Back in 1998, the seven major industrial countries plus Russia (G8) agreed an action plan designed to improve forest management globally which placed considerable emphasis on the problems of illegal logging. The UK government took upon itself the role of ‘focal point’ for actions on illegal logging within the G8 Forestry Action Plan. The government subsequently made a public commitment to ensure that all wood used in the public sector derived from “legal and sustainable sources”. Most estimates suggest the public sector accounts for between 15-25% of wood used in the UK.

ERM strategy

Earlier this year the government commissioned a consultancy firm, Environmental Resource Management (ERM), to draw up a new public procurement strategy. ERM’s work is complete and its proposals are being chewed over by the Department for Environment Food and Rural Affairs (Defra). The main points of the ERM proposals are:

  • As a minimum, all wood supplied under public sector contracts would have to be derived from legal sources. Suppliers would be required to provide independent verification, from an “appropriately qualified” body, that wood is legally obtained.

  • All wood supplied would be classified into “legal”; “legal and progressing towards sustainable”; and “legal and sustainable”.

  • The emphasis would be on progressive improvement. The government would establish quantitative targets to ensure that all wood eventually comes from “legal and sustainable sources”.

  • The preferred method for suppliers to show compliance would be independent chain of custody audits backed by third party forest management certificates.

  • A set of criteria is recommended to assess forest certification and chain of custody auditing schemes. Only forest certificates and wood product labels recognised as meeting the criteria, following assessment by an expert panel established by the UK government, would be accepted.

    There are some good things about the ERM proposed strategy. It is not an all-or-nothing approach and instead emphasises progressive improvement. It is also inclusive in the sense that several forest certification schemes should be able to conform with the ERM criteria (including the Pan-European Forest Certification scheme, Forest Stewardship Council, and Sustainable Forestry Initiative).

    Chain of custody emphasis

    &#8220An alternative approach would be to require all direct suppliers of wood products to government departments to demonstrate their commitment to a code of practice on environmental timber procurement”

    But there are pitfalls, most notably the heavy emphasis on chain of custody. This may reflect a lack of appreciation of the complexities of the international trade in wood products and of the technical obstacles to the cost-effective tracing of wood products. These obstacles were explored in detail in TTJ (The Missing Link, July 20/27) and will not be reiterated here. It is only necessary to point out that in the absence of widely applicable international procedures for chain of custody, the imposition of requirements for traceability of wood products would almost inevitably lead to the creation of “technical barriers to trade”.

    Wood products would have a hard time competing against non-wood products not subject to equivalent requirements for traceability. There is also likely to be discrimination for and against different wood products based on their ability to meet the chain of custody requirements, rather than on any underlying environmental credentials.

    Trade rules

    This sort of discrimination is frowned on by EU trade rules which are designed to prevent the introduction of technical barriers to trade within the EU. So the UK government may, in any case, be constrained in its efforts to enforce requirements for chain of custody.

    Unfortunately it is now too late to influence the ERM proposals. However, there may be opportunities for the timber trade to influence the process of implementation. Efforts need to be made to ensure DEFRA allows a suitable period of pilot implementation before setting any far-reaching targets. It is my guess that UK government procurement officers will soon find they have difficulty meeting the traceability requirements, particularly for manufactured wood products. If so, the industry needs to be in a position to provide credible alternatives.

    And there is an alternative approach more in line with government procurement strategy in other sectors. This would be to require all direct suppliers of wood products to government departments – whether domestic mills, importers, or manufacturers – to demonstrate their commitment to a code of practice on environmental timber procurement. In developing the code of practice, it would be possible to build on 10 years’ experience in the implementation of the Forests Forever Environmental Timber Purchasing Policy. To add credibility, the industry will need to develop procedures for voluntary independent assessment of conformance with the code.

    Drawing on experience

    It would also be possible to draw on experience from another part of the world in designing this system. In the US, participants in the Sustainable Forestry Initiative (SFI) are required to implement and be audited against a “wood procurement system standard”. Rather than emphasising traceability to forest of origin, this standard requires SFI Program participants to establish management systems to ensure that all their direct suppliers are known, to undertake assessments of the legal and environmental credentials of these suppliers, and to participate in a range of environmental education programmes for suppliers. This standard is helping to promote good environmental practice throughout the US forest sector, not just to the companies and forest owners that are certified.

    There may be a lesson here for the UK government. This is an excellent opportunity for public procurement officers to play a truly progressive role by encouraging UK wood trading com-panies to take on wider environmental responsibilities.