Getting on the B list
Published: 23 October, 2006
Rupert Oliver of Forest Industries Intelligence considers the implications of CPET's rating system for timber outside certification schemes
In June 2006, the UK government's Central Point of Expertise on Timber (CPET) released details of the methodology it will use to assess non-certification claims that timber products are from legal and sustainable sources.
The methodology set out in the document Framework for Evaluating Category B Evidence forms an integral part of the UK government's procurement policy on timber and timber products, committing all central government departments, agencies and sponsored bodies actively to seek to buy only verifiably legal and, wherever possible, sustainable timber.
UK government representatives have made it clear that they regard independent forest certification Category A evidence as the best method for suppliers to demonstrate that wood is from legal and sustainable sources. However, in order to conform to EU and WTO rules designed to prevent discrimination against suppliers in areas where there are technical obstacles to certification, the UK government cannot demand that all wood used in public sector contracts be certified. Suppliers must always have an option to provide alternative forms of evidence. The Category B framework has been developed by CPET to provide support to both procurement staff and suppliers on the provision and assessment of such evidence.
In the softwood lumber, OSB and MDF sectors, independently certified wood is readily available and suppliers of these products will generally have little difficulty complying with the Category A criteria. However, for various reasons notably lack of infrastructure, land tenure issues, fragmented forest ownership and political problems in many supply countries distribution networks for certified hardwood lumber and plywood products are still poorly developed. Anybody seeking to supply these products into the UK's public sector will need a good understanding of the role and implications of the Category B framework.
The process to draw up the Category B framework has been a difficult one for the UK government. When an initial draft was put out for review in February, CPET received a very wide range of mainly critical comments. Those stakeholders already able to supply certified products in line with the Category A criteria were clearly determined that the Category B criteria should not provide an easy option for non-certified products to achieve legal and sustainable status. They argued that suppliers should effectively be forced down the certification route. On the other hand, those stakeholders not able to provide certified wood products for various technical reasons, were equally determined that the criteria should provide a real alternative to independent certification and chain of custody. The result is a set of Category B criteria that are rather broad and open to interpretation, as CPET has tried to accommodate these contradictory views.
For proof of sustainability, the criteria effectively set out a specification closely resembling that of a fully operational forest certification scheme. For example, forestry standards must be developed through a consensus-based framework involving balanced representation and input from the economic, environmental and social interest categories. Proof of sustainability also requires that wood is traced back to the specific forest management unit from which it originates.
The fragmentation of ownership in American hardwood forestry makes compliance with certification schemes difficult, even though it ranks among the best-managed in the worldOne significant difference from the Category A criteria is the type of information that will be accepted as evidence that hese conditions are being met. The methodology states that appropriate evidence may include: official documentation such as government permits; company documentation; supplier declarations; and second party verification reports. Third party independent verification is not mandatory and only required if there is any concern about the adequacy, robustness or veracity of the evidence provided.
For proof of legality, the methodology introduces even more flexibility. For example, the criteria for legality are less explicit about the need for full traceability. There is still a requirement that the supply chain is clearly described and complete from point of supply back to the forest(s). But the criteria also state that for timber originating in countries where legal use rights are clear, forest governance is robust and there are functioning mechanisms for monitoring of compliance and public-reporting of non-compliance it may be sufficient information on the country or region from which the timber is sourced.
On the whole, the framework looks a reasonable compromise. In practice, something closely resembling forest certification is likely to remain by far the best method of demonstrating sustainability to the UK government. But other approaches such as independently verified trade association codes of practice and procurement policies such as the Timber Trade Federation's Responsible Purchasing Policy should go a long way towards providing effective assurances of the legality of timber supply.
But there are problems. One is the sheer complexity of the methodology, which may well mean that it is little used. As a result, certification could become a de facto requirement in public sector contracts just to demonstrate legality. And if certified wood is not available, then the tendency will be to substitute other, often less environmentally-friendly, materials.
The requirement for full traceability of individual parcels of wood to a specific forest management unit in order to demonstrate sustainability also creates problems. It will discriminate against wood from smaller private and community forest ownerships due to the extra complexity of trading chains and higher costs of establishing traceability.
For this reason, it will be challenging for most suppliers of American hardwood to demonstrate sustainability. The fact that American hardwoods derive almost exclusively from lands owned and managed by individuals and families is arguably a major factor contributing to their sustainability. But equally, it is a major obstacle in the way of widespread certification.
Another problem arises from the fact that the Category B criteria for legality set a lower burden of proof for wood from countries where forest governance is robust. This is a pragmatic approach designed to ensure that efforts to eradicate illegal wood from trade concentrate only on those countries where this is likely to be a problem. But EU public sector procurement rules state that the same standards for selection of contractors must apply irrespective of point of origin. In practice, this means it may not be possible for CPET to give real guidance on those countries it regards as having robust governance. So it will be difficult to ensure consistent application.
Only time will tell how widely the Category B framework will be applied in the UK. An informal survey of timber traders undertaken for this article suggests that few are even aware that the Category B option exists and there is an assumption that UK central government will, in practice, only accept certified wood. But there is a strong case for keeping the door open to uncertified supplies. As the American hardwood sector demonstrates, there are real technical obstacles to certification of genuinely sustainable forest products in certain situations. Much now hinges on the efforts of CPET to further develop its Category B guidance and to promote the methodology more widely to government authorities at all levels.
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