Last week our Alphabet Soup series defined CITES. CITES is in the news for the flooring industry right now because Mongolian oak and Manchurian ash from Russia (and other species) will be added to CITES listings at the end of the month. I talked to Linda K. Walker, Director, Global Forest & Trade Network-North America about these additions:
Linda, how did these species get added?
Russia's Ministry of Natural Resources and Ecology pushed for inclusion of Mongolian oak (Quercus mongolica) and Manchurian ash (Fraxinus mandshurica) in Appendix III of CITES due to the well-documented levels of illegal logging of these species in the Russian Far East. For example, WWF Russia conducted a comparative analysis of the volume of Mongolian oak legally permitted for harvest in the Russian Far East in 2010 with the "roundwood equivalent" of the volume of exported oak logs, boards and veneer. It revealed that 2 times more oak was logged for export than was permitted by law.
That's compelling evidence. Once the listing goes active, what will happen?
According to our WWF-Russia colleagues, inclusion of oak and ash in Appendix III means that before companies can export these species from the Russian Federation, they will have to present evidence of the legal origin of the timber to the Russian Environmental Monitoring Agency (Rosprirodnadzor). On the basis of that evidence, the agency will decide whether or not to issue an export permit.
The necessity to present such a document will greatly complicate the export of Mongolian oak and Manchurian ash that was logged without any authorization, which should in turn reduce the illegal harvesting. However, the system for collection and checking of documents is still being developed.
So what should buyers look for?Buyers should ensure that they've exercised the due care required of them by laws such as the Lacey Act. Based on what we know about the reliability of documentation for these particular species at this point, we think "due care" here means not just taking documentation at face value, but also analyzing these documents, if possible with the participation of local experts, to ensure that the timber harvest they authorize could really have been the source of the imported products. There are several official documents we expect exporters to offer as documentation:
1) A "forest declaration," the document which determines the location, volume and species composition of timber harvest for forest leaseholders.
2) A purchase contract for conducting of "intermediate logging" (various forms of thinning, intended to improve growing conditions for the remaining trees) or "sanitary logging" (intended to remove sick and dying trees to improve the health and rigor of the stand) in forests not given out under lease.
Examples of the documents mentioned above and others can be found in WWF-Russia's "Keep it Legal" guide.
However, WWF-Russia believes that great care must be taken to develop this system so that fraudulent "multiple use" of logging authorization documents is prevented.What is "multiple use?"There is a limited quantity of such authorizing documents produced in a year, and in theory the volume of oak and ash permitted for logging by these documents should determine how much of these species will be exported from Russia. We do not want to see authorization for X cubic meters of logs be "recycled" and used again. This is often a challenge for buyers who believe they are receiving genuine documentation-because in fact, the document was genuine for the first use, just not repeated uses.
Therefore, in addition to buyers carefully scrutinizing the documentation offered to them, WWF believes it is crucial for the Environmental Monitoring Agency to develop a regularly updated database of the documents presented to the Environmental Monitoring Agency to procure a CITES export permit, and to keep track of the volume exported under each document (keeping in mind that after processing the exported volume will only be a part of the larger, roundwood volume authorized for logging in the documents). This will allow Russian officials to ensure that the same documents are not used multiple times to launder illegally harvested wood.
If such steps are taken, CITES listing could play an important role in excluding illegal Mongolian oak and Manchurian ash timber from the market, and shifting competitive advantage to those companies that operate on a legal basis.
Any other "best practice" recommendations?
Know your source. It is essential that companies know the country of origin of their wood products, as often Mongolian oak and Manchurian ash from Russia can be incorrectly labeled as originating from forests in China or other countries. WWF also recommends that companies source wood products certified by the Forest Stewardship Council, which has developed detailed standards for legality as well as social and environmental considerations for responsible forestry.Thank you, Linda, and thanks to all of the good work you and others at the WWF and GFTN groups do to support legal and responsible trade. Next week, we'll look a bit more at this new CITES listing.