World trade in illegal wood-based products
Under construction

The following pair of charts illustrate the relative scale of and trends in most trade in illegal wood-based products. The scale and trends shown are unlikely to correlate closely with production of illegal wood-based products for end-use in countries of production.

Chart 1 - Imports of illegal wood-based products

Chart 2- Exports of illegal wood-based products

Chart 1 indicates that, during recent years, China has probably imported a greater roundwood equivalent ("RWE") volume than the rest of the world combined. Chart 1 also indicates not only the extent to which trade declined during the recession at the end of last decade but also the likely reality that the impact of the amended Lacey Act and EC Regulation 995/2010 on the quantity of illegal trade has been indiscernible - except perhaps in relation to the EU's imports. However, the trend shown merely reflects the assumptions made in the evaluation. For example, the evaluation assumes that most of the tropical timber which the EU imports from Africa derives from FSC-certified forest and that this is legal. Chart 1 suggests that the EU's illegal imports are supplied primarily from countries with which a VPA is unlikely to be established - China, Russia, and some east European countries.

Chart 2 indicates that Indonesia supplies a greater RWE volume of illegal wood-based products (primarily as pulp and paper) than even China. However, China probably exports rather more than any other country in terms of export value. Concerning Indonesia, a number of the mills of the major producing groups were cerified under what is now a discredited variant of the SVLK. There has not been a formal, dissuasive, public process of forgiveness of these groups (or any others) for the gross illegality and unsustainability of their business, whether or not the illegality took place prior to a "threshold" date (the FSC has adopted November 1994 as a threshold for certifying plantations if these have been established on land which was forested until more recently than that date).

This - and increasing awareness that illegal forest clearance accounts for much of the wood raw material consumed in Indonesia (and eslewhere) - is not consistent with rhetoric which suggests that Indonesia will soon be one of the first countries to commence the routine supply of FLEGT-licenced products.

An Achilles Heel of the EU's FLEGT Action Plan is its (arguably pragmatic) negligence of the well known illegalities which take place prior to the allocation logging or clearance rights. Those illegalities are fundamental to determining whether production of palm oil, rubber, sugar, cattle products, soy, minerals, etc on land which was cleared of forest in order to enable that production. Amongst other things, this negligence tends to accelerate climate change (directly through forest clearance and degradation, and indirectly by minimising financial costs and maximising profits thus further stimulating the paradigm of unsustainable growth and consumption and delaying the sort of governance which must become established to equitably change that paradigm).

Whereas the FLEGT Action Plan will have facilitated changes in forest governance, it might be reasonable to attribute significant changes in forest governance and related trade to other intiatives, such as support for independent monitoring and the response of some in the trade to central government procurement policy (both of which predate the Action Plan), not to forget efforts to segment the market more generally through certification and the contribution of bilateral intitiatives from EU member states.

It might be premature to initiate components of the Action Plan which depend on FLEGT-licensed products being supplied in substantial quantity as a matter of routine until there is much greater certainty that such supplies will take place (with a credible licensing system).

The intent of EC Regulation 995/2010 was published more than four years ago. That regulation sets out to provide greater incentive than available through a VPA alone for partner countries to establish good governance in the supply of wood-based products. However, there appears to be no attempt to use that regulation in this manner - particularly in addressing the supply of illegal wood-based raw material from VPA contries to maufacturing hubs in third countries for subsequent export (including to the EU) or end-use in that third country.

Given that China dominates the production of illegal logs for export in many countries that are characterised by poor governance, both in the tropics and elsewhere, imports from China should be receiving much greater attention from Competent Authorities in the EU member states which account for most of the RWE volume which China exports to the EU. The UK imports a greater RWE volume of wood-based products (and probably illegal wood-based products) from China than any other EU member state, and should therefore take a lead in minimising the EU's imports of illegal wood-based products from China.


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