On the occasion of this meeting of the Environment Council, ATIBT joins the European Confederation of the wood working industries (CEI-Bois), the European Timber Trade Federation (ETTF) and the UK Timber Trade Federation (TTF) to share their position on the points of attention of the draft EU regulation against deforestation and to alert on the consequences of this regulation on the tropical timber sector.
Indeed, this regulation could have serious impacts for tropical timber producing countries. A reliable supply of timber obtained from sustainably managed forests is the first step for advancing towards a bio-based circular economy in which timber can be used as a substitute for non-renewable, unsustainably produced materials and energy. Therefore, the new Regulation should set a reliable and feasible framework for companies trading in timber and timber products.
The tropical timber sector has a key role in achieving the forest management and conservation goals of COP26. However, the private sector, Governments and civil society in producer and consumer countries must come together to establish relationships promoting governance and sustainable management to achieve this. Protecting and sustainably managing tropical forests cannot be left to “one-sided” approaches from the EU but must be incentivised through continual dialogue and resources which supports sustainable production, inspires reform and improvement within producer countries, commits to sustainable consumption and shares the cost of enforcement.
The role of the European Council – i.e. representatives of the individual member states – is key in the decision-making process. For this reason, ATIBT and its partners are urging European governments to take into account the following considerations before the proposal is adopted:
1) the definition of deforestation should not be changed compared to the European Commission’s proposal (“Deforestation means the conversion of forest to agricultural use, whether human induced or not”). The proposed definition is closer to the internationally agreed definition of the Food and Agriculture Organization of the United Nations. Using internationally agreed definitions would facilitate the implementation and enforcement of the regulation.
2) In the interest of focusing the legislation on the main problem to be addressed, we believe that the regulation should focus on deforestation. The problem of forest degradation should be tackled via the support to enhanced adoption of sustainable forest management at pan-European and international level, rather than via a commodity-focused regulation. However, if forest degradation is to be included in the regulation, the definition should be as clear and operational as possible. We therefore support the definition of forest degradation as “structural changes to forest cover, taking the form of conversion of primary forests into plantation forests or into other wooded land” as well as the deletion of the definition of “unsustainable harvesting operations”. The proposed definition of forest degradation would leave little room for uncertainty and would target the most severe problems of forest degradation.
3) Recognising the importance of the Voluntary Partnership Agreements – FLEGT VPAs. VPA are an effective tool for improving forest governance and working towards sustainable forest management. Moreover, VPAs are elaborated in a multi-stakeholder review process where non-EU Countries are also actively involved. VPAs have a key role in effectively contribute to the economic, ecological and social development of producing countries. Without this mechanism in the regulation – or something equivalent – there is no incentive for tropical producers to try and improve their “risk rating” to meet the standards within the EU proposals.
4) Incentivise the development of national standards: The VPAs also help incentivise the development of national standards and national systems in producer countries which demonstrate that exported timber products have met with all the legal requirements of that country. This is an essential first step towards enforceable, long-term sustainable forest management. It also helps involve trading partners in longer term improvements within countries.
5) Recognize the value of high-standard, international voluntary certifications: third party certifications provide an added credible source of due diligence and verification which can supplement the operator’s own efforts without reducing liability. As a practical way forward, legislators could vet market based third-party certification systems against legally binding essential requirements. This would result in companies having the option to employ a market based third party certification scheme to prove compliance with the essential requirements based on ground realities.
6) The requirement to provide geolocation coordinates presents a challenge to the industry for technical reasons and may entail potential breaches of EU competition rules. The collection of geodata information may lead to numerous errors. Especially when, for example, small forest enterprises are cooperatively linked in marketing, and therefore it is difficult to collect precise coordinates over a wide area. It is therefore suggested to assess the feasibility of this proposal or to come back to the requirements of the EU Timber Regulation (that is, to provide information about the country, region or concession of harvest).
The ATIBT invites its members and partners to share this position with their respective governments (in Europe and in the producing countries).
We will follow the developments of the trilogues that will follow this meeting of the Environment Council between the European Parliament, the Council of the EU and the European Commission, a preliminary step to the adoption of the regulation (planned for the end of 2023 according to the objectives of the European Commission).
Contact : Caroline Duhesme, secretary of the ATIBT certification commission