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Using the FSC system to assess illegal logging risk for non-certified products

I am as guilty as any in posting articles on LinkedIn about illegal logging of wood. This may give the impression illegal logging is rampant around the world.

The reality is that in many parts of the globe wood is legally harvested day in and day out. The harvester has legal authority, they comply with a harvesting plan, royalties have been paid, indigenous peoples rights are not adversely affected and so on. The challenge as an importer into Australia is how, when undertaking due diligence, you have evidence for and can reasonably justify a low-risk rating if a compliance authority comes calling.

In Australia, if the product is FSC® or PEFC certified it is a relatively simple matter to meet the Australian Illegal Logging Prohibition Regulation's requirements and justify a low-risk conclusion.

However, what if your supplier can't supply FSC or PEFC certified product or your market won't pay the higher cost of a certified product?

If your product has been made with wood harvested from a lot of different countries - common with furniture or paper products - due diligence can take a lot of time and money.

The good news is that FSC has a series of risk assessments that are free, readily understandable and available to anyone to use internally.

FSC's Controlled Wood System is complicated and there are specific rules about making claims to clients or the general public however I use it all the time for my clients. For clients importing wood or paper products made from wood harvested in first world countries (e.g., USA, France, Germany, New Zealand, etc) I often utilise the FSC Controlled Wood system resources as a reference to justify a low-risk rating at the country of harvest level.

FSC has commissioned specialists in the forestry field to assess the risk of illegal logging at a country level (Illegal logging is one of five categories that they assess risk for - I'm just discussing Category 1 - Illegally Harvested Wood). These risk assessments undergo a public consultation period. The final risk assessments are incorporated into publically available controlled wood national risk assessments (NRAs) or centralized national risk assessments (CNRAs).

NRA and CNRAs for Category 1 for 52 countries have been produced to date. For risk of illegally logged wood at the country level, they conclude that for 26 countries there is a low risk that the wood harvested in those countries has been illegally logged. This includes wood harvested in Australia, Austria, Canada, France, Germany, New Zealand, Sweden, South Africa and the USA.

All the CNRAs and NRAs for countries are freely available at the FSC International Document Center here. Search for the country you are interested in.

Of course, under Australia's Illegal Logging Prohibition Regulation importers still have to assess the supply chain risk and any other information they should be aware of but these NRAs and CNRAs can really make life easier for many importers.

Contact Stephen Mitchell Associates to assist you in undertaking a risk assessment, setting up a due diligence system or responding to a request for information from the Department of Agriculture. Call +61 2 8006 8850 or email

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