PEFC SEMINAR

20-4-1999

By Saskia Ozinga, Coordinator Fern UK

Thank you Mr Chairman and the organisers, for inviting European NGOs. My name is Saskia Ozinga. I am working for an environmental NGO in Brussels and the UK called Fern, which monitors and influences EU activities on forest issues.

Fern coordinates NGO activities at the EU level. Therefore many of the joint NGO position papers on certification, as well as on other issues, which you might have seen were drafted and co-ordinated by my organisation.

I am also the co-ordinator of the Forest Movement Europe (FME), an annual gathering of European NGOs working on forest issues. Participants to the FME meeting include Greenpeace, Friends of the Earth, WWF and many national organisations from most European countries.

What I hope to convey is that I, and I suspect other environmental NGOs, can understand why forest owners and part of the forestry industry have decided to set up their own certification scheme. I can personally sympathise with that approach and even with some of the content of the scheme. Nonetheless I think it is a pity that forest owners did not feel able to work within the framework of the FSC, as environmental NGOs are not likely to support the PEFC now or in the near future.

Before I will go into detail of the NGO's reservations on the PEFC, I would like to take a step back and give you my personal opinion on the history of the certification discussion.

My speech will therefore contain the following three elements:

1) How certification became an issue (on personal title)

2) NGO response to PEFC (representing the FME position)

3) Conclusions (representing the FME position)

In the mid 1980s European environmental NGOs received requests from NGOs and Indigenous Peoples Organisations in the South (i.e. Malaysia, Indonesia) to support their local, regional and national struggles to save their forests. This resulted in campaigns all over Europe for the recognition of land rights of local people and campaigns to restrict the import of tropical timber, often translated as boycotts, so that no timber from these disputed areas could enter Europe.

By focusing on tropical timber the message the general public understood, was "tropical timber is wrong and non-tropical timber is right". In the 1990s NGOs in timber producing countries in the North (mainly Scandinavia and Canada) strongly objected against this message as they felt the forest management in their countries was in many cases as bad as in the tropics and needed overall great improvement.

The NGOs campaigning in consumer countries therefore had to reformulate their message. For most of them it was clear that timber coming from sustainably managed forests is -from an environmental point of view- better than some plastics (particularly PVC and polystyreen) and aluminium. However timber from badly managed forests, or from areas where local people's rights were not respected, had to be avoided. A mechanism needed to be found to allow consumers to make that distinction.

That is why for many NGOs, like Friends of the Earth Netherlands, certification came into the picture. NGOs, together with forestry industry people and representatives of indigenous communities created the FSC to promote environmentally appropriate, socially beneficial and economically viable management of the world's forests.

After a long and often difficult consultation period of several years the FSC was created in 1993. Now 6 years after its conception, the FSC has certified 15 million ha of forests of which 9.8 million ha are in Europe. These figures might indicate that forests in Europe are generally better managed than forests outside Europe, but there are many exceptions. The following figures however show that forest management in Europe needs a lot of improvement:

Still the situation is that most FSC certified timber comes from Europe and the main market for FSC certified timber is also in Europe. A big part of European forests is owned by small forest owners, who's market is mainly Europe. Hence European forest owners were directly confronted with certification.

It was clear from the beginning, based on several press releases that were sent out by forest owners organisations and the CEPF, that forest owners felt hostile towards the FSC. They felt FSC did not meet their needs for several reasons of which the two most important were 1) FSC was not suitable for small forest owners 2) FSC was totally led by NGOs

However I believe there was a strong psychological element involved: forest owners were unprepared, as they had not been involved in the international discussions on certification, and felt confronted with a process over which they felt they had no influence and which could affect them deeply. And it might be true to say that FSC and particularly the FSC supporters in Europe could and probably should have done more to actively engage forest owners in the certification processes from the start.

The forest owners' initial response to the 'certification debate' was "certification of European forests is not necessary, as all European forests are already managed sustainably". Although an understandable response, that claim is definitely not true. In several countries forest owners or their associations, brought so-called 'labels of origin' on the market. In short: the total response was very similar to that of the governments and timber industry of Malaysia and Indonesia a few years earlier. No NGOs can accept these sort of claims. I therefore think it is a step forward that forest owners are now truly thinking about certification and are developing a certification system, i.e the PEFC.

However I do feel it would have been better if, rather than setting up a new system, they would have joined the FSC. Although it might not be perceived as such, the FSC has proven to be a relatively flexible and open system and can and has been influenced according to its member's needs. There are at least three clear examples of this:

Changes within FSC

1) At the founding assembly NGOs were given 2/3 of all votes. Due to complaints by among others industry, there is now an equal division of votes between the social, the economic and environmental chamber.

2) On requests of small businesses and forest owners the FSC has set up a scheme for group certification.

3) The FSC's Principles and Criteria have been changed, particularly the two principles about logging in primary forests (9) and plantations (10)

4) FSC is in a continuing process to deal with "percentage based labelling", an issue which is particularly important for Northern NGOs and Northern industry.

If forest owners had decided to focus all their energy and resources on getting their needs addressed within the FSC system rather than on creating a 'new European system' the end result might have been better. For the forests, for the forest owners, and possibly for the FSC. However they decided not to and the PEFC has now been created.

NGOs feel they can not support the PEFC system. There are many reasons for this, which I will elaborate on below. However reading the drafts available ("The common elements and requirements" and "The Statutes") the system comes across as extremely vague. A lot more needs to be developed.

Although the PEFC paper states that requirements are defined for the following aspects: certification criteria; application; audit and certification procedures; chain of custody and product labelling; none of these are sufficiently dealt with. Particularly the certification criteria and the chain of custody elements are lacking.

The FME has discussed their concerns last week in Munchen and has presented them last Friday in Mainz. I will here elaborate on these concerns:

There are as yet no performance based certification criteria developed. The PEFC document states that the criteria to be developed will be based on the six Pan-European Criteria. That is strange as these criteria as well as the indicators developed for these criteria have no relation to certification and are in many cases not even relevant for sustainable forest management. These criteria were purely developed for Governments to assess their national forest policies and to be able to follow up commitments made at UNCED (UN Conference on Environment and Development) in Rio de Janeiro in 1992 and during the IPF (Intergovernmental Panel on Forests) process. Therefore the PEFC documents give no guarantee that the PEFC will indeed lead to improvement of forest management.

It would have been a step forward if the PEFC documents had stated that the system was going to be based on the PEOLG (Pan European operational Level Guidelines). Although these Guidelines have not been developed for certification -and it is stated in these Guidelines that certification would remain independent from the Pan European Process- they do provide much more of a basis for a certification scheme.

I personally think the PEOLG are quite good guidelines. However even they should be improved to:

1) ensure no logging of old growth forests in Europe will take place

2) put more emphasis on restoration of all forest types which have nearly disappeared 3) ensure all customary rights of Indigenous Peoples (Sami!) are fully respected.

It is therefore very surprising that the PEFC document states criteria will be based on the six Pan European Criteria and that the PEOLG will only "be considered".

It is also not clear what is being certified. NGOs have always argued that certification should take place at the Forest Management Unit level, or in Group certification schemes. The PEFC document mentions regional certification. Regional or national certification would never be acceptable to NGOs as it would not give the necessary information to consumers.

I am sure most of you would agree that a system for setting safety standards for cars would not have much credibility to the outside world if the safety criteria were solely set up and decided upon by the car manufacturers. However that is exactly what the current PEFC documents state in terms of development of the criteria for sustainable forest management. I think most people would agree that is not a desirable situation.

It is clear from the statutes that the PEFC will be a membership organisation. However the only members with voting rights are the national governing bodies. National governing bodies will be set up by forest owners associations who can (bit are not obliged to!) invite national organisations representing (equally?) all relevant interested parties. The higher the annual cutting rates the more votes -to a maximum of three- the national governing bodies have in the General Assembly.

This all makes clear the PEFC is an organisation by and for forest owners. That would be no problem if the attempt was not to provide a credible label for consumers that has to indicate that the forests are managed sustainably.

3) The PEFC label has to be a credible label. That means it should be clear for consumers that the forests the product is derived from are managed sustainably, according to the criteria developed. It also means there should be a chain of custody in place as well as a control system to check whether the forest manager continues to act in line with the certification. Currently there is no chain of custody and consequently there should be no discussion about a label. There is in the document no clear description of a control mechanism.

3) Conclusions

• European NGOs welcome the increasing openness of forest owners and forest owners associations towards forest certification.

• European NGOs do not see a need for the creation of a new European certification scheme as the FSC is operational in Europe
• European NGOs acknowledge that forest owners have had problems with FSC. However forest owners are encouraged to start a dialogue with FSC on how FSC can better meet their needs.

• There will be not much support from European NGOs for the current plans for a PEFCS, because:

1) There are no performance based criteria formulated in the scheme. The six Pan European Criteria do not provide a basis.

2) The scheme is run by and for forest owners and needs structural changes to ensure the equal input of other sectors will be taken on board.

3) There is no chain of custody nor an effective control mechanism in place.

4) The scheme only addresses European forests

Thank you Mr. Chairman