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FSC is aware of the reports’ findings and was approached by Channel 4 for comment. While FSC addressed the statements fully in its correspondence with Channel 4, our full response was not used, and therefore could be open to misinterpretation. We take this opportunity to clarify our response on some of the issues raised.
In April 2021, the EU Commission asked FSC to share an opinion on the draft implementing act on the guidance for implementing the REDII criteria for forest biomass. One of the comments FSC provided was in response to Article 3 of this act which focuses on the assessment of compliance with the harvesting criteria at the national or sub-national level. One of the sub-criterions listed in this article stated the following:
- the national or sub-national laws applicable to the area of harvest ensure forest regeneration, by demonstrating that the applicable laws require natural or artificial regeneration, or a combination of both, aiming at the establishment of a new forest in the same area and within at least five years after the harvesting operation, and that there is no biodiversity degradation in the regenerated forest area, including that primary forests and natural or semi-natural forests are not degraded to or replaced with plantation forests.
FSC made a comment to remove the bold text above suggesting that the implemented legislation consulted was not the correct vehicle for this criterion, not because it disagrees with it. This was clear in our correspondence with the European Commission by email as can be seen in the screen shot below:
- In black: FSC’s original suggestion
- In red: EU Commission’s response to the suggestion
- In green: FSC’s clarification
As part of FSC’s requirements, high conservation values (HCV) must be identified, mapped and protected by forest managers. This includes Woodland Key Habitats (WKH) which are managed under FSC’s HCV requirements.
At the time of harvest, FSC believes that these areas were not identified as areas with WKH. It is possible that the harvesting had taken place before the WKH were registered into this database. However, FSC cannot confirm whether this has happened or not, or the scale of the problem.
It is important to note that as a voluntary tool, FSC certification alone cannot solve all the problems associated with poor forest management and illegal timber trade. FSC certification is an additional control instrument for safeguarding sustainability in timber supply chains. The fight against illegal activities that harm the world’s forests requires a joint effort by all societal actors – state institutions, NGOs, social groups, local communities and companies.