Forestry requirements in Nordic Ecolabelling criteria

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1 Forestry requirements in Nordic Ecolabelling criteria Version 3 - Consultation document Consultation: 9 March June 2015 Nordic Ecolabelling

2 Contents 1 Summary 3 2 Introduction 3 3 Background to forestry requirements 4 4 Proposal for future forestry requirements 5 Appendix 1 Declaration for wood raw material Appendix 2 Certified wood raw material Nordic Ecolabelling s general forestry requirements, version 3, 9 marts 2015 This document is a translation of an original in Danish. In case of dispute, the original document should be taken as authoritative. Addresses In 1989, the Nordic Council of Ministers decided to introduce a voluntary official ecolabel, the Nordic Ecolabel. These organisations/companies operate the Nordic ecolabelling system on behalf of their own country s government. For more information, see the websites: Denmark Ecolabelling Denmark Danish Standards Foundation Portland Towers Göteborg Plads 1 DK-2150 NORDHAVN Tel: Fax: info@ecolabel.dk Norway Miljømerking Henrik Ibsens gate 20 NO-0255 OSLO Tel: Fax: info@svanemerket.no Finland Ecolabelling Finland Box 489 FI HELSINKI Tel: joutsen@ecolabel.fi Sweden Ecolabelling Sweden Box SE STOCKHOLM Tel: Fax: svanen@ecolabel.se Iceland Ecolabelling Iceland Umhverfisstofnun Suðurlandsbraut 24 IS-108 REYKJAVIK Tel: Fax: svanurinn@ust.is This document may only be copied in its entirety and without any type of change. It may be quoted from provided that Nordic Ecolabelling is stated as the source.

3 1 Summary The first forestry requirements were drawn up by Nordic Ecolabelling in 1998, and have since been revised several times. Nordic Ecolabelling has included forestry requirements in all criteria documents that involve significant quantities of wood raw material since An evaluation of the forestry requirements in 2014 indicated a need for a new update to the requirements, not least to accommodate changes to the legislation. The EU has now introduced the European Union Timber Regulation (EUTR) 1, which both affects and supports the forestry requirements, while new Danish regulations for public procurement of wood raw materials do not recognise the Nordic Ecolabel as a guarantee of legal and sustainable wood. There is thus a need for the requirements to be simplified and made more transparent, since they are difficult to communicate to others. Proposed new forestry requirements: Information on the species of tree and the origin of the wood raw material New requirement that wood raw material originating from countries or regions with high levels of corruption (CPI rating below 40) should not be used in Nordic Ecolabelled products unless a further risk assessment of the area is conducted. The risk assessment is to be conducted by Nordic Ecolabelling All wood raw material that is used in Nordic Ecolabelled products must comply with the European Union Timber Regulation (EUTR) (No. 995/2010) All wood raw material (100%) used in Nordic Ecolabelled products must be certified or controlled. A minimum of 70% by weight of all wood raw material used in the Nordic Ecolabelled product must come from certified forestry. The remaining proportion of wood raw material must come from controlled sources. New requirement to allocate certification credits to the Nordic Ecolabelled product/production Requirement for traceability certification, where possible 2 Introduction The Nordic Ecolabel is the official ecolabel in the Nordic countries. It was established by the Nordic Council of Ministers in The Nordic Ecolabel is a voluntary scheme that ecolabels both products and services. Nordic Ecolabelling develops criteria based on a life cycle perspective. Raw material inputs, use, disposal and recycling are included in the assessment, when drawing up the requirements for an ecolabelled product. It is important to be able to reduce the overall environmental impact. Alongside environmental requirements, the criteria also include requirements for product properties in order to ensure quality and performance. The criteria for Nordic Ecolabelling are revised on an ongoing basis. Nordic Ecolabelling sets requirements to wood raw materials in relevant criteria in order to contribute to sustainable forestry (ecologically, economically and socially). From a life cycle perspective, forestry is a key part of the wood product s environmental impact, and 1 Criteria document Forestry (12)

4 it is important that the renewable raw material is grown/used in a sustainable way. Nordic Ecolabelling s forestry requirements focus on sustainable forestry and traceability of the wood raw material. By setting a requirement that the wood raw material must come from certified forestry, Nordic Ecolabelling supports the drive towards more sustainable forestry. This consultation document presents suggested new forestry requirements. The proposal is then that these requirements will be introduced into the 18 product groups 2 that currently have forestry requirements. This consultation gives you the opportunity to put forward your views and comments on the proposal. All submitted comments will be considered and assessed in a published consultation summary. On the basis of this, a revised proposal for forestry requirements will be drawn up, and this will be considered by each Nordic board. The Nordic Ecolabelling Board will then decide on the final requirements. 3 Background to forestry requirements Sustainably managed forests deliver a wealth of benefits for society, beyond the wood for materials and energy. The forests slow global warming by capturing and storing CO 2, they provide daily necessities for local communities and indigenous peoples, ensure biodiversity (wild animals and plants), protect water and soil from pollution and erosion, and so on. Nordic Ecolabelling began an evaluation of its general forestry requirements in The main objective of this evaluation was to check whether Nordic Ecolabelling s current forestry requirements have a sufficient environmental impact. It has been proven that certification of forests brings environmental gains 3, although it can be difficult to quantify the effects that the forestry requirements in Nordic Ecolabelling s criteria have on specific environmental issues such as biodiversity. Nordic Ecolabelling s steerability, i.e. the ability of the ecolabels to influence the process of developing standards for forest certification, is very small. By setting requirements for certified wood raw material, Nordic Ecolabelling can help to increase demand for certified wood. Nordic Ecolabelling has chosen to support the development of forest certification that strives to achieve sustainable forestry, by setting requirements for wood raw material from certified forestry. Forest certification is an important tool in encouraging forestry towards more sustainable practices, with the forestry methods described and followed up/tightened through ongoing revisions. As manufacturers switch to certified wood raw material, this also sends a signal to the forest industry that it is important to recognise and reduce the environmental impact of forestry. The change to certified wood raw material can thus be considered an environmental gain. Nordic Ecolabelling influences this development directly by constantly tightening the requirement for a percentage of certified wood in its criteria documents. 2 Basic module Paper, which includes Nordic Ecolabelling controlled pulp and paper, Fuel, Panels for the building, decorating and furniture industry, Grease-proof paper, Disposables for food, Floor coverings, Durable wood, Sanitary products, Small houses, apartment buildings and pre-school buildings, Copy and printing paper, Printing companies, printed matter, envelopes and other converted paper products, Toys, Furniture and fitments, Biofuel pellets, Office and hobby supplies, Tissue paper, Outdoor furniture and playground equipment and Windows and exterior doors. 3 Criteria document Forestry (12)

5 At the moment, Nordic Ecolabelling approves current forestry standards individually in the countries from which the licence applicant sources its wood raw material. This is a labour-intensive process, and an important question in the evaluation was whether the requirements could be simplified to full approval of certification schemes such as FSC and PEFC, either through national or interim standards. One reason for this is that an individual assessment of forestry standards has shown that the quality of the standards has improved greatly since the beginning of In addition, the EU has introduced new legislation banning the marketing and sale of illegally harvested wood in the EU. The evaluation had a particular focus on producing a recommendation for the formulation of simpler forestry requirements in the future. To assist in the evaluation, an external consultancy firm (Indufor) has assessed Nordic Ecolabelling s current forestry requirements and worked on an assessment of the forestry standards. There has also been an internal evaluation of the complexity of the forestry requirements, and the workload involved in licensing products and services. 4 Proposal for future forestry requirements The starting point for Nordic Ecolabelling s proposed future forestry requirements below is that they will apply in all the criteria where wood raw material has some relevance. The new proposal divides the forestry requirements into two: Requirement O1 covering the origin, legality and traceability of the wood raw material and Requirement O2 covering wood raw material from certified forestry Proposed requirement O1 Origin, legality and traceability The applicant must state the name (Latin and a Nordic language) and geographical origin (country/state and region/province) and suppliers of the wood raw material used. Wood raw material originating from countries with a corruption index (CPI) of less than 40 should not be used in Nordic Ecolabelled products, unless a further risk assessment of the area is conducted. The risk assessment is to be conducted by Nordic Ecolabelling. The requirement concerning the CPI applies at the time of application. Information on the CPI can be found at Wood raw material that is used in Nordic Ecolabelled products must comply with the European Union Timber Regulation (EUTR) (No. 995/2010). This also applies to products that are currently exempted in EUTR. The licensee has a duty to inform Nordic Ecolabelling, if it becomes aware of any breach of the legality principle in EUTR, either in its own operations or in its supply chain. Tree species listed on CITES, appendices I, II and III must not be used in Nordic Ecolabelled products. Information on the appendices to CITES can be found on the CITES Appendices website: Criteria document Forestry (12)

6 Name (Latin and a Nordic language) and geographical origin (country/state and region/province) and CPI rating, plus suppliers of the wood raw material used. Nordic Ecolabelling may require further documentation in the event of uncertainty about the wood raw material s origin. Appendix 1 completed by manufacturer/supplier. In cases where the wood raw material comes from areas with a CPI of less than 40, an external risk analysis in line with EUTR may be included as documentation. Declaration from the manufacturer/supplier that all the wood raw material complies with the European Timber Trade Regulation (No. 995/2010). Appendix 1 may be used. Declaration from the manufacturer/supplier that wood raw material listed on CITES, appendices I, II and III is not used in the Nordic Ecolabelled products. Appendix 1 is to be completed by manufacturer/supplier. Background to requirement O1, Origin, legality and traceability Origin Nordic Ecolabelling sets requirements concerning traceability in order to gain information about which tree species are used in Nordic Ecolabelled products and information about where they come from. The names of the suppliers therefore have to be provided. In setting requirements concerning traceability, Nordic Ecolabelling wishes to ensure that wood and wood raw materials come from legal sources, and not from areas with high biodiversity, protected forest, areas where ownership is unclear, and so on. The requirement supports the proposed requirement that wood raw material originating from countries or regions with high levels of corruption should not be used in Nordic Ecolabelled products, unless a further risk assessment of the area is conducted (see below). The requirement is to be documented by the wood raw material supplier or the manufacturer of the Nordic Ecolabelled product. Appendix 1 completed by manufacturer/supplier. CPI rating Nordic Ecolabelling does not want wood raw material originating from countries or regions with high levels of corruption to be used in Nordic Ecolabelled products, unless a further risk assessment of the area is conducted. Information on Nordic Ecolabelling s risk assessment practices is presented below. In reviewing the forest standards, Nordic Ecolabelling has found that there are often major problems associated with forestry in areas with high corruption, even if the forestry itself is certified. Transparency International s Corruption Perceptions Index (CPI) assesses and ranks countries/territories, based on how corrupt a country s public sector is considered to be. The summary index is a combination of investigations and assessments of corruption that are gathered by a number of reputable institutions. The CPI is a widely used tool in risk assessments, and it is also referred to in the draft of the EUTR user manual. The CPI is updated annually. A CPI rating of less than 40 means that a country has been judged as a high risk region or risk region by Transparency International. The requirement for a CPI rating of less than 40 is not intended as an absolute requirement, but means that Nordic Ecolabelling will conduct a further risk assessment if the wood raw material comes from these Criteria document Forestry (12)

7 countries. Certified wood raw material from areas with a CPI rating of less than 40 is not, in itself, sufficient documentation of legal and sustainable wood raw material. The requirement concerning the CPI applies at the time of application. Risk assessment by Nordic Ecolabelling In cases where the wood raw material comes from areas with a corruption index of less than 40, Nordic Ecolabelling conducts a risk assessment of the areas concerned. The risk analysis assesses five parameters: corruption/legality, traditional/civil rights, biodiversity/high conservation value, converting natural biotopes for other purposes and GMO. The five parameters are the same as those included in the Global Forest Registry s 4 risk analyses. For information on corruption/legality, risk analyses in line with EUTR and other sources are used. Additional information for the risk analysis is drawn from a number of relevant websites, including: The illegal logging website: The CPI of Transparency International: The World Bank: Environmental Investigation Agency: Global Witness: ELDIS regional and country profiles: Responsible Investment and Purchasing Advice Centre (ReIPAC) run by ProForest for subscribers: The Global Forest Registry CITES: IUCN Red list: EU Timber Regulation: In cases where the analysis shows a low risk, the wood raw material may be used in Nordic Ecolabelled products. The applicant may, as documentation, submit external risk analysis reports for the areas with a CPI rating of less than 40. External risk analysis must include an assessment of the 5 parameters: corruption/legality, traditional/civil rights, biodiversity/high conservation value, converting natural biotopes for other purposes and GMO. External risk analysis reports will be included in Nordic Ecolabelling's overall risk assessment of a given area. EUTR Although in Europe illegal wood is banned under the European Union Timber Regulation (EUTR) (No. 995/2010), it is widely known that illegal logging remains a common practice in some countries. A joint study by the United Nations Environment Programme and Interpol, reported in 2012, stated that illegal logging accounted for up to 30% of the global trade in wood and contributes to over 50% of the destruction of tropical rainforest in Central Africa, the Amazon and South-East Asia Illegal Logging Trade Decimates Forests, Africa: AllAfrica.com, 2012, retrieved 18 October 2012 Criteria document Forestry (12)

8 An official duty was imposed on all traders in wood and wood products in the EU, including those who only resell wood and wood products after the wood has already entered the EU market, to keep track of whom the wood was bought from and whom it was sold to. The requirement concerning traceability will oblige Nordic Ecolabelling s licensees to ask their operators, either directly or via agents, for information about their due diligence, including information about where the wood raw material comes from. This also applies to wood raw materials that are exempted in EUTR. EUTR covers a broad spectrum of products, including raw wood, sawn and processed wood, furniture and prefabricated buildings, plus a long list of products that contain paper and board, while many other products (listed by commodity code) are exempted 6. Nordic Ecolabelling wants all wood raw material used in Nordic Ecolabelled products to comply with EUTR. The licensee has a duty to inform Nordic Ecolabelling, if it becomes aware of any breach of the legality principle in EUTR, either in its own operations or in its supply chain (non-compliance flagged up by national supervisory authorities). In this case, Nordic Ecolabelling will determine how serious the breach is and what impact this has on the ecolabel licence. It is likely that these exemptions will be removed when EUTR is revised in 2015/2016, but until then, the requirement remains valid. Certified wood is not automatically considered as legal wood under EUTR (according to the European Commission). Both PEFC and FSC have begun a review of their Chain of Custody standards in order to comply with the provisions in EUTR. Both schemes have, however, already made adjustments that will help the certified operations to meet the requirements in EUTR. In the view of Nordic Ecolabelling, certification or other schemes that are controlled by an external party, and that involve control of compliance with applicable legislation and have sustainability requirements, may be used in the risk assessment. When applying for the Nordic Ecolabel, the supplier/manufacturer must check EUTR and the exemptions set out in the legislation. If their products are exempted by EUTR, they must still declare that the input wood raw material is legal under the rules of EUTR. Appendix 1 can be used for documentation purposes. CITES CITES 7, the Convention on International Trade in Endangered Species of Wild Fauna and Flora, focuses on monitoring and regulation of the international trade. The aim is to only permit sustainable trade i.e. removing no more from populations of wild animals and plants than they can bear. In practice, this means that special licences are required for, or in some cases there is a complete ban on, trade in certain animals and plants living and dead, and products made from their fur, feathers, teeth and so on. CITES covers around 5,000 animal species and around 28,000 plant species, of which approximately are timber-relevant tree species (primarily tropical tree species). Depending on how endangered they are, the species are listed in either appendix I, II or III. Species listed in appendix I are significantly endangered and trade in them is totally forbidden. Otherwise, special permits are required for import and export (appendices II Convention on International Trade in Endangered Species 8 Criteria document Forestry (12)

9 and III). CITES is regulated by EU legislation (Council Regulation (EC) No 338/97) and valid CITES licences are considered to represent legal harvesting in line with EUTR. A consistent problem with the existing systems that seek to regulate the trade in wood or endangered species (e.g. CITES) is that the necessary permits are often sold off cheaply in the export country, due to endemic corruption 9. Nordic Ecolabelling therefore proposes that the tree species listed in appendices I, II and III of CITES should not be used in Nordic Ecolabelled products even if the CITES licences comply with EUTR. Nordic Ecolabelling sees no justification for using tree species listed in CITES, as there are alternative species available. O2 Wood raw material from certified forestry All wood raw material (100%) used in Nordic Ecolabelled products must come from certified forests or controlled sources. A minimum of 70% by weight of all wood raw material (virgin/recovered fibre) used in the Nordic Ecolabelled product must come from certified forestry. The remaining proportion of wood raw material must come from controlled sources, i.e. be covered by the control schemes FSC or PEFC (controlled wood). The certification must be carried out by FSC or PEFC, i.e. by an independent third party. The requirement may be documented as annual purchases of wood. Certified wood raw material is to be allocated to the Nordic Ecolabelled production/product. Applicants must document that at least 70% of all wood raw material (virgin/recovered fibre) used in the Nordic Ecolabelled product on an annual basis comes from certified forestry, and they must document that the remaining proportion of wood raw material is covered by a control programme. The traceability system must be described. Chain of Custody Certificates issued by FSC and PEFC may be used to document traceability. Appendix 2 may be used. Balance sheet or equivalent documentation showing that the quantity of certified wood raw material on an annual basis is allocated 10 to the Nordic Ecolabelled production/product. Background to O2, Wood raw material from certified forestry A minimum of 70% by weight of all wood raw material (virgin/recovered fibre) used in the Nordic Ecolabelled product must come from forestry certified under the FSC or PEFC schemes. The remaining proportion of wood raw material must come from controlled sources, i.e. be covered by the control programmes FSC or PEFC (controlled wood). The requirement also specifies that certified wood raw material must be allocated to the Nordic Ecolabelled production/product (rules on mass balance). This is to ensure that double-entry bookkeeping does not occur. The background to this, in addition to stimulating increased demand for certified wood raw material, is that these are conditions for the use of the FSC and PEFC logos on products. This would make it much easier for manufacturers of Nordic Ecolabelled products to document the requirement, since they simply have to demand FSC and PEFC labelled products. 9 Criteria document Forestry (12)

10 FSC and PEFC are currently the two most dominant certification schemes for sustainable forestry. Although there are some differences between the two schemes, both are considered by Nordic Ecolabelling to be at the leading edge of forestry regulation, and are thus steering towards more sustainable forestry. If, in the future, credible new forestry standards appear in addition to the current FSC and PEFC standards, Nordic Ecolabelling will assess whether these may be used. Since Nordic Ecolabelling refers to FSC and PEFC, the certification bodies that issue forestry and traceability certificates must be accredited/recognised by these certification schemes. Applicants must document that at least 70% of all wood raw material (virgin/recovered fibre) used in the Nordic Ecolabelled product on an annual basis comes from certified forestry. The remaining proportion of wood must meet the requirements of FSC or PEFC concerning wood from controlled sources. Documentation may take the form of invoices and delivery notes. Nordic Ecolabelling will not generally require that the licensee or suppliers are Chain of Custody certified (CoC) to either FSC or PEFC. Requirements concerning traceability certification will depend on how widespread this is in the product group concerned. In this case, it must also be possible to document the traceability requirement for the proportion of certified wood raw material without requiring CoC certification. Requirements concerning CoC certification will, however, be relevant in product groups where this is very widespread (e.g. paper). CoC certification contributes to traceability in the supply chain under FSC and PEFC s guidelines and control systems for traceability. Suppliers that have a valid traceability certificate from FSC or PEFC can document fulfilment of the requirement (proportion of certified wood) using invoices or delivery notes. An important point regarding CoC certification is the verification of the proportion of certified wood in the form of an annual third-party audit. As the supply of certified wood raw material increases globally, in the future Nordic Ecolabelling will potentially be able to tighten the traceability requirement by requiring that a transfer (FSC) or physical separation method (PEFC) is used in certain product groups, i.e. full traceability of certified wood raw material for Nordic Ecolabelled products. Criteria document Forestry (12)

11 Appendix 1 Declaration for wood raw material This appendix shall be used to document the origin of the wood raw material used in a Nordic Ecolabelled product. Appendix to be completed by: Manufacturer of Nordic Ecolabelled product: Supplier of wood raw material: For documentation of wood raw material The applicant must state the name (Latin and a Nordic language), geographical origin (country/state and region/province) and CPI rating Table 1: Overview of origin and CPI rating Type of wood/raw material (type and name)* Geographical origin (country/state and region/province) CPI rating for the area from which the wood raw material originates *Describe whether it is, for example, pine, spruce, beech, etc. and the Latin name Is the wood raw material covered by the European Union Timber Regulation (EUTR) (No.995/2010)? Yes No If no Does the wood raw material meet the requirements in the European Union Timber Regulation (EUTR) (No.995/2010)? Yes No Is the wood raw material listed on CITES, appendix I, II or III? Information on CITES can be found at Yes No The manufacturer or supplier s signature: Date: Company name: Person responsible: Telephone: Criteria document Forestry

12 Appendix 2 Certified wood raw material To verify that all the wood raw material (100%) used, on an annual basis, in Nordic Ecolabelled products comes from certified forests or controlled sources: The table and calculations below must be filled in by the manufacturer Documentation is to be submitted to verify that certified wood raw material is used in the Nordic Ecolabelled product for example, invoices or delivery notes Description of the system for traceability of wood raw material Table 2: Purchased wood raw material on an annual basis for the Nordic Ecolabelled production/product. Applies to both certified and controlled wood raw material Type of wood/ Raw material (Type and name)* Supplier Quantity (m 3 per year) Proportion (%) of wood from certified forestry Proportion (%) of wood from controlled sources Total *Describe whether it is, for example, pine, spruce, beech, etc. and the Latin name Signature of the manufacturer: Date: Company name: Person responsible: Telephone: Criteria document Forestry