian context and has, as a
consequence, seriously undermined support for the standard in Malaysia.
Footprints in the forest
Assessment of eight different schemes
27
Comparison
Although tables are often not the best way to show a comparison, as it is not always possible
to compare like with like, what table 1 does reveal is that in all schemes, except the FSC and
arguably the CSA
18
, the forestry sector dominates the standard-setting process. Although by
itself this does not mean that these standards cannot contribute to better forest
management practices, it does not create conditions for truly independent certification, nor
does it guarantee that the standard describes truly good forest management in a given
context. A certification standard ought to be developed in a fully participatory process
which includes all stakeholders â see chapter 2.
Furthermore, a consumer label is required to inform the consumer about what certification
means. Consumers care about old growth forests, pesticide use, clear cutting, land rights of
Indigenous Peoples and other issues. All certification schemes, therefore, ought to be based
on clear minimum performance-based standards that allow consumers to make an
informed choice â see also chapter 1. As table 1 shows none of the schemes â again with the
exception of the FSC â has meaningful performance-based standards that provide this
guarantee. All certification schemes with the exception of FSC allow for the conversion of
forests to plantations â by bending the definition of âforestâ to include âplantationâ these
schemes are making a mockery of âgood forest managementâ.
Transparency is one of the essential requirements for a credible certification scheme, as
outlined in chapter 3. Despite this, only the CSA, the FSC, Certfor and the MTCC are
considered âtransparentâ based on the fact that certification standards and summaries of all
certification reports are readily and routinely available. Other requirements are field visits
to ensure the forests are well managed in practice (required by most schemes, except some
PEFC schemes; SFI requirements are unclear), annual monitoring visits (required by all
schemes, except SFI) and a well-defined chain of custody (required by all, except SFI). A
Table 1
Footprints in the forest
Assessment of eight different schemes
28
AFS
No
No
Yes
FMU
Yes
CERFLOR
No
No
Yes
FMU
Yes
Certfor
No
No
Yes
FMU
Yes
CSA
No
Yes
No
FMU
Yes
FSC
Yes
Yes
No
FMU
Yes
MTTC
No
No
Yes
FMU
Yes
PEFC
No
No
Yes
Mostly regional
Not always
SFI
No
No
Yes
FMU
Unclear
Is the scheme
based on a set of
clear minimum
performance-
based thresholds?
Does the scheme
require balanced
participation in
standard-setting
process?
Is the standard-
setting dominated
by forestry
sector?
Does the
certification
scheme certify
at Forest
Management Unit
or regional level?
Are field visits
required?
proper consultation process should be an essential part of the certification process, as
outlined in chapters 1, 2 and 3. The FSC, MTCC, Certfor and CSA all require stakeholder
consultation as part of the certification process, but the quality of the process differs
considerably. A yes in one column therefore means something very different in practice
than a yes in another column, see chapter 1. The SFI, PEFC and CERFLOR do not have any
consultation requirements.
Table 2
Footprints in the forest
Campaigning at the EU level
29
Coverage
Forests or
Area certified
plantations
AFS
Australia
Both
± 220,000
CERFLOR
Brazil
Both
50,000
Certfor
Chile
Both
900,000
CSA
Canada
Both
28,405,000
FSC
Global
Both
40,422,684
MTTC
Malaysia
Both
4,111,406
PEFC
Europe
Both
48,600,000
SFI
US, Canada
Both
30,319,476
Unclear Yes No Yes No No
No Yes No Yes No No
Yes Yes Yes Yes No No
Yes Yes Yes Yes No No
Yes Yes Yes Yes Yes Yes
Yes Yes Yes Yes No No
No Yes No Yes No No
No No No No No No
Is consultation
of stakeholders
in certification
process required?
Is annual
monitoring of
certified areas
required?
Is the scheme
transparent
(i.e. are standards
and summary
reports freely
available on
websites)?
Is there a label
and well defined
chain of custody
available?
Does the scheme
prohibit the
conversion of
forests to
plantations or
other land uses?
Does the scheme
prohibit use of
Genetically
Modified
Organism trees?
30
Footprints in the forest
Is certification possible under WTO rules?
31
Is certification possible under WTO rules?
Many NGOs and some governments argue that forest certification and labelling are under
threat from the WTO. It is true that a few governments, notably Canada
19
, are considering
using WTO rules to undermine some independent forest certification schemes, but there is
currently no WTO agreement that disallows certification and labelling schemes. In fact,
there are 723 mandatory labelling schemes that have been notified to the WTO, 51 of which
have been put in place for environmental protection.
20
There is no official WTO position on certification or labelling. Nonetheless, the discussion
between trade rules and product labels has been a contentious issue since the creation of
the WTO in 1994. WTO rules do not prevent countries from imposing different require-
ments, including labelling, on products that have different characteristics. However, where
the requirements relate to aspects that have no bearing on the commercial or indeed
practical âsubstitutabilityâ of the products (relating instead to the way in which products are
produced), discrimination may contravene WTO rules. Put simply, if a consignment of
certified timber and a consignment of uncertified timber are equivalent in terms of their
function and appearance when they are sold, the WTO does not allow the different ways
the timber was produced to be of relevance in, for example, setting tariffs. Most of the
discussion within the WTO has therefore focused on whether labelling based on âprocess of
production methods (PPM)â is allowed, and much of the controversy has focused on the
status of voluntary eco-labelling programmes.
A forest certification scheme is in this respect a voluntary PPM-based labelling scheme.
WTO members have until now failed to agree on the extent to which PPM-based labelling
schemes are covered under the Technical Barriers to Trade (TBT) Agreement, let alone
whether they are permissible. It is, however, increasingly argued, notably in a paper
prepared by the OECD,
21
that discrimination of products on the basis of PPM is now
allowed under WTO, since a WTO ruling (Appellate Body) in the âshrimp turtle caseâ
22
removed the restriction on using PPMs for the development of environmental regulations.
The condition given was that the process and production measures should be implemented
in a manner that conforms to WTO rules. Therefore, the argument follows that if there is
no WTO-related restriction on PPM-based environmental regulations, then there should
be no difficulty with eco-labels using a similar approach.
23
This approach has not, however,
been put to the test.
If a certification scheme were to be challenged in the WTO, it might allege failure to meet
obligations under the following WTO Agreements: Government Procurement, Technical
Barriers to Trade (TBT), Subsidies and Countervailing measures and the Sanitary and
Phytosanitary Agreement (SPS).
24
Currently, the only area under discussion among WTO members in relation to
labelling and certification is the TBT Agreement.
25
The TBT Agreement tries to ensure
that regulations, standards, testing and certification procedures do not create
unnecessary obstacles to trade. The agreement recognises a countryâs right to adopt
the standards it considers appropriate â for example for human, animal or plant life,
5
Taiga forest
Photo: Greenpeace
32
for health, for the protection of the environment, or to meet other consumer
interests.
In order to prevent too much diversity, the agreement encourages countries to use interna-
tional standards where these are appropriate. The agreement sets out a code of good
practice for the preparation, adoption and application of standards by central government
bodies, which is applicable to WTO members and open to all non-state-bodies developed
in standard-setting. The code of good practice requirements includes avoiding duplication
of standards, making every effort to achieve national consensus, and (wherever
appropriate) requiring performance-based standards.
In its final report to the Cancun meeting in September 2003,
26
the WTOâs CTE Committee
stressed the importance of the TBT Agreementâs Code of Good Practice. Moreover, it
recalled that the TBT Committeeâs decision on the principles for the development of
standards provided useful guidance. These principles include transparency, inclusiveness or
openness (that all stakeholders be involved in the development of the standard), impar-
tiality and consensus, effectiveness and relevance, coherence and whenever possible respon-
siveness to the needs and interests of developing countries.
In line with ISO clauses (laid down in the ISO Guide of Good Practice for standardization)
27
and WTO requirements (laid down in the TBT Code of Good Practice and the Principles for
the Development of International Standards), all forest certification schemes should ensure
that:
â Standard-setting processes for certification schemes are open and equally accessible to
all interest groups at all stages and all levels.
â The standard-setting process is consensus based.
â Standards are performance-based.
â They do not duplicate other standards or processes.
â They operate in a transparent, coherent and impartial way.
Conclusion
Although forest certification and labelling based on PPM are under discussion in WTO
circles, there is as yet no plan to prohibit voluntary certification and labelling. NGOs and
governments should, therefore, refrain from using âWTO argumentsâ to argue against certi-
fication. It is unlikely the WTO would ever rule against voluntary certification schemes as
long as they meet WTO and ISO rules. Arguably, FSC meets these rules better than other
schemes as the FSC scheme contains performance-based standards, includes all stake-
holders in standard development, is transparent and impartial.
Footprints in the forest
Is certification possible under WTO rules?
33
Relevant developments in the debate
As this report describes, there are problems with regards to setting and upholding certifi-
cation standards, with different certification schemes applying different standards,
procedures and rules. These are not, however, the only concerns. This chapter evaluates an
approach to three further relevant issues: mutual recognition, the step-wise approach and
illegal logging.
Mutual recognition
A few years ago
mutual recognition
was a key topic in the forest certification debate.
Mutual recognition is a reciprocal arrangement under which one schemeâs standards body
or system recognises, and accepts, other standards or certification systems as substantively
equivalent in intent, outcome and process. Given the proliferation of certification schemes
on the market, it is not surprising that there are calls for mutual recognition between
different schemes. Such calls are often supported by governments and industry.
At present, the differences between the certification schemes examined here are too great to
justify mutual recognition. Nonetheless, it is clear that this is exactly the aim of PEFC: to
develop mutual recognition agreements with schemes within and beyond Europe, with the
sole exception of the FSC. Demonstrating this, AFS, SFI, CSA, CERFLOR, Certfor and
MTTC are all represented on the PEFC Council with the aim of having their standard
endorsed by the PEFC. The AFS and Certfor have already submitted their schemes to the
PEFC for assessment. This is a peculiar development as PEFC was originally created to meet
the demands of the small forest owners. If this situation continues, the founding intention
of the creation of the PEFC will undoubtedly be undermined by big industry â the most
obvious beneficiary from mutual recognition.
Conclusion
Although the debate on mutual recognition is less prominent than a few years ago, mutual
recognition is happening at a grand scale. Virtually all existing certification schemes, with
the exception of the FSC, are attempting to assemble under the PEFC umbrella.
Step-wise approach
A topic of growing interest in the certification debate is
step-wise approach
. In 2002, a
study by the International Tropical Timber Organisation (ITTO) found that less than 8%
of the worldâs certified forest area is in the tropics i.e., in ITTO member producer
countries.
28
As a result the ITTO concluded that certification schemes have not been
designed in a way that helps developing countries make fast progress in this field. The step-
wise approach is the process whereby continuous improvement is essential, and different
starting levels are recognised. As such, this phased approach is proposed as a potentially
feasible option for tropical timber producers to gain recognition for their efforts to
6
Footprints in the forest
Relevant developments in the debate
34
implement certification. The step-wise approach should be based on commitment to
achieve certification to a defined standard for SFM, which is acceptable to the market. Some
see verification of legality as a first step in market acceptability. In particular, European
governments that have adopted timber procurement policies see verification of legality as
a first step, followed by the production of sustainable timber. This may be problematic.
ITTO says it wishes to consult widely, including NGOs, forest owners, local communities
and Indigenous Peoples, in the development of this approach. However, it remains to be
seen whether ITTO will be true to its word.
Conclusion
Step-wise approaches are happening at different levels. The response of companies whose
practices cannot meet the standards developed by a certification scheme (originally those
set by the FSC), has been to create other certification schemes with standards that they can
meet. The response of some consultancies, notably Proforest, to solving the difficulties that
forest managers are having meeting certification standards (notably the FSCâs), has been to
develop steps (modules) for companies to allow them to climb up to a certifiable level. The
response of some retailers has been to pick and choose the certification schemes that they
believe credible and acceptable. While NGOs have not developed a joint response to step-
wise approaches, they have by and large not been willing to acknowledge certifications
according to standards that are lower than the FSCâs. Thus NGOs are likely to have
difficulty publicly acknowledging forest managers who adopt lower performance standards
under a step-wise approach.
Illegal logging
With
illegal logging
in the spotlight, it is not surprising that many make the link between
illegal logging and forest certification as both require chains of custody, auditing, and so on.
Certifying legality is now sometimes seen as a first step towards certifying sustainability.
However, several studies have pointed out problems with this approach. A recent final draft
of a report by SGS Global Trade Solutions, written for the World Bank/WWF Alliance states:
âCertification schemes such as FSC, PEFC or ISO 14000 [âŠ] may not be the most
appropriate and comprehensive solutions to the illegal logging problem [âŠ]These
âquality assuranceâ systems have not been designed as tools to enforce the law and to be
made compulsory. They are not based on regular and unannounced audits and on
continuous sampling and they rely on paper-based chain-of-custody systems that are
possible to forge. Given this, certification schemes do not provide the level of confidence
that is likely to be required to demonstrate legal origin.â
29
The same report points out that improving the current rules and regulations may not be
adequate to detect illegal logging and to prevent fraud concerning certification in Africa,
the report states:
âBy design, certification cannot be used as a detection tool: although ârespect of all
national and local laws and administrative requirements ⊠and of all the provisions of
Footprints in the forest
Relevant developments in the debate
35
binding international agreementsâŠâ. is part of FSC principles 1.1 to 1.5, certification
audits do not involve probing, in-depth investigation for fraud. Legality is not the
primary concern: assessors are not policemen. Certification is a quality assurance
approach and demands trust and goodwill. Initial assessments and surveillance visits are
limited in time, frequency and area. Current chain-of-custody requirements and audit
systems are therefore vulnerable to abuse.â
30
There are cases, in the US for example, where the concern over legality will be more focused
on compliance with laws governing forestry practices, endangered species, water quality,
etc. In these cases, unannounced visits, in depth chain of custody analysis and the like are
less necessary to control the logging, as the impact and design of a logging operation
cannot be easily hidden.
Another recent World Bank report,
31
clearly states the need for physical segregation of
certified products from non-certified products throughout the chain from forest to retailer,
as well as the need for independent monitoring of the chain of custody to detect illegal
practices. If a label stating that the forest product is coming from well-managed forests is
to be used as verification that the wood is legally sourced, three conditions have to be
fulfilled:
â the forest certification standard needs a clear requirement that national laws have to be
abided by;
â the standard needs to be implemented effectively;
â there needs to be effective chain of custody control from the forest to the point at which
the product is labelled.
In order to effectively exclude non-certified content, a credible chain of custody should
include three main elements: identification, segregation and documentation. Segregation
requires clients to physically keep certified wood separate from uncertified wood at all
phases of transportation, production, distribution, sale and export. Accurate records need
to be maintained for the production of certified products.
Conclusion
Many link discussions on forest certification with the verification of legality, necessary to
identify illegally sourced timber. This report argues that forest certification schemes are not
ideal tools to address illegal logging practices, although some schemes (FSC and CSA) are
notably better in identifying them than others. Even these schemes are not based suffi-
ciently on the unannounced audits, continuous sampling, and in depth chain of custody
analyses that are seen as essential for verification of legality in cases where fraud could be a
problem. Furthermore, certification schemes do not address â or adequately address â the
legality of the non-certified timber supplies. While most certification schemes are
attempting to address the legality of non-certified timber supplies procured and purveyed
by certified companies, the procedures are still largely inadequate. It is therefore advisable
to de-link the discussions on verification of legality from the qualitative auditing of forest
management practices.
Footprints in the forest
Relevant developments in the debate
36
37
Executive summary
This report looks at the current practices and challenges ahead for forest certification. It
argues that for a certification scheme to be credible several conditions need to be met.
These include an inclusive standard-setting process that is independent of vested economic
interests, a certification process that emphasises auditing the forest itself rather than
documents in an office, and transparency. Furthermore, for a product label to be
meaningful and trustworthy to consumers, the certification standards should clearly define
the minimum threshold that a forest owner or forestry company must meet before the
forest gets certified. Finally, to ensure the product that the consumer buys comes from a
certified forest, a credible tracing and tracking system needs to be in place.
The importance of an inclusive standard-setting process is often poorly understood.
There is, however, no scientifically correct definition of âsustainable forest managementâ.
Criteria and indicators describing what constitutes good forest management in a given
national or regional context need, therefore, to be developed jointly by different
interest groups including representatives from economic, social and environmental
sectors. The standard-setting process needs to be independent of vested economic interests;
a certification standard that has been developed by the forestry industry alone is not
credible.
The conditions that need to be met for a certification scheme to be credible, including the
criteria mentioned in this report, have all been identified by governments and industry in
numerous official positions. Nonetheless, as this report shows, most of the eight forest
certification schemes currently in operation do not fulfil most of these criteria.
The eight forest certification schemes examined â AFS, CSA, CERFLOR, FSC, PEFC, SFI,
MTCC and Certfor â clearly demonstrate how different certification schemes tell different
stories and therefore will yield different results. Each applies different forest management
standards, with different procedures and labelling rules. The problem is that most of these
forest certification schemes certify the status quo thereby undermining the concept of certi-
fication. To give just one example, all schemes assessed, with the exception of the FSC, allow
for the conversion of forests to plantations. In other words, consumers can buy a piece of
timber that they believe comes from a âwell managed forestâ while, in fact, that forest has
been cut down to make place for a plantation. We believe that the expectations of the
consumer are not in this circumstance met, and that any scheme that allows this scenario
is not a credible one.
Looking carefully at whether the examined schemes meet the above-mentioned conditions
for credibility, this report concludes that with the exception of the FSC the forest certifi-
cation schemes do not meet these conditions. Six out of the eight schemes, FSC and CSA
32
being the exception, have standards primarily developed by the forestry sector, thereby
putting the independence of certification into doubt. Half of the schemes assessed are not
transparent, as summary reports of certifications or even the standards themselves are not
freely available on websites. Social issues, and specifically land and user rights issues,
arguably one of the most important discussions in the current forest debate, are not (or not
7
Footprints in the forest
Executive summary
Moss in tree, food for
reindeer
Photo: www.pefcwatch.org
38
sufficiently) addressed by any of the schemes, although the FSC again is well ahead of its
competitors.
Considering these results, it should come as no surprise that for most NGOs the FSC
remains the only credible scheme.
Although much attention has been focused on the threat for forest certification posed
by the WTO, this report argues that that this threat has been exaggerated. As long as a
certification scheme fulfils international rules for standardisation, which most and notably
the FSC does, then it is wholly WTO compatible.
Many link discussions on forest certification with the verification of legality, necessary to
identify illegally sourced timber. It should be kept in mind however, that forest certification
schemes are not ideal tools to address illegal logging practices â although some schemes are
notably better in identifying illegal practises than others. Even these schemes are not based
sufficiently on the unannounced audits, continuous sampling and independent monitoring
of the chain of custody that are seen as essential for verification of legality. It is, therefore,
advisable to disassociate the discussions on verification of legality and the qualitative
auditing of forest management practices.
With the majority of certification schemes currently in operation certifying the current
status quo of forest management, the credibility of certification as a tool to improved
forest management is on the line. Unless existing forest certification schemes improve and
tighten their procedures and practices, forest certification can achieve very little in
improving forest management. The FSC should still be seen as the benchmark for credible
certification, as it has clear minimum performance-based national standards and a
balanced and inclusive decision-making process. It is also transparent and has well
developed certification, accreditation, chain of custody and labelling procedures.
Nonetheless, the FSC has also come under close scrutiny for failing to implement its own
policies, and will have to improve its performance on the ground (rather than its
procedures) to ensure forest certification remains a credible tool for improving forest
management.
Footprints in the forest
Executive summary
39
Footprints in the forest
Executive summary
An aerial view of the Klabin plantation in Brasil
Photo: Edward Parker
40
41
Eight forest certification case studies
The workings of the eight certification schemes described in chapter 4 are
dealt with in further detail in this section. The information is derived
from eight case studies commissioned by FERN for this report. The full text
of the eight case studies is available at FERNâs website: www.fern.org. The
eight schemes are categorised as âoldâ schemes â the CSA, FSC, PEFC and SFI
â and ânewâ schemes â the AFS, CERFLOR, Certfor Chile and MTCC. The case
studies have been carried out by NGO representatives chosen â wherever
possible â from the region where the scheme operates. All certification schemes
have had the chance to provide comments, improvements, and suggestions to
the summaries included in this report. All comments indicating factual
mistakes, have been duly incorporated. None of the individuals, or NGOs
involved in drafting the case studies is, however, responsible for the analysis or
the content of the remaining part of this report.
Footprints in the forest
Eight forest certification case studies
Certified timber
Mexico
Photo: Juan Carlos Reyes Garcia
42
Canadian Standards Association
Standard (CSA)
Based on a report by Sierra Club Canada
1 History and characteristics
Creation
The Canadian Standards Association (CSA) is an independent,
not-for-profit, non-statutory, voluntary membership organi-
sation engaged in standards development and certification
activities. It was chartered in 1919, and in 1973 was accredited
by the Standards Council of Canada â the federal agency
responsible for Canadaâs National Standards System.
The CSA has a separate division, called QMI, which carries
out registration of management systems, including the CSAâs
Sustainable Forest Management system. Another CSA
Division called CSA International carries out product certifi-
cation. CSA Internationalâs Forest Products Group delivers
the Forest Products Marking Program, which is the chain of
custody, and product-marking component of the CSA SFM
Program. CSA International is the Canadian member of the
PEFC Council, with the aim of having the CSA standard
endorsed by the PEFC.
Funding
The development of the CSA SFM standard was supported
with proponent funding from the Forest Products Association
of Canada and the Federal Government of Canada.
Motivation
The CSAâs Sustainable Forest Management system was
developed to, âpromote the use of internationally recognized
sustainable forest management certification standards in
Canada in order for Canadian producers to continually move
towards sustainable forest management, secure a sustainable
supply of raw material, and to ensure marketplace acceptance
of Canadian forest productsâ.
33
Coverage
The CSA standard must be applied to a âdefined forest areaâ in
Canada but does not specify an upper or lower size limit.
Amount of hectares certified
33 Certificates have been issued, comprising a total area of
28.4 million ha. The size of forest lands certified under each
certificate ranges from a low of 110,000 ha, to a high of
4,940,000 ha, with an average size of 760,000 ha and a median
size of 470,000 ha. An industry survey projects that 71.7
million ha will be certified under the CSA scheme by the end
of 2006.
34
CSA International has issued 44 chain of custody
certificates covering 76 sites in Canada. Three sites are
licensed to apply the CSA SFM Mark on certified forest
products.
Label and chain of custody
There is a label and chain of custody in operation through
CSA Internationalâs Forest Products Group.
2 Quality of the standard
Performance or system
The CSA claims that its standard is a performance standard,
because it, âprescribes use of a mandatory set of criteria and
elementsâ, and, âgives the public an opportunity to assist in
setting specific values, objectives, indicators and targets at the
local forest level for each of the elements.â
35
The public
performance requirements, while laudable, are not relevant to
the claim that it is a performance standard, since they
describe a process that must be followed rather than a result
that must be achieved. The CSAâs claim to be a performance
standard rests on its âCSA SFM elementsâ, a set of 17 broadly
worded requirements. They are roughly comparable to the 10
global principles of the FSC. The difference is that in the case
of the FSC, the principles are interpreted through 56 criteria,
all of which are then interpreted through national or
regionally specific standards subject to approval by FSC
International. In the case of the CSA, however, the applicant
is responsible for providing additional detail on each of the
17 elements, including values, objectives, indicators and
targets. The standard itself provides an accountability check
only on the process used to incorporate public input and
develop the SFM plan, and not on the specific targets in the
plan. The CSA SFM standard is, therefore, a management
system standard with a detailed framework for the
development of performance requirements by the applicant
in consultation with affected publics.
Comments
The strengths of the CSA standard are that it was approved
unanimously by a Technical Committee comprising a
diversity of interests. It has strong requirements for public
Footprints in the forest
Canadian Standards Association Standard (CSA)
43
participation; it has excellent provisions for tracking chain of
custody and it has outstanding requirements for transparency.
As a result, it is a good tool for a forestry company to foster
better relations within affected communities.
Its limitations are that the Technical Committee that
approved the standard lacked representation from Aboriginal
organisations, or from environmental organisations involved
in active public campaigns to highlight negative forestry
practices. Furthermore, it is a difficult standard for managers
of small forests to implement. Lastly, as mentioned above, the
standard lacks detailed performance requirements. These
inherent limitations in the CSA SFM standard make it
inadequate for use in influencing purchasing decisions made
by green consumers or retailers.
3 Standard-setting procedures
Who is involved?
Responsibility for developing CSA standards rests with
Technical Committees, whose members are appointed from
various sectors intended to reflect a âbalanced matrixâ of
academia, environmental and general interest and
government and regulatory bodies. The Technical Committee
that approved the current CSA SFM standard comprised five
industry representatives, six governmental representatives, six
environmental, or general interest representatives, and eight
academics, professionals or other individuals.
Is balanced participation required?
The standard was developed in a balanced and open way. The
CSA and the Technical Committee made genuine efforts to
resolve conflicts that arose. It was not possible to resolve all
conflicts, however, and three organisations â the Sierra Club
of Canada, the Alberta Wilderness Association and the
National Aboriginal Forestry Association â withdrew from the
Technical Committee before the remaining Committee
members unanimously approved the standard. The failure to
address the concerns of environmental and Aboriginal repre-
sentatives on the Technical Committee was not due to an
unfair or imbalanced process, but rather to a fundamental
disagreement about what the standard should include in its
scope.
The standard states that when CSA set out to review the
original standard it âstrengthened the conservation represen-
tation on its SFM Technical Committeeâ.
36
This refers to the
two conservation groups that withdrew from the Technical
Committee. The claim is misleading in implying that the
standard was approved by a strengthened Technical
Committee.
4 Certification process
Who does what?
The certification process follows the following steps:
â
The organisation files a formal application with the certifier.
â
A review of preliminary documentation is completed to
assess readiness to proceed to the preliminary assessment
audit.
â
A preliminary audit is done to assess just how prepared
the organisation is for the upcoming certification audit.
The preliminary audit is a combination of a field (forest)
audit, interviews with employees and document review.
â
The certification audit ascertains whether or not the
organisation meets the standard, with a high proportion
of audit time spent in the field.
â
The certificate of registration is awarded.
â
Annual surveillance audits are done at least once a year.
â
A full re-certification must be done every three years.
During the certification audit, the certifier determines
whether each of the 17 SFM elements identified in the
standard has been addressed by the applicant organisation.
The auditor first confirms that each element has been
addressed, meaning that it has one or more objectives,
indicators and targets associated with it, and these are being
implemented. The auditor is also required to assess whether
or not a valid indicator has been chosen for each element,
and whether the associated objectives and targets will, if
implemented, provide a sufficient guarantee that the
requirement will be met. An auditor must note and
report any weaknesses in the link(s) between a requirement
and its associated objectives and targets.
37
Major non-conformances (precluding certification), include
any one or combination of the following:
â
one or more requirements of the standard have not been
addressed;
â
one or more requirements of the standard have not been
implemented; or
â
several minor non-conformances exist that, taken
together, lead the auditor to conclude that one or more
requirements have not been addressed.
Footprints in the forest
Canadian Standards Association Standard (CSA)
44
There is a separate independent third party audit required of
the chain of custody requirements set out in CSA PLUS 1163.
This is needed as a first step if an organisation is interested in
using the CSA Mark (label) on the wood products derived
from a certified forest.
Is stakeholder consultation required?
The CSA process requires public participation in the
standard-setting process (identification of values, objectives,
indicators, targets based on the CSA SFM elements), as well as
in the review of the SFM management plan, in the design and
monitoring, and in discussing and resolving any issues
relevant to SFM, among others. The public participation
requirements of the CSA SFM standard are in many aspects
exemplary. As written, they allow for local stakeholders to
play an effective role in influencing forestry operations in
their region.
The key components of the CSAâs public participation process
require the organisation to:
â
establish and implement a public participation process;
â
openly seek representation from a broad range of
interested parties, including efforts to contact Aboriginal
forest users and encourage their participation; and
â
ensure that the public participation process works
according to clearly defined operating rules that are
agreed to by the participants. The process must also
include provisions on, inter alia, timelines, internal and
external communications, resources, roles and responsi-
bilities of participants, conflict of interest, decision-
making methods, access to information, participation of
other experts and government, and a dispute-resolution
mechanism.
There are, however, several cautionary points worth noting:
â
No standard can guarantee that a public participation
process is truly effective at elucidating, addressing and
resolving public interests and concerns with forest
management.
â
A poorly facilitated process, or one that is manipulated by
the applicant to meet a predetermined outcome, may
technically fulfil all of the public participation require-
ments of the CSA standard, but without achieving the
desired result of an engaged and satisfied public.
Footprints in the forest
Canadian Standards Association Standard (CSA)
Canada
Photo: Ian McAllister/raincoast.org
45
â
Local public advisory groups often lack independent
expertise with knowledge of the latest advances in science,
or in best management practices.
â
Although local residents are most directly affected by
forestry operations it remains the case that forests and
forest health are a matter of national and even global
concern. Any standard that incorporates local public
involvement must strike a delicate balance between the
need for regional flexibility and the, sometimes,
conflicting need for national or international consistency.
These cautionary notes apply to all public participation
processes. They are especially important in the case of the
CSA standard, however, because of the high degree of
importance assigned to the public participation process. It is
through that process â rather than the standard itself â that
organisations receive guidance on specific targets or thresholds.
Monitoring
Annual surveillance audits are required. A certificate is valid
for three years.
Complaints procedures
Appeals regarding the standard are to be initially addressed to
the CSA (if it pertains to the standard), or to the registrar (if
it pertains to a certified client). If the matter is not resolved
by these agencies then the Standards Council of Canada
should be approached.
38
5 Transparency
The CSA standard is available for free downloading from the
CSA website. The organisation obtaining CSA SFM certifi-
cation must make three important documents publicly
available:
â
its SFM plan;
â
an annual report on its performance in meeting and
maintaining the SFM requirements;
â
the results of independent certification and surveillance
audit reports.
These requirements set a high standard for transparency and
accountability. The certifier is further required to make the
initial certification reports and annual surveillance audit
reports publicly available.
6 Label protection and chain of custody
Within the CSA International Forest Products Marking
Program there are three marking options. These marking
options are based on how the inventory of certified forest
products are managed. The marking options include:
â
100% of the product has been tracked and monitored
from its point of origin (a CAN/CSA Z809 certified
forest) to the end consumer. This mark appears on the
product and/or the packaging.
â
At least 70% of the input used to make this product line
has been tracked and monitored from its point of origin
(a CAN/CSA Z809 certified forest) to the end consumer.
This mark appears on the product and/ or packaging.
â
At least 70% of the content of this composite product has
been tracked and monitored from its point of origin (a
CAN/CSA Z809 certified forest) to the end consumer.
This mark appears on the product and/or the packaging.
The CSAâs chain of custody guidelines are not set out in a
standard, but rather in a supplementary publication prepared
internally by CSA. These guidelines are published without
prior review or approval by the CSAâs Strategic Steering
Committee on the Environment. The CSA chain of custody
guidelines are also set out without being approved as a
standard by the Standards Council of Canada. Nonetheless,
the CSAâs chain of custody requirements equal or surpass
those of any other major forest product chain of custody
labels, with the exception of its approach to wood from
controversial sources.
Policy on controversial sources
In the case of percentage-based claims, none of wood-based
raw material may come from controversial sources.
Controversial sources are defined as âwood or wood raw
material from illegal or unauthorised harvesting such as
harvesting in forest areas protected by law. Also, wood or wood
raw material from forest areas officially published by
government authorities (or the body with the legal authority to
do so) as planned to become strictly protected by law, without
the government authorities (or the body with the legal
authority to do so) giving permission to harvest.â The
requirement that wood from controversial sources not be
included is limited to illegal logging, rather than to logging of
rare old growth or other high conservation value forests. The
lifecycle analysis requirement is progressive but may be hard
to audit.
Footprints in the forest
Canadian Standards Association Standard (CSA)
46
Forest Stewardship Council (FSC)
Based on a report by Chris Lang
1 History and characteristics
Creation
The FSC was founded in 1993 by 130 representatives from
environmental, economic and social sectors of society. Its aim
is to support environmentally appropriate, socially beneficial
and economically viable management of the worldâs forests. It
became operational in 1994 as a membership organisation.
FSC members are divided over three chambers representing
environmental, social and economic interests. Each chamber
has equal voting rights. The FSC is governed by an
International Board, with equal representation from the
environment, social and economic chambers.
Funding
The FSC is funded by accreditation and membership fees,
governments, environmental organisations and private
foundations.
Motivation
âThe scheme was created because a group of timber users,
traders and representatives of environmental and human rights
organisations met to discuss how they could combine their
interests in improving forest conservation and reducing defor-
estation. Their meeting confirmed the need for an honest and
credible system for identifying well-managed forests as
acceptable sources of forest products. It was from these
beginnings that FSC has developedâ.
39
The FSC was founded,
â[âŠ] in response to public concern about deforestation and
demand for a trustworthy wood-labelling schemeâ.
40
Coverage
The FSC provides a platform for certification at Forest
Management Unit level only. There are mechanisms available
for certification of small businesses. The scheme covers both
plantations and forests.
Amount of hectares certified
As at January 2004, 40, 422, 684 ha in 59 countries had been
certified under the FSC scheme. On its web site,
41
the FSC
divides its certificates into the following categories: plantations,
semi-natural and mixed plantation and natural forests.
Label and chain of custody
The FSC has a system for tracing certified products through
the chain of custody. It also has a label and rules established
for label use. The FSC has issued most chain of custody
certificates: 3,405 certificates in 72 countries.
2 Quality of the standard
Performance or system
National FSC standards are based on the 10 international FSC
Principles and Criteria and Indicators. The national (or
regional) standards are performance-based, but include
system-based standards as well. All national and regional (i.e.,
sub-national) standards must meet the FSC Principles and
Criteria as well as its process requirements. There is some
difference in quality between the different national and
regional standards, caused by the fact that these standards are
developed at the national (or regional) level, and therefore
reflect national or regional priorities.
Quality
FSC standards are inclusive of social, spiritual, environmental
and economic values. National/Regional Forest Management
Standards are set at national or regional level. For example,
the US is divided into nine different regions for the purpose
of standard-setting. FSC national standards are detailed and
specific. They require compliance with national regulations.
They include requirements such as: harvest canât exceed
growth; no conversation of natural forest to plantation, or to
non-forest land; proportion of existing plantations to be
restored to natural forests; protection of high conservation
value forest; protection of workersâ rights and indigenous
rights, and no use of GMO trees.
There are currently 17 adopted regional FSC standards in
nine countries. However, the FSC has certified forests in 59
countries. Many FSC certificates have thus been awarded in
the absence of national standards. In these cases, the certifi-
cation body uses its own generic standards adapted to the
local situation, which must be based on the FSC Principles
and Criteria, but is often much less specific. It is, therefore,
understandable that in those cases that FSC certificates have
been challenged, this has mostly been in countries where
there is no national FSC standard. FSC is addressing this
problem by improving harmonisation in the use of certifi-
cation bodiesâ interim or generic standards, and providing
more detailed guidance on standards development. It is also
Footprints in the forest
Forest Stewardship Council (FSC)
47
promoting the development of national standards through its
policy of decentralisation. Where draft national standards
exist, certification bodies are required to take these into
account for the purpose of forest management evaluation.
42
Comments
The FSC Principles and Criteria do not allow for GMO trees,
prohibit the conversion of forests to plantations and have
clear requirements for protection of high conservation value
forests as well as workersâ rights and indigenous rights. As
with other certification schemes, it is seen as a problem that a
certification body can allow for certification if a minor failure
occurs, while a major failure, defined as a failure at the level
of the Principle, would bar a forest management unit from
being certified. At the moment of writing this report, there is
no clear definition of what constitutes a major failure, nor
what is a reasonable timeframe to rectify a minor failure. This
opens the door to abuse of the system, which has occurred in
some cases. The new accreditation standard, which will be
operational from 2004 onwards is, however, expected to
provide detailed guidance on major and minor failures.
3 Standard-setting procedures
Who is involved?
Standards are developed by a national working group, which
has a separate legal identity, but agrees on FSCâs mission and
purposes. The FSCâs National Initiative Manual sets out
requirements for national standard-setting processes.
43
A
National Working Group must have a balanced composition
of social, environmental and economic interests. Any
interested stakeholder group must be given access to the
National Working Group. As a minimum requirement, the
Working Group must have two representatives from each
chamber. However, where a balance of interests is not
represented in the Working Group, a clear demonstration
must be made of extra efforts to seek input from under-
represented interests.
The National Working Group decides upon decision-making
procedures, but consideration should be given to the FSCâs
three-chamber and voting system. FSC recommends that all
national initiatives take decisions through consensus. When
disagreement exists issues should be put to a vote, with a
Footprints in the forest
Forest Stewardship Council (FSC)
FSC certified products
Photo: EdwardParker
48
required two-thirds majority. All FSC Working Groups may
include non-members as full participants, or as observers.
Once a national standard has been finalised, the FSC interna-
tional secretariat must confirm that all consultation require-
ments and recommendations are explicitly and adequately
addressed before a standard meets the FSC Principles and
Criteria, and is sent to the FSC board for final approval. The
board and secretariat check specifically whether any
particular interest group has dominated the development of
the standard, whether there have been fair decision-making
procedures, whether all FSC members have been contacted
and whether there is a mechanism for revision.
Is balanced participation required?
The system requires balanced participation in the creation of
National Working Groups in voting procedures and in the
general FSC International board.
44
4 Certification process
Who does what?
There are 12 FSC accredited certification bodies. In countries
where there is an adopted FSC standard, this standard is used
for certification. Where no FSC endorsed standard exists the
certification body produces an interim standard before the
assessment takes place. The interim standard must be
finalised and circulated to stakeholders at least one month
prior to the certification decision.
45
The certification process is as follows: a forest owner/manager
asks a certification body, accredited by the FSC, to certify the
forest. The certification body conducts an audit of the forest.
If the forest is found to conform to FSC standards, a
certificate is issued. Even if the certificate is issued, the certifi-
cation body may issue conditions or corrective action
requests, which describe improvements which are to be made
within a given timeframe.
Is stakeholder consultation required?
Consultation of stakeholders in the certification process is
required by the FSC, and the accreditation manual contains
guidelines on minimum levels of stakeholder consultation.
There is, however, evidence in a number of cases that the
stakeholder process does not always work in practice as it is
envisaged on paper. In its new Accreditation Standards, the
FSC has apparently provided more detailed guidance to certi-
fication bodies on requirements for stakeholder consultation.
Monitoring
Certificates are awarded for a five-year period and are then
re-assessed. Certificate holders are audited on an annual basis
during this five-year period.
Complaints procedure
If a forest is unjustifiably certified or refused a certificate,
there is an elaborate complaints mechanism open to FSC
members. In the first instance, the FSC encourages concerns
to be raised directly with the parties concerned.
46
If a
complaint becomes a formal dispute, it must be supported by
at least two FSC members. However, both the FSC secretariat
and some FSC members agree that the mechanism is
complicated and cumbersome, and needs to be revised. A
revision process is underway.
5 Transparency
Are summary reports available?
Full certification reports are not available. The certification
body is, however, duty bound to prepare a summary for each
certified forest management enterprise. FSCâs accreditation
manual gives a recommended, but not required, structure of a
public summary. Random checks show that public summaries
are available from the web sites of the certification bodies.
Are standards and procedures freely available?
Yes, standards and procedures are available on the FSC
website, in draft or in final form.
6 Label protection and chain of custody
Label use
The FSC label can only be used on products where the chain
of custody has been audited and is monitored annually. If
there are several stages of processing in different plants or
even different countries, each stage must be audited to ensure
that wood that is claimed to be FSC certified, is in fact
genuinely FSC certified and originates from a specific
certified forest. Any FSC-labeled product will have a chain of
custody certificate number on the label and this can be used
to identify the certificate holder in the event of a question
arising. If the minimum-percent approach is used, the label
should specify what the percentage is.
Footprints in the forest
Forest Stewardship Council (FSC)
49
Chain of custody procedures
The current chain of custody system is based on two
approaches:
a) minimum percentage input and b) segregation.
â
Approach a) means that if a minimum percentage of FSC
certified material enters the product chain, the full output
from this process can be labelled as FSC certified â with
the relevant percentage of certified material specified on
the label. FSC accepts that the FSC label is used on
products that contain less than 100% FSC-certified virgin
wood or fibre, with the balance being made up of some
combination of non-certified (and uncontroversial or
controlled) virgin wood or fibre, reclaimed/recycled wood
or fibre, or non-wood fibre. The threshold for labelling
products that contain less that 100% FSC content vary for
different product categories i.e., chip and fibre products
such as paper or chip board, assembled products such as
veneers or solid wood products e.g., logs or planks.
â
Approach b) means that certified timber is kept separate
from non-certified timber, via physical separation,
marking, etc.
The current process is under review and a new proposal has
been developed. Under the new proposal, which is not yet
approved, an input-output volume credit system is envisaged.
This proposal, currently being pilot tested with sawn-wood
products, would allow a sawmill to label an equivalent
volume of sawn timber (finished product) as the volume of
FSC certified logs (raw material) it processes. In this system at
least 10% of the logs must originate from FSC certified
forests. This new draft standard is accompanied by new labels:
labels for premium forestry (100% certified), verified forestry
(solid wood products from the volume credit system), and
verified blend (assembled products, chips and fibre products,
and products containing volume credit and recycled
material). At the time of writing, the FSC was still evaluating
this proposed new labelling system.
47
It is envisaged as part of
the trial that 100% post-consumer recycled material will be
allowed to carry the FSC label.
Policy on controversial sources
All certificate holders producing products that contain less
that 100% FSC certified material are required to exclude
controversial wood from their FSC product lines. No product
carrying an FSC label should, therefore, include wood from
what the FSC describes as âcontroversial sourcesâ The FSC
defines
â
controversialâ as wood that is: illegally harvested;
from genetically modified trees; from areas where traditional or
civil rights are violated; from uncertified high conservation
value forests; or from endangered forestsâ
48
The FSC has
produced a âsample company policyâ, which gives guidelines to
companies on how to deal with controversial sources. The
FSC currently relies on the companies themselves to take
âreasonable measuresâ to ensure that its wood is from non-
controversial sources. As part of its review of chain of custody
standards, the FSC is developing more stringent require-
ments, and renewed guidance for companies and certification
bodies to ensure that any non-certified wood in FSC product
lines is controlled.
Footprints in the forest
Forest Stewardship Council (FSC)
50
Programme for the Endorsement of
Forest Certification Schemes (PEFC)
Based on a report by Elisa Peter
1 History and characteristics
Creation
The PEFC was set up between 1998 and 1999 by the national
forestry interest groups â mainly associations of small-forest
owners in several European countries as the Pan European
Forest Certification Scheme. The scheme is governed by the
PEFC Council, which consists of representatives of national
certification schemes
49
and are the PEFCâs members. All of the
other forest certification schemes examined in this report,
with the exception of the FSC, are members of the PEFC
Council. The PEFC is not a single certification scheme with a
single standard, but a programme for the endorsement of
national certification schemes. The PEFC Council has so far
endorsed 13 European schemes.
50
Many other European
schemes, and five non-European schemes are expected to put
their national schemes forward for endorsement.
51
Once these
non-European schemes are adopted, the PEFC will no longer
be a European scheme. It has prepared for this change by
renaming itself as the Programme for the Endorsement of
Forest Certification Schemes.
Funding
The PEFC is funded by its members through membership
fees.
Motivation
The scheme was created by a group of small-forest owners
and parts of the timber industry who felt the FSC did not
address their needs and was dominated by NGOs. The
purpose of the scheme was, âto establish an internationally
credible framework for forest certification schemes and
initiatives in European countries (in first instance) which will
facilitate mutual recognition of such schemesâ.
52
Coverage
Schemes under the PEFC umbrella can certify at regional
Footprints in the forest
Programme for the Endorsement of Forest Certification Schemes (PEFC)
European beach forest
Photo: Daan van Beek
51
level, at forest management unit (FMU) level, or issue a group
certificate. All current PEFC schemes certify at the regional
level with the exception of Sweden, Norway and Switzerland,
which certify the Forest Management Unit.
53
Amount of hectares certified
In the 13 countries that have PEFC approved certification
schemes, a total of 48.6 million ha have been certified. It is
unknown how small or large the forest holdings are that have
been certified.
54
Label and chain of custody
There is a label and chain of custody available.
2 Quality of the standard
Performance or system
All PEFC approved schemes have developed a national
standard. To be accepted as a PEFC scheme, this standard
should be based on the âPan European Criteria for Sustainable
Forest Managementâ or criteria developed by other regional
processes, such as the Montreal Process, or the International
Tropical Timber Organisation (see page 16 for an explanation
of these processes). These criteria are not performance-based.
Instead, they were developed by governments to monitor and
report on the status of forests at the national level. They were
not developed to assess any performance level. It is, therefore,
not surprising that the 13 different schemes so far approved
by the PEFC Council have widely diverging standards. Some,
such as Sweden, are clearly based on performance, but most
of them, with France being the clearest example, are system-
based standards, which do not specify a minimum
performance level that needs to be met before a certificate is
awarded. A recent improvement within the PEFC system is
that more emphasis is put on the Pan European Operational
Level Guidelines (PEOLG) â which now form the reference
for the adoption or revision of national certification
standards. The PEOLG include more performance-based
criteria.
Quality
The environmental performance of the different PEFC
national standards varies enormously from high environ-
mental performance, such as in Sweden, to virtually no
environmental performance requirements, such as in France.
The PEFC Council has made the ILO core labour standards
obligatory. Therefore all national standards will have to
incorporate these seven standards in their national standard.
55
There is no such requirement to recognise the land or user
rights of indigenous peoples (which is in line with ILO 169),
or those of local communities.
Comments
In all PEFC standards, indigenous rights are not recognised.
This is of particular concern, as PEFC will soon incorporate
tropical schemes where the indigenous rights and land rights
issues are of great concern. The PEFCâs failure to recognise
the land rights has already caused problems for the Sami
people in Scandinavia.
3 Standard-setting procedures
Who is involved?
The process of development of a standard is initiated by
national forest ownersâ organisations,
56
which have to create a
Forum of all interested parties. The parties should represent
the different aspects of sustainable forest management and
include forest owners, forestry industry, environmental and
social NGOs, unions, retailers and other relevant organisa-
tions. The views of the national forest ownersâ organisations
have to be documented and considered in an open and
transparent way. Some national governing bodies decide by
reaching a consensus, others by a voting procedure.
Once a standard-setting process has started, this has to be
communicated to the public â the final draft is sent out for a
formal national consultation process lasting 60 days.
Although environmental and social groups can be part of a
national governing body, in most cases NGOs have refrained
from participating in the PEFC standard-setting processes.
The exception to this is France, where a large coalition of
environmental NGOs has been part of the standard-setting
process, and is currently actively participating in regional
PEFC processes. In other countries (e.g., Germany and
Latvia) small environmental and social NGOs are partici-
pating in the standard-setting processes, but no large environ-
mental organisations have been involved.
Once a national standard has been developed and approved
by the National Governing Body, it is submitted to the PEFC
Council for endorsement. The Council then assesses the
standard (and the other elements of the certification scheme).
The assessment compares the scheme with the PEFC Council
requirements in relation to certification standards, standard-
Footprints in the forest
Programme for the Endorsement of Forest Certification Schemes (PEFC)
52
setting procedures, scheme implementation procedures, chain
of custody standards and certification procedures. A checklist
of minimum requirements is available. The assessment is
carried out by a consultant, starting formally after the
national scheme has been submitted for endorsement, and a
press release has been issued by the PEFC Council to allow
for comments to be received.
If the assessment is positive, the Council endorses the scheme.
As all existing endorsed schemes are Council members, this
means in effect that schemes vote for each other to be
included in a âmutual recognitionâ agreement. In theory,
assessment reports are publicly available from the National
Governing Body, but this is not always the case in practice.
Is balanced participation required?
The PEFC Council encourages consultation of all interested
parties during the standard-setting process at the national
level. In all existing PEFC schemes, decision-making power
rests largely with the forestry industry and forest owners
during standard-setting, as well as system development and
maintenance. Even where social or environmental NGOs
participate, the distribution of voting power is such that they
can always be overruled by the joint votes of the forest owners
and forestry industry.
4 Certification process
Who does what?
As the rules set by the PEFC Council are minimal, the certifi-
cation procedure is mainly developed by the certification
body. The certification procedure is required to fulfil relevant
ISO Guidelines.
57
The vast majority of the PEFC-endorsed
schemes certify at the regional level with whole regions
certified in one go. Although the procedures and terminology
vary slightly from country to country, a regional certificate is
usually issued by a third party certifier to a regional applicant
entity, which qualifies all forests in that region for the certifi-
cation process. Once a region is thus âcertifiableâ, forest owners
have to take an active step in order to join the regional certifi-
cation by signing an agreement with the regional entity. Only
the forests of those forest owners who commit themselves to
respecting PEFC minimum requirements (by signing the
agreement), are considered as certified forests. In Sweden,
field visits are mandatory before a forest can be certified, but
this is not the case in France and Germany.
As most PEFC-endorsed standards are system-based
standards and lack clear performance-based requirements, the
certification process is logically based on a process that
focuses on assessing documents provided by the applicant
rather than on an evaluation of forestry practices on the
ground. Regional and individual applicants alike undertake
certain commitments in regard to environmental aspects of
forest management, but most of these are system-, rather than
performance-based.
Stakeholder consultation required
Stakeholder consultation during the certification process is
not required, although some national schemes have carried
out stakeholder consultations.
Monitoring
Surveillance audits take place once a year, but are on a
random basis â which means that not all holdings are audited
every year. All certificates need to be re-assessed every five
years.
Complaints procedure
All PEFC-endorsed schemes are required to establish an
independent dispute settlement body that takes care of
complaints arising from scheme implementation, or certifi-
cation procedures that cannot be addressed in the dispute
settlement procedures of the relevant accredited certification
body.
Responsibility for the handling of complaints is usually
divided between the accreditation body, the certification body
and the PEFC Council. The accreditation body usually has
procedures in place to handle complaints regarding the
accreditation process, but nothing specific for accreditation of
PEFC certification bodies. Certification bodies are also
required to have mechanisms in place to deal with
complaints. However, since neither accreditation reports nor
certification reports are publicly available, it is difficult for a
third party to bring forward complaints. The very few
complaints made so far have therefore come from applicants.
5 Transparency
Are summary reports available?
Neither full certification reports nor summaries are available,
or even made available to interested parties on request. None
of the national PEFC web sites visited contained any
Footprints in the forest
Programme for the Endorsement of Forest Certification Schemes (PEFC)
53
assessment or summary reports, with the exception of
Germany.
58
PEFC Sweden plans to publish summary reports
on the internet from the beginning of 2004.
Are standards and procedures available?
The standards and the basis for assessing certification
schemes are available, as are general policy requirements.
Minutes of the General Assembly are not available to non-
members, although the PEFC secretariat states they are
âwidely availableâ as many members distribute them widely in
their country.
59
6 Label protection and chain of custody
Label use
PEFC has a logo that can be used with or without the
following claims, âfrom sustainably managed forestsâ, or,
âpromoting sustainable forest managementâ See below for
requirements for each claim.
Chain of custody procedures
There are currently over 600 chain of custody certificates
awarded, and this amount is forecast to increase dramatically.
The chain of custody certification is currently based on the
following three approaches:
I
inventory control and accounting of wood flows via a
âpercent in - percent outâ system.
II
inventory control and accounting of wood flows via
minimum average percentage system.
III
physical segregation.
Using the input-output option of the first approach means
that when a known percentage of PEFC certified wood enters
into processing, the same percentage of the production
output is considered certified. The minimum average
percentage option means that a total batch of products can be
labelled as certified, when the amount of certified wood in
the input batch exceeds 70% by volume or by weight. The
third, physical segregation, approach means that certified
timber is kept separate from non-certified timber. Only when
this third approach is used can the claim, âfrom sustainably
managed forestsâ be made. When approaches
I
) or
II
) are used
only, the claim, âpromoting sustainable forest managementâ is
allowed.
Policy on controversial sources
All schemes are required to demand from all suppliers of raw
wood materials or purchased products at least a signed self-
declaration that the supplied raw material or products do not
contain any wood raw material from controversial (i.e.,
illegal) sources. This is implemented in Sweden, which also
includes wood from key biotopes as a controversial source,
but no evidence was found of other schemes having similar
policies.
Footprints in the forest
Programme for the Endorsement of Forest Certification Schemes (PEFC)
54
Sustainable Forestry Initiative (SFI)
Based on a report by American Lands
1 History and characteristics
Creation
The Sustainable Forestry Initiative was launched in 1995 by
the American Forest & Paper Association (AF&PA). The
AF&PA is the predominant national trade association for the
U.S. wood and paper industry. AF&PA members control the
majority of the U.S.â industry-owned forests, and account for
a large percentage of the wood products manufactured in the
U.S. All AF&PA member companies are required to
participate in the SFI program. SFI is also open to non-
AF&PA participants called licensees that manage forests in the
United States and Canada, such as local government entities,
land trusts, and Canadian companies. Together all SFI partici-
pants control over 40,485,830 ha of forests in the United
States and Canada. The SFI is a member of the PEFC
Council.
Funding
SFI is funded principally by the SFI programme participants.
Motivation
The programme was developed in response to public
concerns about the forest products industryâs environmental
performance. AF&PA research on public perceptions found
that the public felt industry was not protecting wildlife, lakes
and streams, preserving wilderness, or practising sustainable
forestry. Clear-cutting was a major concern. The AF&PA
established the SFI to overcome these negative public
perceptions, and to promote awareness of things the industry
felt it was doing well, such as replanting.
Coverage
SFI certification usually occurs at the company or landowner
scale, although companies can certify only part of their
forests. The average size of SFI certified forests, across both
the U.S. and Canada, is 705,104 ha.
60
Roughly one fourth of
AF&PA member companies and SFI licensees have had their
operations SFI certified. The AF&PA has also begun to
address non-industrial private forestlands in the U.S. by
âmutually recognisingâ the American Tree Farm System
(ATFS), a programme of the American Forest Foundation to
educate and recognise the management of private forest
owners in the US. There are 65,549 certified tree farms
covering 26 million acres, approximately 60% of forest land
in 48 states.
Amount of hectares certified
As of July 2003, 43 companies and landowners had
17,714,505 ha certified under the SFI in the U.S., and
12,604,971 ha certified in Canada. Most SFI certified entities
are large, integrated wood products companies, while a few
are smaller wood products companies, timber investment
management organisations, state forests, or university forests.
Label and chain of custody
The AF&PA now allows SFI certified companies to label their
wood and paper products as being from an SFI certified
company. According to the SFIâs office of label use, as of April
2003, over 20 companies were authorised by the AF&PA SFI
to use this label. The AF&PA also allows companies to make
other marketing and public relations claims in connection
with SFI participation. The SFIâs wood procurement
standards lack most elements of a chain of custody system.
2 Quality of the standard
Performance or system
The SFI standards are divided into 6 principles, 11 objectives,
and a large number of performance measures, core indicators,
and non-core indicators. The SFI standard and certification
process emphasise evaluation of system-based measures and
Indicators, rather than field performance-based measures and
Indicators. To be certified, forestry operations must address a
subset of âcore-indicatorsâ. These indicators focus largely on
system-based measures that can be assessed in an office rather
than in the field. The use of all other SFI verification
indicators remain discretionary. Only about two-dozen of the
SFIâs 154 performance measures and core indicators require
companies to produce specific on-the-ground outcomes.
Examples of the SFI performance measures and core
indicatorsâ more concrete requirements include: limitation of
individual clear-cut units to an average of 120 acres and
replanting within 2 years of logging.
Quality
The SFI standards do not address social issues. While the
introduction to the SFI standards and procedures reference
an expectation that companies will comply with laws,
Footprints in the forest
Sustainable Forestry Initiative (SFI)
55
including those relating to social issues, there are no specific
performance measures or indicators in the SFI standard to
assess performance with respect to social issues such as
respect for indigenous peoplesâ rights and requirements to
meet ILO standards. The SFI standards are very weak with
regard to most ecological issues. As a consequence, a number
of SFI certified companies continue to log old growth and
endangered forests, eliminate rare and endangered speciesâ
habitats, replace natural forests with tree plantations and
residential sprawl, and clearcut and apply chemicals at
excessive and unnecessary levels. The SFI standard does not
adequately or consistently require companies to maintain
natural forest ecosystems. Nor does it require any habitat
restoration on larger properties to help support imperiled
speciesâ recovery.
Comments
Under the SFIâs certification procedures, participants are
granted significant flexibility to tailor the standard and define
the indicators that will be used to assess the forest
management. Although there is an expectation that company
forest managers and certifiers will address a set of core
indicators â providing some measure of consistency and
replicability to the standard â company forest managers (and
certifiers) are also encouraged to customize the standard for
each applicant in order to address local conditions. This
includes altering core indicators that are not considered
appropriate, writing new indicators, and/or selecting which, if
any, of SFIâs other optional indicators to use. One SFI certifi-
cation report states that âdiscretion is provided to forest
managers as to the specific performance criteria for the
majority of indicatorsâŠ.â
61
.
Furthermore, many of the âcoreâ
indicators required for certification do not require assessment
of field-level performance. Consequently, the SFI standard
fails to require a consistent benchmark for environmental
performance. One companyâs field performance under the SFI
may mean something very different from another, yet both
can claim compliance with the SFI standard, and receive the
same certificate.
Footprints in the forest
Sustainable Forestry Initiative (SFI)
This was Murrelet Grove on Pacific Lumber Company Land, SFI certified
Photo: www.dontbuysfi.com
56
3 Standard-setting procedures
Who is involved?
The SFIâs standards and procedures were largely developed
and approved by industry for industry, rather than by a
balance of environmental, social and economic interests. To
develop the SFI standards and procedures, the AF&PA
established a forest resources task force in February 1994,
which hosted regional workshops to gather input from
AF&PA members and allied organisations. In October 1994
the AF&PA board formally approved the SFIâs first set of
standards. Limited changes to the standards were made in
1998,1999 and 2000.
62
The AF&PA Board approved the 2000
Edition of the SFI Standard in July 2000 after review by
AF&PA members, the SFIâs Expert Review Panel, consultants,
and other invited parties.
63
In July 2000, the AF&PA
appointed a Sustainable Forestry Board (SFB), which has
governed more recent changes to the SFI Standard. The SFB
completed two rounds of revisions in August 2001 and June
2002, resulting in the current 2002-2004 version of the
standard. In 2004 the SFB is embarking on a third revision
expected to produce a new standard in 2005.
AF&PA established the SFB to help manage, evaluate and
improve the SFI standard and procedures, and monitor and
resolve non-compliance. AF&PA appointed three conser-
vation/environmental organisations to the SFB and 11
forestry interests as follows: six AF&PA companies, a logger, a
non-industrial plantation owner, a state forestry represen-
tative, a forestersâ representative, and a university forestry
department representative. The SFB does not include social
interests. AF&PA later dropped an AF&PA company and
added a conservation and a university representative, bringing
the total to 15 members, two thirds of whom represented
forestry interests. In January 2002, the SFB became an
âindependentâ non-profit body, responsible for revising the
SFI standards, subject to AF&PAâs endorsement. AF&PAâs
board endorsed the SFBâs most recent revisions on 26 June
2002. The power to appoint new SFB members now rests with
the SFB. While the SFB includes five conservation groups, it
remains dominated by forestry interests.
Is balanced participation required?
Balanced participation of environmental, social and economic
interests is not required. The standards have essentially been
set through industry dominated processes. While partici-
pation of conservation and environmental groups has
improved with the establishment of the Sustainable Forestry
Board, this Board is not balanced and truly independent, or
accountable to broader and more balanced stakeholder
bodies. The majority of board members represent forestry
interests that were originally appointed by the AF&PA. The
SFB does not include social interests.
4 Certification process
Who does what?
The SFI certification applicant has considerable influence
over the certification process. The SFI program procedures
allow the certification applicant to work with the certification
body to tailor the scope, location and extent of the audit, the
audit plan, the audit team and the audit report content.
64
Participants define their own corrective actions. There is no
stakeholder consultation or public input process. A control
audit will take place within three years, and every five years
thereafter.
The certification process involves the following basic steps:
â
the forestry company that wishes to be SFI certified
identifies and hires a certification body that meets the
SFIâs accreditation requirements;
â
the forestry company decides which of its forests to have
assessed;
â
the forestry company and the certification body agree
upon which elements of the SFI standards to use for the
assessment i.e., develop the standard;
â
the certification body assesses the forestry companyâs
performance under the defined standard, using some
combination of a review of the companyâs policies, plans,
and on-the-ground practices;
65
â
the certification body decides if the company meets the
SFI standard;
â
the company and certification body agree upon any
corrective actions that may be required;
66
â
the certification body and the company write a certifi-
cation report;
â
the certification body conducts re-assessments in
subsequent years.
Is stakeholder consultation required?
SFI certifiers are not required to consult with knowledgeable
scientists, conservation organisations, community groups,
and others likely to have independent knowledge of the wood
product companyâs management practices and their impacts.
Nor are SFI certifiers required to consult with neighbouring
landowners, downstream water users, fishing groups, and
others potentially impacted by the companyâs practices.
Footprints in the forest
Sustainable Forestry Initiative (SFI)
57
Monitoring
Initial re-verifications are to occur within three years of the
original certification. Subsequent re-verifications may happen
as infrequently as every five years. âPeriodic surveillance
auditsâ of unspecified intervals are also required for
companies using an on-product SFI label. These latter audits
are more cursory in nature.
Complaints procedure
The Verification/Certification Principles and Procedures
clause establishes limited procedures for appeals of certifi-
cation decisions by outside parties. The ultimate arbiters of
appeals over individual practices are the SFIâs State
Implementation Committeesâ Inconsistent Practices
Programs, or the AF&PA SFI National Inconsistent Practices
office. The ultimate arbiters of appeals over entire certification
decisions are the SFBâs Certification Appeals Subcommittee
and, potentially, an SFI Ad-Hoc Certification Review Task
Force. There is anecdotal evidence that the SFI State
Implementation Committees may lack sufficient independence
from SFI certified companies.
67
Equally important, it is
questionable whether the SFI standards contain sufficiently
clear threshold (or, âbottom-lineâ) requirements to engender
appeals in the first place. As noted by NRDC (2001),
68
the lack
of concrete information in public summary reports, and the
lack of public access to private timberlands will also make it
difficult to appeal SFI certification decisions.
5 Transparency
Are summary reports available?
Although the SFI policies require written certification reports
for companies that are certified, these same policies also state
that, â[ ] all information related to the SFI verification is the
sole property of the Program Participantâ, and that the, â[âŠ]
Participant will determine the distribution of the verification
report or summaryâ. Public summaries of the certification
reports are only required when companies wish to make
public claims regarding their certification. However, up to
date public summaries are not provided at the SFI website, or
at the website of the certification bodies. They are also not
available upon request from the certification bodies. To
obtain reports, interested persons must make a request to the
company that was audited.
As the summary reports are written by both the forestry
company and the certification body their independence and
objectivity can be questioned. The only substantive content
requirement for SFI public summary reports is a list of the
indicators used and a summary of findings. This means that
in practice, the quality of SFI public summary reports varies
considerably.
69
6 Label protection and chain of custody
Label use
AF&PA controls all decisions about the SFI label and its use.
SFI program participants must apply to the AF&PAâs Office of
Label Use & Licensing for permission to use the label. There
is one label for those mills that receive most of their raw
material directly from the forest (âPrimary Producersâ).
There is a second label for mills that run largely processed
wood (âSecondary Producersâ).
Chain of custody procedures
70
AF&PA does not use a traditional chain of custody system as
a basis for product labelling; its does not require segregation
and tracking of SFI certified wood from the forest through
manufacturing and labelling to assure the certified content of
labelled products. Instead SFI has a wood procurement
accountability system. For product labelling and claims,
AF&PA requires all wood used by primary producers (i.e.,
forest managers) and two-thirds of wood used by secondary
producers (i.e., manufacturers) to come from sources
(certified and non-certified) that are allowable under AF&PAâs
SFI On-Product Label Use Requirements and SFIâs standards
governing non-SFI wood procurement by SFI certified
companies.
Allowable sources (and sourcing policies and systems) are
broadly defined. They include:
â
wood from SFI certified forests;
â
recovered wood fiber;
â
wood from plantations and forests outside of the United
States and Canada that: (
I
) buyers recognize as well
managed according to generally accepted practices, and
(
II
) are not illegal according to SFIâs definitions and
indicator for company âprocurement policies that
contribute to elimination of illegal logging.â Furthermore,
such sources should not conflict with SFIâs indicator for
company âprocurement policies that promote conservation
in biodiversity hotspots and major tropical wilderness
areasâ identified by the SFB. The policies are expected to
help conserve, not preserve, such forests;
Footprints in the forest
Sustainable Forestry Initiative (SFI)
58
â
wood from non-industrial private forest owners who are
certified by the American Tree Farm system â a deficient
system whose standards do not even encompass most of
SFIâs requirements and lack most basic protection
measures for environmental and social values.
It appears that wood from non-certified non-industrial
private owners is also allowable as long as SFI participants
follow the indicator to âencourage [not require] landowners to
reforest following harvest and to use Best Management
Practicesâ and have a system to evaluate whether progress is
made. Furthermore, the AF&PA Guidance Document on Wood
Flow Accounting and Legality, May 2003, suggests that wood
from âconversionsâ also might be allowable.
The SFIâs performance measures ask companies to ââŠclearly
define and implement their own policies to ensure that mill
inventories and procurement practices do not compromise
adherence to the Principles of Sustainable Forestry.â The core
indicators also ask companies to have âprocurement policy in
place for the purchase of raw material from qualified logging
professionals, wood producers and other wood suppliers.â
Independent third party certifiers must check that SFI
certified companies have procurement policies and systems to
buy from allowable sources, although there is no written
requirement that certifiers actually assess the sources or the
chain of custody from them to the SFI company. This is called
a having a third party certified procurement system in
conformance with the SFI. As long as wood originates from
third party certified SFI producers, and/or third party
certified procurement systems for non-certified wood, it may
be labelled. The SFI does not require certification labels to
indicate the percentage of wood batches that are actually from
SFI certified forestlands
Comments
Under SFIâs third party certified wood accountability and
procurement system, as much as 100% of a batch of wood
carrying the SFI label may originate from a broad range of
forests that are not managed to the SFIâs full set of standards,
without any indication of this on the product label. Thus, the
concept of SFI certified and labelled products is confusing
and misleading to consumers. Although it provides an extra
measure of accountability about wood sources, the SFIâs
wood procurement system allows labelling of status quo or
near status quo wood supplies.
The Australian Forestry Standard
(AFS)
Based on a report by Tim Cadman
1 History and characteristics
Creation
The Australian Forestry Standard was established as a joint
initiative between the Ministerial Council on Forestry,
Fisheries and Aquaculture (renamed as the Primary
Industries Standing Committee of the Primary Industries
Ministerial Council) and the forestry industry â represented
by the National Association of Forest Industries (NAFI),
Plantation Timber Association of Australia (PTAA) and
Australian Forest Growers (AFG) â with secretarial support
provided by the Federal Governmentâs Department of
Agriculture, Forestry and Fisheries. A company, AFS Limited,
was created on 23 July 2003 and manages the AFS along with
other components of the Australian forest certification
scheme. The AFS is a member of the PEFC and has submitted
its scheme for assessment to become a PEFC endorsed
scheme, and enter into a mutual recognition agreement with
the other 13 PEFC endorsed schemes.
Funding
The development of the scheme is funded in equal parts by
the participants to the Primary Industries Standing
Committee of the Primary Industries Ministerial Council, i.e.,
the Commonwealth and the State and Territory
Governments, and the peak forest and timbers industry
bodies i.e., NAFI, PTAA and AFG.
Motivation
The reasoning behind the creation of the standard is
described on the AFS website as: âBuyers of timber, like buyers
of other goods such as food and clothing, are becoming more
interested in where the product they buy comes from, and how
it has been produced. In order to satisfy this interest, timber
producers around the world have begun to investigate various
systems of independent certification of forest management. The
Australian Forestry Standard (or âAFSâ) applies community
values and the science of forest management to identify the
economic, social, environmental and indigenous criteria that
are most important for assessing whether a forest is well-
managedâ.
71
Footprints in the forest
The Australian Forestry Standard (AFS)
59
Coverage
The standard covers all forest types and land tenures, small,
medium or large. A provision for group certification of forest
owners is part of the system.
Amount of hectares certified
One certificate has been issued to the company Gunns ltd.
The certificate covers approximately 220.000 ha.
72
Label and chain of custody
There is no label available as yet. A process for labelling and a
chain of custody standard has been prepared and is currently
under consideration for recognition as an Australian Standard
by Standards Australia. AFS Limited has a logo, which can
also be used as a label. Labelling rules are under development
for use in 2004.
2 Quality of the standard
Performance or system
There is one standard that will be interpreted regionally,
based on state- and territory-specific regulations. The
standard is a combination of largely system-based criteria,
with some performance-based, prescriptive measures
included. The criteria are based on the international govern-
mental system-based criteria contained in the Montreal
Process for the conservation and sustainable management of
temperate and boreal forests (see page 16). Furthermore,
national and regional agreements and state specific
management guidelines form part of the standard.
Quality
As stated above the standard is based on the Montreal Process
and interpreted in a regional context via the National Forest
Policy and Regional Forest Agreements. As there is consid-
erable divergence as to how forests are managed regionally by
state governments, management procedures and guidelines
vary considerably. The standard is, therefore, open to consid-
erable interpretative flexibility â including different targets for
soil and water conservation, use of chemicals and conser-
vation of rare species.
The standard claims to be inclusive of social, spiritual,
environmental and economic values. Nonetheless, environ-
mental NGOs withdrew from the process because they believe
the standard does not include these values. Environmental
organisations were not able to progress beyond concerns
regarding the processes of the AFS and resigned before any
substantive progress was made in addressing environmental
concerns. Environmental concerns with the current draft
standard refer to the use of clear felling, chemical use (partic-
ularly the native wildlife poison 1080), logging of old growth
forests, and the conversion of native forests to plantations.
Indigenous peoples were represented on the AFS Technical
Reference Committee via the peak body ATSIC (Aboriginal
and Torres Straight Islander Commission).
Comments
The standard has been heavily criticised by a number of
environmental NGOs in Australia for not addressing key
environmental concerns, and certifying âbusiness as usualâ
forest practices including the conversion of native forests to
plantations, the use of GMOs etc.
73
AFS states it will review
some issues in the first review period including the use of
GMOs and carbon sequestration.
74
3 Standard-setting procedures
Who is involved?
The structure, composition and terms of reference for the
AFS were originally developed by the government and the
forestry industry. A technical reference committee was subse-
quently established comprising ten people representing the
forestry industry and nine people representing other interests,
including community and consumer interests, scientists, regu-
latory or controlling bodies and forest owners and processors.
In the early stages, the development of the standard occurred
without the involvement of environmental NGOs or
Indigenous Peoplesâ Organisations. In a second phase two
representatives of the environmental movement participated
in the committee responsible for the development of the
standard. These were WWF and the Native Forest Network
Australia (representing itself and six other environmental
NGOs). They stated consistently that their full participation
was contingent on restructuring the AFS to make it more
inclusive. After repeated attempts to renegotiate the structure
it became apparent that this was not going to change, and
these NGOs withdrew from the process.
Comments
Subsequent to their withdrawal from the AFS process, the
AFS website continues to carry information that implies that
environmental NGOs are still associated with the AFS.
75
There
Footprints in the forest
The Australian Forestry Standard (AFS)
60
seems to be some confusion within the AFS about the
difference between the development of national or regional
forest programmes, policies and the development of a certifi-
cation standard, considering the following statement:
âPublic consultation and participation is an integral part of
developing legislation, policies and plans for the manage-
ment of Australiaâs publicly owned forests. In all states there
are formal public consultation and participation processes
to ensure that the interests and opinions of the community
are considered in the forest management planning processâ.
76
Is balanced participation required?
As indicated above, there is no requirement for balanced
participation. No equal weight is given to environmental,
social and economic interests.
4 Certification process
Who does what?
The certification body uses the generic standard of the AFS
and takes regional (State or Territory) regulations into
account. The standard itself is generic enough to permit this.
The forestry company approaches a certification body, which
will ask for some basic information to provide a quote and a
formal proposal. A pre-assessment might take place. When a
forest owner is ready to process with certification they
complete a formal application form, and agree a fee with the
certification body. The certification body carries out an initial
visit and confirms the audit plan is appropriate, that the team
has the right competencies and that the system is ready for an
audit. During the audit the certification body evaluates the
management of the forest against the requirements of the
certification standard. If the audit is positive a certificate will
be issued. The certification body will check the certificate
holder to ensure continued compliance with the standard.
They will also check that corrective actions the forest owner
was asked to carry out have been completed.
It is unclear under which corrective actions a certificate can
still be issued, and when corrective actions are too big for a
certificate to be issued. The documentation makes a
distinction between major non-conformances â when forest
Footprints in the forest
The Australian Forestry Standard (AFS)
Management practices permitted under AFS standard
Photo: Native Forest Network
61
management is failing to meet a relevant requirement â and
minor non-conformances â when forest management is
partially failing to meet a requirement, or there is a risk of a
requirement not being met. If a major non-conformance is
found, no certificate can be awarded until the requirement is
met. If there is a substantial time-lag before the major non-
conformance is addressed, a new audit may be required in
order to achieve certification.
Is stakeholder consultation required?
Requirement for consultation or participation of NGOs and
local communities in the certification process are unclear, as
is guidance given on how consultation should take place. The
AFS states the following on participation: âIn general, partici-
pation in certification should be fostered. However, the level of
participation should be appropriate to the particular stage of
the certification process, with broader stakeholder involvement
during establishment and dispute resolution stages, and
narrower representation during accreditation and certification
stagesâ.
77
Monitoring
There is an annual surveillance audit and certificates are to be
reassessed at three yearly intervals.
78
Complaints procedure
The final draft standard states that procedures for dealing
with complaints and disputes could include issues such as:
identification and recording of complaints and disputes
received; a mechanism for substantiation of complaints and
disputes, and identification of immediate and longer-term
corrective and preventative actions; documentation of
agreements reached to resolve disputes; and documentation
of corrective and preventative actions taken and assessments
of their effectiveness.
79
It is, however, not clear if a complaints
mechanism is in operation or planned, nor indeed, how it
would work.
5 Transparency
Are summary reports available?
Unknown.
Are standards and procedures available?
Although the scheme claims transparency,
80
transparency was
considerably hindered by the fact that the current official
âinterimâ standard accredited by Standards Australia was, up
to the moment this report went to print, not freely available.
It was only available for purchase. This has, however, now
been rectified as the standard is now available on
www.forestrystandard.org.au/where.html
6 Label protection and chain of custody
Label use
There is a label in preparation and label rules are under
development for use in 2004.
Chain of custody process and main requirements
A draft (18/08/03) chain of custody procedure is available,
81
and is very similar to that of the PEFC. There are two
different approaches to the chain of custody companies can
choose under the AFS:
a
an inventory control and accounting of raw material flow
option;
b
a physical segregation and/or marking of raw material
option.
Option a) incorporates two approaches, an input-output
system for solid wood, or a minimum average percentage for
composite products. The minimum percentage should not be
less than 70% by volume or weight for all wood or forest
products, including solid wood, assembled goods, pulp and
paper, woodchips and fibre. This percentage can include also
timber from forests certified under other (not specified) certi-
fication schemes.
Comments
The scale of chain of custody verification under the AFS goes
beyond the products and the AFS allows for market claims to
be made through chain of custody certification to a batch of
products (or a single product), a single production unit (or
plant, site, facility or line) and a whole organisation operating
within a region or at national level.
Policy on controversial sources
The draft policy states that organisations shall ensure that no
wood raw material known to be from illegal sources enters
any stage of the certification chain. The organisation shall
document the origins of wood raw material or forest
products to demonstrate that steps have been taken to
confirm the legal status of the products.
Footprints in the forest
The Australian Forestry Standard (AFS)
62
Sistema Brazileiro de Certificação
Florestal (CERFLOR)
Based on a report by Cristina Soutelo Soeiro
Timmer
1 History and caracteristics
Creation
The first concept of CERFLOR was presented in 1991 at the
World Forestry Congress in Paris, by the Brazilian Silviculture
Society, a private forestry organisation. Originally initiated by
the private sector, the concept slowly obtained support from
research and governmental institutions, developing into the
Brazilian governmentally accepted scheme for certification of
forest management. In August 2002, the Ministry of
Development, Industry and Trade (MDIC) officially launched
the scheme, in the presence of five other Ministries. It became
operational in March 2003.
The scheme is managed by INMETRO â The National
Institute of Metrology, Normalization and Industrial Quality
â which is also responsible for accrediting certification bodies.
ABNT (Brazilian Association of Technical Norms), a private
body recognised by the government as the National Forum
for Normalisation, is responsible for co-ordinating the estab-
lishment and revision of the CERFLOR rules. These rules are
developed in working groups, with representatives of different
sectors of society. In November 2002, CERFLOR became a
member of the PEFC Council, with the aim of having its
standard endorsed by the PEFC.
Funding
The development of the scheme was partly funded by ITTO.
It is unclear who funds the current scheme.
Motivation
The expansion of FSC in Brazil has stimulated a movement
by some forest industry leaders, dissatisfied with FSC
standards, to create a set of national standards for certifi-
cation of forest management and chain of custody systems
(CERFLOR). The private forestry sector together with the
Brazilian Government, therefore, developed a system, âthat
would satisfy both consumers and producers of forest
productsâ.
82
Coverage
The scheme intends to certify both plantations and natural
forests in Brazil, but certification is currently only possible for
plantations (named âplanted forestsâ). A standard for ânative
forestsâ is still under development. Certification takes place at
the Forest Management Unit level. There is a group certifi-
cation process that makes certification for small businesses
possible. However, this has not yet been tested.
Amount of hectares certified
Currently only one forest management unit of 50,000 ha
Eucalyptus plantations of the company INPACEL
Agrofloresta Ltd belonging to the International Paper Group,
has been certified in ParanĂĄ. Another company, Aracruz
Cellulose, has also initiated the process for certification of an
area of 164,596 ha of Eucalyptus plantations, spread over
eight municipalities.
Label and chain of custody
A label and chain of custody have been developed, but are not
yet being implemented.
2 Quality of the standard
Performance or system
At the moment there is only a standard for the certification of
plantations.
83
A standard for natural forests has been under
development since April 2001. This standard is expected to be
finalised in 2004. The plantation standard has five principles,
each accompanied by criteria (19) and indicators (100).
Principles and criteria are mandatory, indicators can vary
depending on local conditions. The standard is largely a
system-based standard, with very few performance-based
requirements. A lot of emphasis is put on management plans,
monitoring exercises and developing plans for local
communities.
The standard does not have clear minimum performance-
based environmental or social requirements. The social
requirements do not extend beyond what is legally required.
There is no recognition of the requirement of self-determi-
nation of indigenous peoples. The standard does demand
respect for the, â[...] non depleting habits and customs of local
communitiesâ (Indicator 5.1.b), and, â [âŠ]respect for the
rights of use and tenure of land with natural forests by local
communitiesâ (Indicator 1.2). It is, however, not very clear
what the latter means for certification of plantations. There
are no requirements relating to spiritual values.
Footprints in the forest
Sistema Brazileiro de Certificação Florestal (CERFLOR)
63
Quality
The environmental quality of the standard is elaborated
in principles 3 (biodiversity) and 4 (soil and water), but
with a few exceptions (indicators 3.1.a.b.d) all the criteria
and indicators refer to plans, programmes or activities
being in place, rather than specifying minimum performance
levels.
Comments
CERFLOR requires compliance with national legislation.
Principle 1 requires the forest owner/company to fulfil the
requirements of all existing legislation with regard to
environment, forest, social welfare, labour and taxes. Also,
other criteria
84
focus on fulfilling legal requirements before
certification can be granted.
3 Standard-setting procedures
Who is involved?
In March 2001 ABNT, with support from MDIC and
INMETRO, created a temporary committee for the study of
forest management. This committee was put in charge of co-
ordinating the development of the CERFLOR program, and
later became a permanent working group of the Technical
Subcommittee for Forest Management (SCT-CERFLOR). The
draft standard was available on the internet for consultation,
although there is no explicit requirement for public consul-
tation before the standard is finalised. Apparently, some
comments were received and incorporated, but it is not
known what the results were of this consultation.
The plantation standard was developed with the
participation of private sector (55%), researchers and
technical advisers (24%), government (13%), environmental
NGOs (1%) and others (7%).
85
No representatives of social or
indigenous groups participated. The standard was finally
approved by SCT-CERFLOR, with equal voting rights of its
four chambers: producers, consumers, neutrals and regulating
bodies.
There are virtually no environmental NGOs, or representa-
tives of indigenous or local groups involved in the
development of the CERFLOR standards.
Footprints in the forest
Sistema Brazileiro de Certificação Florestal (CERFLOR)
Deforestation in South West Amazon
Photo: José Paulo Genari Tezza
64
Is balanced participation required?
Although it is a requirement of the system to involve different
interests and balance participation of different sectors of
Brazilian society, so far the system is based on economical
interests rather than on social or environmental concerns.
A true balanced public participation was not reached, or yet
sought.
4 Certification process
Who does what?
Certification procedures are detailed by INMETRO
86
and
ABNT,
87
with the latter also specifying the qualifications
criteria for the forest auditor.
88
Certification can be asked by
the company that wishes to be certified or any other legal
body.
After a formal request for certification, the company presents
the relevant documents to the certification body. The certifi-
cation body informs the client of all requirements, and once
satisfied that there is sufficient information available,
adequate resources and support for the audit, accepts the
proposal to do the audit. The certification body then
establishes an Audit Team, and a Certification Committee,
although it is not clear if a different Team or Committee is
created for each process. The criteria
89
for certification bodies
require that members of this Certification Committee should
represent a balance of different interest groups, from environ-
mental and productive sectors, organised civil society and
neutral people. Both Audit Team and Certification
Committee have to be approved by the client. There is no
information available of the composition of the Audit Teams
or Certification Committee in the INPACEL case, or in the
ongoing Aracruz case.
After a pre-audit, an audit plan is developed by the Audit
Team in accordance with the client. The audit consists of an
initial meeting, the collection of evidence (including field
visits and interviews), analysis of the found evidences and a
closing meeting, after which a report is presented to the
client. The results of the audit are released in a summary
report for a limited period of time. At the end of the
stipulated period, the results are analysed by the Certification
Committee, taking into account any comments received.
When the Certification Committee has a favourable opinion
it advises to issue a certificate. The responsibility for
bestowing and monitoring plantation certificates lies with
CERFLOR. The label for chain of custody is controlled by
INMETRO, the body that also monitors certifiers periodically
to evaluate their compliance with accreditation requirements.
Currently, there is only one CERFLOR accredited certifier,
BVQI â Bureau Veritas Quality International.
Is stakeholder consultation required?
Although the certification process is said to be open to âall
interested partiesâ, there is no requirement for consultation of
local people, nor a description of how such a consultation
could take place. In the process of certifying Aracruz, BVQI
has stated that, ârepresentation of civil society is fundamental
for a complete evaluationâ, and has therefore done this in the
form of public meetings where local people were invited to
participate. This invitation was, however, not widely and
timely distributed. Furthermore, Aracruz was also present (as
an observer) making it difficult for people to present their
concerns.
Monitoring
A certificate is awarded for five years, after which it receives
compulsory re-assessment. All certificate holders are to be
revisited in the field once a year.
Complaints procedure
In the case of complaints, the initial appeal should be made to
the certification body. If no solution is found, the complaint
is passed to INMETRO, and in the last instance to
CONMETRO, the National Council of Metrology,
Normalisation and Industrial Quality.
Comments
It is possible to appoint auditors from inside the clientâs
organisation, or ask that those be part of the Audit Team, as
long as they fulfil the conditions and rules of INMETRO, and
do not represent a conflict of interests. The auditor needs to
have done a training course in forest management. Leaders of
an Audit Team need to have four years relevant experience, or
a minimum of two years if accompanied by a post-graduate
qualification in forestry.
5 Transparency
The information with regard to the certification can only be
released with permission of the audited. Certification reports
are considered property of the client, and not for publication.
Draft summary reports are to be released for a minimum of
Footprints in the forest
Sistema Brazileiro de Certificação Florestal (CERFLOR)
65
40 days before the meeting of the Certification Committee,
but are not available afterwards. Also the official documents
are not easily accessible when in development, and once
finalised they are not freely available â needing to be
purchased. Although there is involvement of different groups
of stakeholders in the development of these procedures, it is
mainly based on forestry industry interests.
6 Label protection and chain of custody
The CERFLOR label certifies, âthe forest management unit is
managed according to the principles, criteria and indicators of
forest sustainability ABNT/CERFLOR. With this certificate, the
forest producer can prove that the wood comes from a
sustainable originâ.
The chain of custody requirements states that, âthe control
system must ensure traceability [sic] of the raw material in
each stage of the process in relation to the origin, the quality of
the material coming from each FMU must be registered, the
organisation must ensure that the raw material is identified
and segregated in accordance with the originâ.
90
The chain of custody works on basis of input-output and
requires minimum 70% of raw material certified, in volume
or weight. Material recycled before use can be included in this
minimum percentage, while material recycled after use (from
consumers or factories) can represent maximum 50% of the
final product, in volume or weight.
Policy on controversial sources
There are minimal guidelines for dealing with controversial
sources, such as timber that has been illegally harvested. This
can be found in requirement 9 of the chain of custody control
system: the organisation must ensure that raw material or
products that are not according to requirements be identified,
and controlled to avoid its use or non intentional delivery.
The exact meaning or consequences of this statement is still
to be found, since no chain of custody audit has yet been
performed.
CertificaciĂłn Forestal en Chile
(Certfor)
Based on a report by Sue Hulme
1 History and characteristics
Creation
Certfor Chile is a national certification initiative led by a
non-profit organisation â FundaciĂłn Chile. Created in 1976
to market innovation by a conglomeration of: the Chilean
Government, the US based ITT Corporation, the Instituto
Forestal de Chile (INFOR) â the Chilean Government agency
for forest research and official statistics â and the Chilean
Wood Manufacturers Association (CORMA). CORMA
represents private industrial landowners, but is heavily
influenced by the two largest forest companies in Chile,
Forestal Arauco and Forestal Mininco. FundaciĂłn Chile acts
as the secretariat of Certfor Chile, while INFOR is responsible
for technical advice. Certfor Chile was accepted as a full
member of the PEFC Council in November 2002, and has
submitted its scheme for endorsement by the PEFC.
Funding
In 1997, the EU funded INFOR to develop a standard of
sustainable forest management. In early 2000, the
Development and Innovation Fund of the Industrial
Promotion Agency (CORFO) funded the development of
Certfor Chile, specifically requesting FundaciĂłn Chile to set it
up as a joint venture with INFOR, in order to take advantage
of the previous effort carried out by these organisations.
91
The creation of the system was funded by CORFO with a
non-returnable fund (public bidding fund) of approximately
$ 200,000 (50% of the remaining costs came from companies
and CORMA).
92
Today, Certfor Chile is still funded by
CORFO. In late 2003, it also received new funding of an
equivalent amount to develop standards for native forests
under the same requirements.
Motivation
The objective of Certfor Chile is to develop an internationally
recognised National Forest Certification Standard for Chilean
plantations, lenga forest and second-growth beech forests.
93
The Certfor Chile scheme was created in response to the
impact of global environmental requirements on interna-
tional trade and on the marketing of forest products.
94
This
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CertificaciĂłn Forestal en Chile (Certfor)
66
new demand has its origins mainly in Europe and North
America, where consumers are asking for products that come
from well-managed forests. To avoid being left behind, the
Chilean Government and Chilean timber industry jointly
initiated the development of a Chilean standard for
sustainable forest management. Certfor Chileâs goal is to have
8 million ha certified by 2005.
95
Coverage
When fully operational, the Certfor Chile standard is
intended to be applicable to all forest types, sizes of
operations and tenures, including group certification. The
standard is designed to be applicable at the Forest
Management Unit level.
Amount of hectares certified
Certfor Chile has so far certified only four forestry
operations: Bosques Arauco, Forestal CholguĂĄn, Forestal
Celco y Forestal Valdivia,
96
adding up to a total of 900,000 ha
of pine and eucalyptus plantation.
Label and chain of custody
There is a label and chain of custody system.
2 Quality of standard
Performance or system
The plantation standard has been completed, and is being
assessed by the PEFC as part of the assessment of the Certfor
Chile certification scheme.
97
The draft âPrinciples, Criteria and
Indicatorsâ for the plantation standard (2002), show that
Certfor Chile is mainly a system-based certification
programme. The standard consists of 9 principles
(1. planning and long term objectives; 2. biodiversity;
3. productivity maintenance; 4. water and soil protection;
5. local communities; 6. indigenous peoples; 7. forest workers
and labour relations; 8. law and international agreements;
9. monitoring) 43 criteria and 179 indicators. The first draft
of the standards for natural forest is available, and it is
expected that to be completed by 2005.
98
This report focuses
on the plantation standard.
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CertificaciĂłn Forestal en Chile (Certfor)
67
Quality
â
Principle 1 is fully system-based. Criterion 1.1. reads
âforest managers are formally committed to sustainable
forest management and can demonstrate their intention to
continue with forestry activities in the FMU for at least one
more rotationâ, which reveals the interest of the timber
industry.
â
Principle 2 (biodiversity) contains some performance-
based indicators such as 2.2.1, which requires at least 10%
of the FMU to be destined for conservation purposes, and
2.14, which requires that areas identified as corridors are
not planted. However, most principles are system-based
and focus on inventories and monitoring. The existing
performance-based indicators are weak, unclear,
99
or
contradictory. The standard allows for the use of GMOs
and also allows for native forest conversion when forests
are not of âhigh environmental valueâ, ânatural productive
forestâ, or âcorridor forestâ.
Although principle number 5 is entirely concerned with local
communities, all criteria are system-based. Furthermore,
principle number 6 dealing with indigenous peoples focuses
on legally recognised land titles, and does not allow for self-
determination. The scheme demands mapping of indigenous
lands, but it is not clear whether this refers to lands identified
by indigenous peoples as theirs, or lands identified by the
state as belonging to indigenous peoples. Requirements to
halt timber extraction from disputed lands only relate to legal
disputes. The social principles related to workersâ rights are
largely performance-based.
Comments
Positive elements of the standard refer to the training of
workers, the need to educate forest workers in Chileâs national
and international environmental commitments of forest
managers, and the requirement to achieve clarity of land
ownership and user rights before certification.
3 Standard-setting procedures
Who was involved?
The Certfor Chile standard was developed in five stages:
Definition of Principles Criteria, and drawing up of the first
draft of the National Forest Certification standard (December
2000).
â
Definition and Indicators for plantations.
â
Definitions and Indicators for lenga forest.
â
Definition and Indicators for secondary forest.
â
Design of the certifier accreditation system and editing of
final documents.
FundaciĂłn Chile hired two consultants (from South Africa
and Sweden) to produce a first draft standard after a round of
meetings with relevant actors. At this stage, INFORâs work in
the context of the EU-funded proposal was also taken on
board. It is, however, not clear to FERN if, and how, the input
provided by those consulted was taken on. There was no
response from Certfor when asked to comment on this draft
report.
There also exists a Working Group. This is a three-member
group reporting to the Technical Committee. The Working
Group is responsible for preparing draft documents to be
revised by the Technical Committee and, upon their recom-
mendation, discussed and approved by the Superior
Council.
100
Information about who participates in the
Working Group or the Technical Committee is not available.
There is no reference to these two bodies in the Certfor Chile
statutes.
The draft standard was discussed at a workshop with
interested stakeholders. Recommendations were considered
by the Certfor Chile board of Directors or Superior Council
(consisting of seven individuals participating on a personal
basis, which instruct the Working Group to introduce
approved modifications into the text of the standard).
Although the standard-setting process has been open to
stakeholders to submit comments as part of public consul-
tation activities, there is nothing in the structure of the
standard-setting process that ensures that the views of one
group of stakeholders is not able to dominate the standardâs
development. It is further unclear if and how comments
provided have been taken on in the final standard.
National and international certification bodies will be
accredited by the Chilean State National Accreditation
System, Instituto Nacional de Normalizacion (INN), in order
to certify to Certfor Chileâs sustainable forest management
standard, the group certification standard and the chain of
custody standard.
Is balanced participation required?
No.
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CertificaciĂłn Forestal en Chile (Certfor)
68
4 Certification process
Who does what?
Certfor Chile procedures state that the certification process
starts when a forest company contacts an accredited certifying
organisation.
101
The certifier goes in the field and completes a
certification audit. Later, the results of this audit are evaluated
by a group of independent experts. Their evaluation is then
communicated to the certifier who ultimately decides
whether or not to certify the forest company.
Is stakeholder participation required?
Stakeholder consultation goes through the following
process.
102
The applicant prepares a list of stakeholders that is
sent to the certifier to ensure all the relevant organisations are
represented. A questionnaire is then sent to all the stake-
holders 30 days before the final evaluation and, once all the
information has been received, is summarised, and sent to the
group in charge of the audit for consideration. If a
stakeholder asks for a meeting, this must be organised. All
resulting comments are required to be mentioned in section
6.0 of the certification report. In the case of Grupo Arauco,
for example, 130 stakeholders were consulted through written
interviews. During the audit, 97 people were interviewed;
these were workers, neighbours, community representatives,
public sector professionals, NGOs and others.
Monitoring
A certificate is valid for five years.
103
During this period,
annual follow-up visits are carried out to make sure that the
standard is respected.
104
Complaints procedure
Criterion 5.4 of Certfor Chileâs standard mentions that regis-
tration of complaints should be maintained and.processed
according to set guidelines, and that community complaints
are handled according to a pre-established procedure.
105
It is
not clear, however, if the complaints mechanisms fully
consider the views of local communities in the pre-
established procedures.
At a higher level, according to Procedure 4.11, the Governing
Board has the power to listen to complaints from either the
certification body, or the client if they are not able to settle
their differences and reach consensus among themselves.
If complaints cannot be solved between the involved parties,
or do not lie within the competence of the certification body,
the Dispute Settlement Body deals with all complaints arising
from the implementation of group or regional certification,
interpretation of certification requirements, etc. The Dispute
Settlement Body can also resolve possible grievances in chain
of custody certification that do not exclusively concern an
applicant and a certification body.
5 Transparency
Are summary reports available?
A brief summary of the certification process of Grupo Arauco
is available on Certfor Chileâs website.
106
In the Principles and
Criteria, it is also mentioned that forest managers regularly
need to make information about their management practices
available to interested third parties.
Are standards and procedures available?
These documents are available on the Certfor Chile website
and on the PEFC website.
6 Label protection and chain of custody
Label use
Forest managers can make use of their achievement both in
accessing markets by providing labelled products, and by
making the public aware of their achievement in their general
advertising. Certfor Chile has produced a logo-use guide,
which describes the rules for on-product labels, on-product
statements, and general advertising and publicity.
Chain of custody procedures
The chain of custody standard of Certfor Chile takes into
account three modalities of accounting for certified timber:
107
a
Physical separation
Under this modality, certified timber in the chain of
custody must be separated at all time from uncertified
timber. Separation can be by product, space and/or time.
Product: Physically distinct materials (individual marking)
Space: Differentiated sections and/or production lines
Time: Use of the same spaces or production line but at
different times
When physical separation is not feasible, the following
two methods of inventory control are recognized.
b
Input-output
Based on the premise that when a known percentage of
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CertificaciĂłn Forestal en Chile (Certfor)
69
certified materials enters a certain process (input batch),
the same percentage of the production (output batch) is
considered certified.
c
Minimum average percentage
Based on the premise that the production can be qualified
as certified, if the amount of certified material in the
input batch is equal, or bigger, than a claimed percentage.
Therefore, at the end of the process, the product is not
100% certified, but rather equal to the percentage of
certified timber claimed.
The minimum percentages established by Certfor Chile
are:
I
Products elaborated from fiber (pulp, paper, wood-based
panels, others): 17.5% of the total and 30% of the virgin
fiber.
II
Solid wood: 70%.
III
Assembled products (remanufactures, furniture, plywood,
others): 70%.
Policy on Controversial Sources
Certfor Chileâs standard include requirements, which are in
compliance with Annex 4, chapter 8 in that wood from
controversial sources must not enter the chain of custody
process, and that the company must acquire at least a self-
declaration from all suppliers to that effect.
108
In principle 2 of
the chain of custody standard, the issue is defined. Two
criteria address the problem:
â
Criteria 2.7: A system for verifying that the supplierâs
chain of custody number is legitimate and that it covers
the materials supplied. The purchaser should check with
Certfor Chile that the chain of custody or SFM certificate
is valid â This is carried out the first time that raw
materials are purchased from a new supplier, and
afterwards its validity checked once a year. The purchaser
should check with Certfor Chile that the chain of custody,
or SFM certificate, is valid â this is carried out the first
time that raw materials are purchased from a new
supplier and afterwards its validity is checked once a year.
â
Criteria 2.8: A system to verify that no illegally harvested
timber or timber products can enter the system. There is
a system to verify the legal status of all uncertified timber
products.
There is also a system to verify the legal status of all
uncertified timber products. There is a waybill identifying the
timberâs origin.
Malaysian Timber Certification
Council (MTCC)
Summary, based on a report by
Wong Meng Chuo of IDEAL
1 History and characteristics
Creation
The Malaysian Timber Certification Council (MTCC) was
created in October 1998, and started operating in January
1999. The Council grew out of a joint initiative by the
Malaysian Ministry of Primary Industries, and the Malaysian
Timber Council who together organised a âSeminar on
Timber from Sustainably Managed Forestsâ in April 1994.
This seminar resulted in the formation of a committee that
was coordinated by the Malaysian Timber Industry Board.
This committee in turn led to the establishment of the
Malaysian Timber Certification Council (MTCC). The MTCC
is a member of the PEFC Council.
Funding
The Councilâs main source of income is the interest from an
endowment fund of RM 36,000,000 â equivalent to Euro
7,650,611 created by a timber export levy fund.
109
Motivation
A leaflet produced by the MTCC states: âWith the growing
concern over deforestation and the associated environmental
effects, consumers of forest products, such as timber, want to be
assured that these products have been produced through sound
forest management practices. In this regard, timber certification
has been promoted as a market-linked tool to encourage
sustainable forest management practices in producer
countriesâ.
110
The purpose of the MTCC scheme was best summed-up by
the Malaysian Primary Industries Minster Datoâ Seri Dr Lim
Keng Yaik: âMalaysia wanted to revive its timber product
exports to Europe where the trade has suffered from the
ill-founded perception that the products did not come from
well-managed forestsâ.
111
Coverage
The MTCC scheme certifies at forest management unit
(FMU) level, which means different things in different states.
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Malaysian Timber Certification Council (MTCC)
70
In Peninsular Malaysia, an FMU is the permanent forest
reserve. In Sabah, an FMU will be the area covered by each
Sustainable Forest Management License Agreement, while in
Sarawak an FMU is defined as the individual concession
area.
112
There is no separate mechanism for the certification of
small businesses.
Amount of hectares certified
As of November 2003, seven â out of a total of 13 states have
been certified. They include: Pahang, Terengganu, Selangor,
Johor, Kedah, Perak and Negeri Sembilan. A total of 4,111,406
ha have now been certified in Malaysia. The average size of
these forests is 587,344 ha. In all cases, the Governments of
the respective states are the official owners of the certified
forests.
Label and chain of custody
The MTCC has a label and a chain of custody.
2 Quality of standard
Performance or system
The Malaysian Criteria, Indicators, Activities and Standards of
Performance (MC&I) for Forest Management Certification is
largely a system-based standard. A report on the Assessment of
Compatibility of Malaysian Criteria and Indicators for Forest
Certification with FSC Requirements points out that: âThe
minimum performance levels or thresholds for failure for each
criterion with the MC&I have not been predefined.â
113
âThe majority of MC&I indicators tend to concentrate on
ensuring the existence of appropriate legislation, documen-
tation and systems. They assess the quality and quantity of
input. But the MC&I have relatively few output-related criteria
or indicators.â
114
Quality
There are also some specific problems with the content of the
standard. Under criterion 6, Economic, Social and Cultural
Aspects, the economic aspects take account of, âthe ratio of
domestic log production to processing capacity of wood
industriesâ, as well as the, âexistence and implementation of
mechanisms for the effective distribution of incentives, and the
fair and equitable sharing of costs and benefits among the
parties involvedâ.
115
Unfortunately, the term âparties involvedâ
is narrowly defined and comprises only the State Government
and the Federal Government.
116
Other parties affected in a
direct or indirect way â either through shared benefit or
shared cost (such as environmental pollution or degradation)
â are not considered.
Regarding socio-economic aspects, the standard includes
criteria for the health and safety of forest workers, and for the
creation of employment opportunities, but minimum
performance levels have not been defined. On the rights of
indigenous peoples and local communities, the criteria are
input oriented and not performance-based. They ask for
policies, rules, reports and so on, but do not specify any
minimum performance levels. Cultural and spiritual aspects
are not considered. Community places of worship and burial
grounds would, therefore, not be safeguarded. Environmental
values are reflected in criteria 4 (biodiversity) and 5 (soil and
water). The indicators (âperformance-based standardsâ) for
criteria 4 and 5 are, however, incomplete, unspecified and
inconsistent between the three regions of Peninsular Malaysia,
Sabah and Sarawak.
117
Comments
The MC&I require adherence to national and regional laws.
However, issues of legality are not necessarily adequately
addressed. This is particularly true in the case of disputes
with the local community over land rights. Native customary
laws (described as âadatâ) are very much part of the legal
system in the pluralistic social context of Malaysia. But, usersâ
rights are being challenged by the MTCC forest management
certification scheme. This is due to the fact that forest lands
were often untitled under native customary rights, although
clearly demarcated among local people through usage and
shared knowledge. By not recognising native customary law,
the MTCC scheme aggravates the injustice to indigenous
communities and challenges the legal rights of indigenous
citizens as enshrined by the national constitution.
Certifications as of January 2005 will be based on a new
standard of FSC-compatible Malaysian Criteria and Indicators
for Forest Management Certification â (known as the
MC&I2002), which will be field-tested in the three regions
(Sabah, Sarawak and Peninsular Malaysia). This standard
does include some criteria and indicators omitted by the
current MC&I. Under principles 2 and 3, for example, the
legal and customary tenure rights of local communities or
indigenous peoples are considered. However, itsâ indicators
depend on the availability of documentation that native
customary land rights are not always able to provide. As for
the other principles in MC&12002, they do go into more
Footprints in the forest
Malaysian Timber Certification Council (MTCC)
71
detail than the previous MC&I version, and cover missing
aspects such as efficiency of utilisation, spiritual and cultural
sites, genetic diversity, chemical use, illegal exploitation, forest
fire, monitoring and assessment, and high-conservation-value
forest. They are, however, still incomplete and not sufficiently
performance-based.
3 Standard-setting procedures
Who is involved?
Between 1994 and 1998, the development of a technical
design for the MC&I was co-ordinated by the National
Committee of Sustainable Forest Management (consisting of
the Ministry of Primary Industries, the Forestry Departments
of Peninsular Malaysia, Sabah, and Sarawak, the Forest
Research Institute of Malaysia, the Malaysian Timber Industry
Board, the Malaysian Timber Council, and the Faculty of
Forestry at the University Putra Malaysia). The design was
derived from the ITTOâs Criteria and Indicators for the
Sustainable Management of Natural Tropical Forests.
During this period, there was no environmental or
indigenous NGO involvement, nor were any NGOs asked to
contribute to the process. Environmental and conservation
NGOs, such as the Malaysian Nature Society (MNS) and
World Wide Fund for Nature, Malaysia (WWFM), were
invited onto the Board of Trustees when the National Timber
Certification Council, Malaysia (NTCC) was established in
October 1998. The MNS was not, however, invited onto the
reconstituted Board in 2001, and WWF Malaysia resigned
from the Board in January 2002 due to disagreements over
the MTCCâs decision to launch a scheme using standards that
had been developed without balanced stakeholder partici-
pation.
118
The new MC&I2002 that will be implemented in 2005, were
finalised at national-level consultations in October 2002 in
Kuala Lumpur, and adopted as the standard for assessing
forest management practices at FMU level for the purposes of
certification. The participant list for this national consultation
shows that, out of 106 participants, only 14 of them
represented social and environmental interest groups.
119
Earlier in July 2001, 13 environmental and social NGOs had
Footprints in the forest
Malaysian Timber Certification Council (MTCC)
Logs from Pahang, Malaysia, an MTCC certified forest
Photo: Carol Yong
72
withdrawn from the process, as their requests had not been
taken into account.
Is balanced participation required?
As can be seen above, the scheme does not require a balanced
participation of social, economic and environmental repre-
sentatives.
4 Certification process
Who does what?
Applications for certification must be made using the
appropriate application form. The MTCC then assigns a certi-
fication body from the pool of registered independent
certifiers.
120
The applicant may arrange an optional pre-audit
visit prior to the main assessment. This visit has three
functions: (
I
) to confirm that the client understands the certi-
fication requirements; (
II
) to confirm the scope of the
proposed certification; and (
III
) to determine whether the
FMU is ready for the main audit. The main audit is then
carried out either in accordance with the requirements of the
MC&I for Forest Management Certification.
Any cases of non-compliance with the MC&I for Forest
Management Certification are met with written Corrective
Action Requests (CARs) from the assessor to the client. Major
CARs prevent the client from being certified, whereas minor
CARs do not preclude the FMU from being certified. When
corrective actions have been satisfactorily implemented the
certification body will âclose outâ the CAR.
A peer review panel, appointed by the MTCC, evaluates the
audit report. This panel normally consists of two members,
and is given up to ten working days from receipt of the
assessment report to submit their findings. Once the
assessment report has been reviewed a Certification
Committee (established by the Board of Trustees of MTCC
and composed of four members from each of the interested
groups on the Board â i.e., industry, research or academic
institutions, non-governmental organisations and
government agencies) makes the final decision. When a
decision has been taken by the Certification Committee, a
certificate is issued. A summary of the audit report is made
available by the MTCC for the general public.
Is stakeholder consultation required?
Yes, the certification itinerary must include time for consul-
tation with interested parties within the FMU, including, as
appropriate: environmental and social organisations, local
communities, local and national government officials;
forestry departments, educational and research bodies,
workers unions and trade representatives. Anecdotal evidence
suggests, however, that consultation, even if claimed, does not
always occur.
Monitoring
The validity of a certificate lasts five years. During this period,
an FMU is subject to reassessments under surveillance visits
that take place once every 6-12 months.
Complaints procedure
Following a recent decision of the MTCC Board, an appeal
against the decision of the Certification Committee will be
considered by the Appeals Committee, which consists of the
four Board members not involved in the Certification
Committee. However, there are insufficient details of the
mechanism to provide any clarity about its workings
5 Transparency
Are summary reports available?
Summary certification reports are available on the MTCC
website.
Are standards and procedures available?
The standards and procedures are freely available. The
minutes and proceedings of National Steering Committee
meetings and of the national and regional consultations are
not, however, made freely available to all the stakeholders in
the process, even upon request.
6 Label protection and chain of custody
Label use
Certified products will be packaged and labelled in
accordance with the requirements of the MTCC certification
scheme. chain of custody certified products will bear the
MTCC logo. According to MTCC as of October 2003, there
are 37 companies awarded the Certificate for chain-of-
custody
121
. These companies are allowed to export MTCC-
certified timber products using the MTCC logo. Up to the
end of September 2003, a total of 6,869 cubic metre of
MTCC-certified sawn timber has been exported to the
Footprints in the forest
Malaysian Timber Certification Council (MTCC)
73
Netherlands, Germany, Belgium, the United Kingdom,
Australia and France.
122
Chain of custody procedures
The Malaysian requirements for chain-of-custody certifi-
cation were finalised in November 2000. The MTCC website
reveals that 37 companies from Peninsular Malaysia are chain
of custody holders as of October 2003. MTCC chain-of-
custody is based on
a
an input-output system, or
b
a minimum percentage system. The minimum percentage
of certified material is 70% for solid wood products, and
30% for wood fibre based products.
Footprints in the forest
Malaysian Timber Certification Council (MTCC)
Malaysia
Photo: BMF
74
Endnotes
1
1
Proforest: Assessing Forest Certification Schemes: A Practical Guide;
December 2002; www.proforest.net/index3.htm
1
2
FERN; Forests of Fear; December 2001 at www.fern.org. Forests to Fight
Poverty, Creating National Strategies; Edited by Ralph Schmidt, Joyce
Berry and John Gordon; Yale University Press; New Haven & London
1999.
1
3
Rametsteiner, Ewald and Simula, Markku (2001); Forest certification,
forging novel incentives for the environment and sustainable forest
management; workshop in Brussels, September 2001.
1
4
Colchester, M., Sirait, M. & Wijardo B. (2003). âObstacles and
Possibilitiesâ. Implementation FSCâs Principles No.2 and 3 In Indonesia.
Discussion Document, January 29-31, 2003. Study Commissioned by
AMAN and Walhi in cooperation with the Rainforest Foundation.
1
5
Report of the ad hoc intergovernmental panel on forests on its fourth
session. E/CN.17/1997/12. 20 March 1997
1
6
Report of the ad hoc intergovernmental panel on forests on its fourth
session. E/CN.17/1997/12. 20 March 1997.
1
7
The term credibility is a vague term. Bass and Simula 1999 have
interpreted this term as multi-stakeholder support, transparency, reliability
and accountability
1
8
These are: The African TimberOrganisation; Dry Forest Asia; Dry Zone
Africa; Pan European Forest Process âHelsinki Process-; Tarapota
Proposal; Near East Process; Montreal Process; Lepaterique Process; ITTO
Criteria and Indicators.
1
9
COFO, fifteenth session 12-16 March 2001 Rome; Criteria and Indicators
of Sustainable Forest management of All Types of Forests and Implications
for Certification and Trade
10
EU Statement regarding agenda item 6: Crietria and Indicators of
Sustainable Forest Management of All Types of Forests and Implications
for Certification; 7 March 2001.
11
IFIR; Proposing an international mutual recognition framework. Report of
working group on mutual recognition between credible sustainable
management certification systems and standards; February 2001.
www.sfms.com/pdfs/ifirframework.pdf.
12
WT/CTE/8, 11 July 2003
13
http://wbln0018.worldbank.org/Institutional/Manuals/OpManual.nsf/
tocall/C972D5438F4D1FB78525672C007D077A?OpenDocument
14
The main problem is that the CSA allows applicant companies to control
the development of the local certification standard (i.e. the indicators and
targets against which performance is measured) used for their own audit â
although with broad stakeholder input via a public participation process.
Although these processes are often consensus based, they still give the
company a large say in setting its own targets.
15
Seven of the eight core labour standards adopted by PEFC are ILO
Conventions : Right to Organize and Collective Bargaining Convention,
1949 (No. 98) ; Freedom of Association and Protection of the Right to
Organize Convention, 1948 (No. 87); Right to Organize and Collective
Bargaining Convention, 1949 (No. 98); Forced Labour Convention, 1930
(No. 29); Abolition of Forced Labour Convention, 1957 (No. 105);
Discrimination (Employment and Occupation) Convention, 1958 (No.
111); Equal Remuneration Convention, 1951 (No. 100); Minimum Age
Convention, 1973 (No. 138)
16
The company Gunns Ltd has been certified under the AFS. A summary
report has not (yet?) been made available.
17
www.forestrystandard.org.au/where.html
18
The main problem is that the CSA allows applicant companies to control
the development of the local certification standard (i.e. the indicators and
targets against which performance is measured) used for their own audit â
although with broad stakeholder input via a public participation process.
Although these processes are often consensus based, they still give the
company a large say in setting its own targets.
19
G/TBT/W/196 March 2002
20
FERN; Ecolabelling, forest certification and the WTO; July 2003. Available
at www.fern.org
21
Vitalis, ibid and Guy Salmon, Voluntary Sustainability Standards and
Labels: the case for fostering them; Round Table on Sustainable
Development, December 2002.
22
US/Shrimp Turtle, Recourse to Article 21.5 of the DSU by Malaysia, AB
Report, 22 October 2001, WT/DS58/AB/RW
23
Vitalis, ibid and Salmon. Ibid
24
This agreement concerns the application of sanitary and phytosanitary
measures â in other words food safety and animal and plant health
regulations. The agreement recognises that governments have the right to
take sanitary and phytosanitary measures but that they should be applied
only to the extent necessary to protect human, animal or plant life or
health and should not arbitrarily or unjustifiably discriminate between
Members where identical or similar conditions prevail.
25
Within the WTO it is the TBT Committee that would have to give any
interpretation of (voluntary) environmental labelling programmes and
their legitimacy under WTO rules. The TBT Agreement applies in
principle to both mandatory and voluntary product-labelling standards,
including in principle labelling standards developed by non-state actors.
Although the TBT Agreement itself does not specifically apply to non-state
actors, Article 4 states that âmembers (i.e. governments) shall take such
reasonable measures as may be available to them to ensure that local
governments and non-governmental standardizing bodies within their
territoriesâŠ. accept and comply with this (i.e. the TBT) Code of Good
Practiceâ. Furthermore the Title of Article 3 of the TBT reads: Preparation,
Adoption and Application of Technical Regulations by Local Government
Bodies and Non Governmental Bodies. This assumes that when dealing with
Technical Regulations, which are by definition mandatory, non-state actors
would have to apply to TBT rules. It should be noted that the TBT Code of
Good Practice for the preparation, adoption and application of standards
is open to any standardizing body; hence, also for non-governmental
bodies.
26
WT/CTE/8, 11 July 2003
27
ISO/IEC (1994). Code of Good Practice for standardization, Guide 59,
clause 6.1.
28
ITTO; ITTO International workshop on comparability and equivalence of
forest certification schemes. Kuala Lumpur 3 to 4 April 2002. Forest
Certification: Pending challenges for tropical timber
29
SGS Global Trade Solutions (2003) âLegal Origin of Timber as a Step
Towards Sustainable Forest Managementâ, Final Draft, September 2002 â
June 2003, World Bank/WWF Alliance, p. 2.
30
SGS Global Trade Solutions (2003) p. 9. Ibid
31
Dennis P. Dykstra et all; Technologies for wood tracking: verification and
monitoring the chain of custody and legal compliance in the timber
industry. Washington DC: Environment and Social development East Asia
and Pacific Region Discussion Paper; World Bank Environment
Department. Discussion Paper. Draft, December 2002
32
In the case of CSA the targets set for the audit are still influenced by the
forestry company. Some would therefore argue that certification is unduly
influenced by the forestry industry.
33
Canadian Sustainable Forestry Certification Coalition website,
www.sfms.com/
34
Canadian Sustainable Forestry Certification Bulletin; December 2002.
Available at www.sfms.com
35
CAN/CSA-2809-02, section 0.4
36
CAN/CSA-2809
37
Stefan Janhager, Standards Council of Canada, personal communication
with Sierra Club Canada., Dec. 2, 2003.
38
In July 2001 three environmental organisations in Alberta (Albertans for a
Wild Chinchaga, Canadian Parks and Wilderness Society â Edmonton
Chapter and the Alberta Wilderness Association) registered complaints
with QMI (in reference to Weldwoodâs Hinton SFM certificate) and
KPMG (in reference to Canforâs Grande Prairie certificate). In both cases
the complainants alleged that the measures described in the management
plan were insufficient to adequately address a number of goals, including
Footprints in the forest
Endnotes
75
protecting rare ecological sites, maintaining sufficient habitat for
woodland caribou and conserving soil and water resources. In responding
to the complaints neither QMI nor KPMG addressed the substance of the
complaints. Instead, QMI responded that the public participation process
requirements had been met, that âover 250 letters of invitationâ had been
sent, and that the complainants had had the opportunity to participate but
had chosen not to. QMI proposed that the issues raised in the complaint
be referred to Weldwoodâs public advisory group. KPMG responded that
the public involvement process met all of the standardâs requirements, and
that KPMG agreed with Canfor that the specific objectives in the plan
were âreasonable in the circumstancesâ, without explaining why (or what
circumstances were being referred to), acknowledging only that SFM is
ânot an exact scienceâ.
39
Frequently asked questions; www.fscoax.org; November 2003
40
âAbout FSCâ, FSC UK web-site accessed 27 October 2003 http://www.fsc-
uk.info/about.asp.
41
http://www.fscoax.org/html/5-3-3.html),
42
Nonetheless in close co-operation with FSC members of the environ-
mental chamber the FSC board representative, representing Northern
environmental NGOs has phasing out of certifierâs standards as a top
priority for the FSC.
43
Available at http://www.fscoax.org/principal.htm
44
Despite these thorough requirements, in at least one instance problems
have arisen: NGOs have complained that economic interests dominated
the Irish standard setting process.
45
There is however at least one case where this has not happened and the
interim standard was not produced till after the certification was
approved.
46
http://www.fscoax.org/principal.htm
47
Options for revision of FSC Policy on chain of custody and labelling for
assembled products. Reference code FSC-DIS-40-003
48
FSC chain of custody standard for sawn wood products, Annex 2
49
These are called national governing bodies. According to the PEFC
statutes: The national forest ownerâs organisations or national forestry
sector organisations having the support of the major forest ownersâ associ-
ations are responsible for inviting national organisations representing
relevant interested parties to constitute a national governing body.
50
Finland, Norway, Germany, Austria, Sweden, Czech Republic, France,
Spain,Switzerland, Latvia, UK, Belgium, Italy.
51
CSA in Canada, SFI in US, MTCC in Malaysia, CERFLOR in Brazil. The
Chilean Certfor and the Australian AFS are currently being assessed by the
PEFC.
52
âAbout the PEFCâ at www.pefc.org, accessed February 2001.
53
The PEFC Council has commented in its response to FERN on the draft
report that this information is incorrect. Apparently more national
schemes certify at FMU level. However no more information was provide
on which schemes. FERN was not able to find this information on the
PEFC website.
54
The size of forest management certificates issued under the PEFC
umbrella vary from 0.2 hectare to 158,000 hectare (individual forest
management certificate holder); 3,000 hectares to 235,000 hectares (group
forest management certificate holder) and 13,376 hectares to 6,590,000
hectares (regional fort management certificate holder).
55
Seven of the eight core labour standards adopted by PEFC are ILO
Conventions : Right to Organize and Collective Bargaining Convention,
1949 (No. 98) ; Freedom of Association and Protection of the Right to
Organize Convention, 1948 (No. 87); Right to Organize and Collective
Bargaining Convention, 1949 (No. 98); Forced Labour Convention, 1930
(No. 29); Abolition of Forced Labour Convention, 1957 (No. 105);
Discrimination (Employment and Occupation) Convention, 1958 (No.
111); Equal Remuneration Convention, 1951 (No. 100); Minimum Age
Convention, 1973 (No. 138)
56
âor national forestry sector organisations having the support of the major
forest ownersâ organisations in that countryâ Annex 2 Technical
Document, www.pefc.org, November 2003
57
ISO Guide 62,65 and 66.
58
Although here NGOs complained the summary reports did not contain
sufficient information.
59
PEFC Council comments on draft FERN report, January 2004 version.
60
AF&PA. 2003. SFI Program Participants That Have Completed 3rd Party
Certification. SFI webpage, www.afandpa.org, July, 2003. American Forest
& Paper Assn., Washington, DC, USA.
61
KPMG. 2001. Final Audit Report: AF&PA SFI Program Third Party
Verification Audit of Sierra Pacific Industries. August 17, 2001. KPMG,
Vancouver, BC.
62
NRDC. 2001. Behind the Logo: An Assessment of the Sustainable Forestry
Initiative in Comparison With the Forest Stewardship Council in the USA.
Natural Resources Defense Council, San Francisco, CA, USA. Available at
www.fern.org.
63
NRDC (2001). The ERP was selected by the AF&PA to advise the AF&PA
and SFI, and to review companiesâ reports to the system. The ERP does
not have management or decision authority within the SFI system.
64
The AF&PA SFIâs requirements for the certification process are contained
in the 2002 - 2004 SFI âVerification/Certification Principles and
Proceduresâ and the 2002 - 2004 SFI Standard, in AF&PA & SFB (2002).
65
It is unclear when, if ever, the SFI requires âfieldâ evaluations for most of a
companyâs on-the-ground forest management practices and outcomes.
The âVerification/Certification Principles and Proceduresâ do state that
certifiers are to establish that companiesâ ââŠon-the-ground activities
conform or comply with the [SFI Standard].â However, the SFI standards
explicitly require field evaluations for only a few specific performance
measures and indicators â implying that field evaluations may not be
required for the other standards.
66
The âVerification/Certification Principles and Proceduresâ state that
companies may not be certified until âmajor non-conformancesâ with the
SFI standards have been corrected, and a plan for correcting any âminor
non-conformancesâ has been established. However, major non-confor-
mances are defined as failures to comply with the objectives and
performance measures of the SFI standards. Most of the SFI objectives and
performance measures do not require specific on-the-ground forest
management practices or outcomes â raising the question of whether
major non-conformances are likely to be found.
67
The chair of Californiaâs committee, for example, is reportedly an
employee of Sierra Pacific Industries.i
68
NRDC. 2001. Behind the Logo: An Assessment of the Sustainable Forestry
Initiative in Comparison With the Forest Stewardship Council in the USA.
Natural Resources Defense Council, San Francisco, CA, USA. Available at
www.fern.org.
69
American Lands Alliance reviewed one report which was a mere 6 pages
long, and which failed to provide: a basic description of the natural
resources found on the companyâs lands, a discussion of the companyâs
performance relative to each SFI indicator, and timelines and require-
ments for each of the companyâs 12 minor nonconformances to be
addressed. This report also failed to adequately address one of the most
serious silvicultural and ecological problems occurring on some of the
companyâs land.
70
Based on AF&PA Guidance Document on Wood Flow Accounting &
Legality, May 2003; SFI Program On Product Label 09/15/03; Summary of
Procurement System Requirements, SFI Program Standard 09/15/03.
71
http://www.forestrystandard.org.au/paper01.html â accessed by the
researcher 19/11/03
72
Personal communication Mark Edwards, AFS Ltd, 30 January 2004
73
Including WWF, West Australian Forest Alliance,Friends of the Earth,
Conservation Council, Native Forest Network etc.
74
Communication between Mark Edwards from AFS Ltd. and Tim Cadman,
15 December 2003
75
http://www.forestrystandard.org.au/paper05.html
76
http://www.forestrystandard.org.au/paper05.html
77
http://www.forestrystandard.org.au/paper05.html
78
http://www.forestrystandard.org.au/paper10.html
Footprints in the forest
Endnotes
76
79
Final draft Australian Forestry Standard Page 171 of 207
80
âAll stages of the certification process should be transparent. This includes
the development of certification standards, criteria and principles, the
operations of accreditation and certification bodies, and the non-
commercial results of certification in forms that are accessible and
meaningfulâ Dr Hans Drielsma,
http://www.forestrystandard.org.au/paper1.html â accessed 19/11/03
81
http://www.forestrystandard.org.au/publications/pdf/draft3_Chain of
Custody_standard_180803.pdf (accessed 19/11/03)
82
May, Peter H. (2002) Forest Certification in Brazil: Trade and
Environmental Enhancement. Consumer Choice Council
83
NBR 14789 Forest Management âprinciples, criteria and indicators for
planted forests.
84
Notably criteria 3.5. and 3.6
85
Greenpeace (2002), Certificacao Florestal; Cerflor Empresa e governo tem
credibilidade para realizar ceertificacao florestal?
86
NIT-DICOR-053 Criteria for accreditation of organisms for forest
management certification according to NBR 14789
87
NBR 14791 Guidelines for Forest Audits (GFA) â general principles, and
NBR 14792 GFA â audit procedures â auditing forest management.
88
NBR 14793 GFA â audit procedures â qualifications criteria for forest
auditors
89
NIT-DICOR-053
90
Are detailed in NBR 14790
91
A comparative Analysis of the Programs CertforChile and the FSC;
EcoNativa, December 2002.
92
http://www.certfor.org/ingles/certfor.htm
93
www.certforchile.cl/english/i_q_somos.htm
94
http://www.certfor.org/ingles/certfor.htm
95
Certification Watch Conference
http://www.certfor.org/documentos/FCW_AC.pdf
96
http://www.certfor.org/archivos/Sistema/certificados.htm
97
http://www.pefc.org/internet/html/members_schemes/4_1120_59/5_1246
_309/5_1123_729.htm
98
Forest certification Watch Conference
http://www.certfor.org/documentos/FCW_AC.pdf
99
Although the standard specifies that plantations will not replace native
forests (2.1.3), big areas of second growth forests and open forest that are
not economically viable can be replaced by plantations
100 PEFC council minimum requirement checklist
http://www.pefc.org/internet/resources/_Toc3412738
101 http://www.certfor.org/faq.htm
102 Procedimiento de la realixaciĂłn del proceso de consulta publica
http://www.pefc.org/internet/resources/4_1334_686_file.597.doc
103 http://www.certfor.org/faq.htm
104 http://www.certfor.org/archivos/Sistema/certificados.htm.
105 http://www.certfor.org/documentos/Chilean_Standard.pdf
106 El proceso de certificaciĂłn de Arauco
http://www.certfor.org/archivos/Sistema/certificados.htm#P
107 Chain of Custody Standard and Checklist
http://www.pefc.org/internet/resources/5_1185_747_file.581.doc
108 PEFC council minimum requirement checklist
http://www.pefc.org/internet/resources/_Toc34127386
109 MTCC Annual report 2002
110 NTCC(1999) Leaflet âConservation, management and utilisationâ.
111 Lim 2002 Quoted by Yong, Carol (2002). The Malaysian Timber
Certification Scheme and the FSC, Case Study 8: Malaysia in âTrading in
Credibility: The Myth and reality of the Forest Stewardship Council (The
Rainforest Foundation). 2002:125.
112 Sandom, James and Simula, Markku, Assessment of Compaticbility of
Malaysian Criteria and Indicators for Forest Certification with FSC
Requirements (National Timber Certification Council, Malaysia, April 19,
2001 (draft). Page 31.
113 Sandom & Simula 2001:19 Ibid.
114 Sandom & Simula 2001:27. Ibid
115 MC&I 6.1 and 6.2, version 2001.
116 As shown in the second column â activities of MC&I, 2001
117 For Criterion 5.2 â on the subject of environmentally sensitive areas â
there is no performance-based standard tabled at all for Sabah and
Sarawak. And this is also the case for Criterion 4.2, on forest areas reserved
for conservation purposes, in which only Peninsular Malaysia is given a
figure of 5%, while Sabah and Sarawak have no such requirement. For
Criterion 4.1, âExistence and implementation of procedures to identify
endangered, rare and threatened species of forces flora and faunaâ, the
criterion for Sarawak is listed as âProcedures for pre-felling inventoryâ
without any specifications. Similar cases exist for Criterion 4.3,
âProcedures for the assessment of yield plots and long-term ecological
research plotsâ and Criterion 5.4, âProcedures for identifying and
demarcating sensitive areas for the protection of soil and waterâ. Also, in
Criteria 5.1 and 5.3 on the protection of soil and water and on buffer
strips, the Standards of Performance for Sarawak are listed as the General
Harvest Plan and the Detailed Harvesting Plan.
118 Ng, Ginny, Tong, Pei Sin & Lim, Hin Fui (2002), Environment and Social
Components in Forest certification: Thorny Issues in Malaysia? (WWF
Malaysia, Malaysian Nature Society, Forest Research Institute Malaysia)
119 Those present included WWFM, MNS, a woodworkers union, a consumer
association, a national woman organisation, a rotary club, an environ-
mental protection association and three indigenous organisations, namely
Persatuan Murut Sabah, Kadazandusun Cultural Association (both
newcomers) and Sarawak Dayak Iban Association
120 Eight certifiers are registered as assessors for forest management: Saytech
(Sarawak) Sdn. Bhd., Gaya Tunas Sdn. Bhd., Chemsain Konsultant Sdn.
Bhd., SGS (Malaysia) Sdn. Bhd., TropBio Forest Sdn. Bhd., Sirim QAS Sdn.
Bhd., Forest Research Institute Malaysia (FRIM), and the Faculty of
Forestry at the University Putra Malaysia (MTCC website as of August
2003).
121 Press release dated 31 October 2003
122 Comments by MTCC on âA report on the Malaysian Timber Certification
Scheme, November 2003 by Wong Meng Chuo, IDEAL
Footprints in the forest
Endnotes