The Forest Stewardship Council (FSC) has temporarily banned certificate holders from selling Russian wood products that originate from sanitary logging in the Irkutsk region as “FSC-certified” or “FSC-controlled wood”.

This ban follows a recent investigation that alleges significant volumes of illegal wood could have entered global markets carrying the FSC-certified label.

Prohibiting the sale of sanitary harvest wood as FSC

Under the ban, holders of chain of custody certificates are prohibited from selling, or supplying, FSC-certified materials or FSC-controlled wood, in any form, that has been harvested as a result of sanitary felling (salvage logging) in the Irkutsk region.

The purpose of this ban, according to the FSC, is “[to eliminate the risk of timber from illegal (or unreasonably assigned) sanitary cuttings in the Irkutsk region into the FSC supply chain”.

The ban will be withdrawn or amended after “[the necessary changes are made to the regulatory documents or policies]”.

It is unclear how the FSC will enforce this.

This ban seems to be an apparent admission of the FSC’s uncertainty about what timber is entering which company.

See also: Can FSC certified wood be illegal?

The global reach of wood from Irkutsk

For many markets around the world, wood products are increasingly made from Russian timber.

See: Russian softwood lumber imports into U.S. increase 13x since June 2015

And the Irkutsk region reportedly accounts for 12-14% of Russia’s timber products.

Common wood species that occur in Irkutsk region include Spruce, Pine, and Larch. (Picea obovata, Pinus sylvestris, Larix sibirica respectively.)

Legal risks in timber supply chains originating in Irkutsk tend to be of a very large scale.

Here are some examples:

The risk of the FSC Russia ban

This ban (1) reinforces the need for buyers to practice timber due diligence regardless of FSC certification, and (2) demonstrates the risk from jurisdictional forest certification and policy decisions.

For example, if you’re buying an FSC Spruce or Pine product, how do you know it did not originate from sanitary logging in Irkutsk (and is thus not a tradable FSC product under the ban)? The only real way to know (with a relative degree of certainty) is by conducting your own timber due diligence.

The problem is, for many buyers, the cost of due diligence data collection, risk analysis, and mitigation exceeds profit margins. It could be more profitable to simply specify FSC Spruce that is not of Russian origin. So, the certification instrument that is designed to create a premium for certified companies (FSC), becomes a detriment to a regional wood products industry at large.

For governments that are working to have all forest concessions certified by the FSC, like Gabon, what happens if illegal wood enters FSC chain-of-custodies there? Does the FSC respond with a country ban on wood from certain harvesting methods? Or certain species?

FSC certification is not a guarantee of legality. Jurisdictional bans have the potential to undermine the sustainability premium that FSC supposedly provides, at scale. Buyers of wood products concerned about the legal origins of their purchases should apply the same level of timber due diligence to FSC wood, as non-certified wood.

See: Over 100,000 tons of fraudulent FSC plywood?

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