As is usual with such reports from well-respected NGOs, Failing the Forests immediately generated exaggerated headlines in the national press. On November 23, The Daily Telegraph stated that “Britain is the biggest importer of illegally-logged timber in Europe, responsible for destroying an area of the world’s forests three times the size of Luxembourg each year… Britain’s market for timber, the largest in Europe, is fuelling the destruction of 1.4 million acres of forest a year”.
So the report has done its work, raising alarm amongst the consuming public and nudging politicians another step in the direction desired by WWF. The first recommendation of Failing the Forests makes clear what WWF believes is the appropriate direction: “as a matter of urgency the EU must develop legislation which prohibits the import of illegal timber and wood products into the EU”.
But even a brief review of the WWF report suggests its arguments rely on inadequate data. Its claims are highly sensitive to assumptions made about levels of illegal trade in Russia and the Baltic states as these two regions account for such a high proportion of EU imports. And the approach adopted by WWF fails entirely to acknowledge recent efforts by the importing industry to improve traceability of imported wood products. When these other factors are taken into account, the case for the adoption of indiscriminate EU-wide legislation on all wood imports begins to look very shaky.
The WWF report assessed illegal wood imports into the EU using a very crude analytical procedure. It estimated the proportion of logs alleged to be harvested ‘illegally’ in six regions supplying timber to the EU where this form of harvesting is believed to be most prevalent (Russia, Baltic states, Congo Basin, East Africa, Indonesia, and Brazil). It then assumed that the proportion of ‘illegal wood’ sourced by the EU from these regions is equivalent to the WWF’s estimates of illegal harvesting.
One weakness of this approach is that WWF’s estimates of illegal logging levels in the six regions can only be extremely tentative. The difficulties of making a realistic assessment of levels of illegal imports from a particular region are well illustrated by the Baltic states, a point well made in another report published by WWF Latvia in 2003 entitled The features of illegal logging and related trade in the Baltic Sea region. Drawing on a survey of forestry experts in the region, the WWF Latvia report shows that, depending on the definition used, estimates of ‘illegal logging’ in the Baltic states vary from as little as 0.5-2.5% to around 50%. The lower estimate assumes that ‘illegal logging’ includes only laws directly related to forestry activity (such as logging without a felling licence). The higher estimate refers to Estonia and assumes that ‘illegal logging’ includes a wide range of broader issues, including violation of tax, social and other legislation issues.
The WWF Latvia report makes clear that the state authorities in the Baltic countries can provide only fragmented information on these alternative forms of ‘illegal logging’. It also demonstrates that the timber trade may have only limited leverage to tackle underlying causes. Factors driving these forms of illegal logging include: low income levels and unemployment in rural areas; gaps and conflicts in existing regulations; overly complicated tax regulations; inefficiency of the tax authorities; poor state forest authority performance; and fragmented forest ownership (there are almost 400,000 private forest owners with limited knowledge and experience in forestry).
Another serious flaw of the WWF analysis is the assumption that there is a direct correlation between the volume of illegally harvested wood in a particular region and the volume of EU imports of illegal wood. A report published by the European Forestry Institute in October 2005* demonstrates that this assumption is misplaced. The report indicates that about 75% of the volume of timber imported from the north-west Russia into the EU is covered by a proprietary tracking system that is either certified to ISO 14001 or EMAS registered. As these systems explicitly include provisions to exclude illegal material, these should provide an adequate level of assurance that only legal timber is handled. So even if the WWF estimates of levels of illegal logging in north-west Russia are reliable (EFI suggests they may be overstated), voluntary measures by the EU importing trade are already fairly effective at screening out illegal wood.
In time, a case may be made for tighter controls on imports of ‘illegal timber’ into the EU – but not on the basis of the WWF report. Any move to tighten EU import legislation should follow a well informed debate on the appropriate definition and scope of ‘illegal logging’. This debate needs to take into account a realistic assessment of the leverage that may be applied by the EU importing trade over different aspects of ‘illegal logging’.
In fact, currently available information highlights the merits of the existing approach adopted by the European Commission through the FLEGT Action Plan. This approach involves development of Voluntary Partnership Agreements with a relatively limited number of countries known to have significant problems with illegal logging. These agreements provide an opportunity to gain experience of the practical problems associated with defining illegality in the forestry sector, and of the challenges involved in developing systems of legality licensing. This approach is being combined with support for private sector initiatives – such as the Tropical Timber Trade Action Plan – that aim to encourage wider adoption of timber tracking procedures in problem countries.
