The European Timber Trade Federation (ETTF) commissioned Proforest to carry out an assessment of certification and legality verification schemes against the new EU Timber Regulation (EUTR). The concept was to evaluate current systems that can meet the EUTR due diligence requirements for legal timber and timber products. In general, the assessment by Proforest for Global Forestry Services Wood Tracking Program (GFS WTP) and Legal Verification Services (LVS) are correct, although there are several errors in the final report as it was published prior to incorporating the comments submitted by GFS as presented below.
GFS would like to summarize the corrections to Proforest findings, as stated below:
| Criterion 1.1.3 | The standard requires compliance on legal requirements directly related to timber harvesting concerning: Environment Forest management Biodiversity conservation |
| Proforest findings | Partial Compliance. This criterion is not covered by legal origin. Considered addressed for VLC and TLAS Sabah Standard. |
| GFS Response | GFS recognizes 2 levels of legality VLO (Verified Legal Origin) and VLC (Verified Legal Compliance). The GFS legal Verification Service for VLC is recognized to be in full compliance to EUTR. |
| Criteria 1.1.5 | The standard requires compliance on legal requirements related to trade and customs, in so far as the forest sector is concerned. |
| Proforest findings | Non-Compliance. This criterion is not covered by the requirements of legal origin. Legal requirements related to trade and customs are not addressed beyond forest management level. |
| GFS Response | Proforest only considered the Legal Verification Service that is limited to forest management and operations but did not take into consideration the Wood Tracking Program requirements for the Chain of Custody (CoC). The GFS Wood Tracking Program (WTP) does capture legality in the wood processing mills and trade companies in document # WTP-005 v07 Sept 2012 under Criteria 7.0
7.0 Legal Requirements. The organization shall have adequate knowledge and demonstrate compliance to relevant regulations for its activities and operations. 7.1) The organization shall maintain a register of all relevant governmental regulatory requirements such as health and safety, labour requirements and environmental emissions in respect to their operations. 7.1.1) The organization shall be legally registered and maintain permits for operations. 7.1.2) The organization shall have list and access to all relevant governmental regulatory requirements. 7.1.3) Records of regulations and permits shall be maintained up to date. 7.2 The organization shall demonstrate compliance with all relevant governmental regulatory requirements. 7.2.1) The organization shall demonstrate compliance to regulations. |
| Criterion 1.2.1 | International schemes or scheme operate in more than one country must have a system in place to ensure that forest standard on legal compliance set out in criteria 1.1.1 – 1.1.5 are defined at national level. |
| Proforest findings | Partial Compliance. Not fully addressed as the system does not ensure that all criteria 1.1.1-1.1.5 are defined at national level. Addressed where TLAS Sabah Standard is used. |
| GFS Response | GFS VLC does capture the requirements of National and local regulations that is inherent in the LVS 005 Criteria 4.0-6.0. Again Criterion 1.1.5 is captured under the WTP Criterion 7.0 as stated previously. |
| Criteria 3.1 | Certification/verification must be undertaken by a body which is accredited to evaluate against forest management standard that covers the legality requirements set out in criteria 1.1.1 – 1.1.5 above. |
| Criteria 3.2 | Certification/verification must be undertaken by a body whose organisation, systems and procedures conform to ISO Guide 170653 or ISO/IEC 17021:2011, or publicly available equivalent. |
| Proforest findings | Non-Compliance. No requirement for certification body to be accredited to evaluate against forest management standards, including the legality requirements set out in criteria 1.1.1-1.1.5. |
| GFS Response | Criteria 3.1 & 3.2 are essentially identical. GFS is not an accredited certification body but does operate according to ISO systems and standards. There is no current accreditation system for legality, all companies that issue a statement or certificate of compliance that is actually against the company’s reputation not directly under a regulated accreditation system. Thus the finding against GFS as a third party verification should be partial compliance as the company has formal systems and was found to comply to 1.1.1 – 1.1.4. |
| Criteria 4.1 | Assessment of Chain of Custody must be undertaken by a certification body, which is accredited to evaluate CoC standard. |
| Criteria 4.2 | Assessment of Chain of Custody must be undertaken by a certification body operating in accordance with ISO Guide 65 or ISO/IEC 17021:2006 or publicly available equivalent. |
| Proforest findings | Non-Compliance. No requirement for certification body to be accredited to evaluate against forest management standards including the legality requirements set out in criteria 1.1.1-1.1.5. |
| GFS Response | Again, Criteria 4.1 & 4.2 are essentially identical to 3.1 & 3.2 but are now used for Chain of Custody systems. GFS is not an accredited certification body but does operate under formalized procedures according to ISO systems and standards. GFS is now collaborating with Bureau Veritas to address the issue of accreditation under their Due Diligence System (DDS). |
| Criterion 4.4 | If mixing of certified/verified and uncertified/unverified material in a product or product line is allowed, the uncertified/unverified material must be covered by a verifiable system which is designed to ensure that it complies with legality requirements set out in criteria 1.1.1 – 1.1.5 above. |
| Proforest findings | Partial Compliance. Not compliant for VLO, but addressed for VLC, where other 3rd party schemes used deliver compliance. |
| GFS Response | GFS WTP does NOT permit mixing of non-verified material under the COC requirements. VLC material may be used to make a VLO product. GFS also recognizes other 3rd party verification systems under the WTP as a measure to mitigate risk. The global market cannot afford for verification organizations to exclude other independent assessments and only recognize their own system especially since legality MUST be defined according to local laws and regulations. |
Summary:
GFS actually complies to most all the requirements of the EUTR in regards to the Wood Tracking Program coupled with the Legal Verification Service for Verified Legal Compliance. Global Forestry Services is a technical forestry specialist company that can provide independent verification but is not a Certification Body thus does not comply to Criteria 3.1; 3.2; 4.1 & 4.2 in the Proforest report that references requirements for accreditation. GFS is currently collaborating with Bureau Veritas on their new Due Diligence System so clients under GFS WTP will have the option of adding certification with Bureau Veritas to fulfill the requirements for accreditation.
In Sabah, Malaysia, GFS conducts monthly field assessments to cover all licensed forest areas as part of the ongoing Sabah Timber Legality Assurance System (TLAS). GFS reports compliance to the Sabah Forestry Department and posts summary reports on the GFS website under the client database that is updated monthly. GFS has already conducted field assessments using the EU supported Sabah TLAS requirements for over 15 forest management units with new areas being added each month. Current and future GFS Wood Tracking Program clients especially in Sabah Malaysia that include the BV DDS risk assessment using verified legal compliant (VLC) timber and products will be able to meet the due diligence requirements of the EUTR.