Results of an investigation into Swedish old growth forests

The Forest Stewardship Council (FSC) commissioned its assurance partner Assurance Services International (ASI) to conduct an investigation to better understand concerns raised by stakeholders about the encroachment of industrial forestry into Sweden’s old growth forests with high conservation values. The affected areas include FSC-certified forests and areas where FSC controlled wood is sourced.  

Over the past few years, environmental stakeholders have been voicing their concerns through FSC and ASI’s respective complaints and incident handling systems about logging in areas designated as woodland key habitats in Sweden. Acknowledging the complaints received by certification bodies, ASI and FSC agreed to launch an investigation in April 2023.  

About woodland key habitats in Sweden 

Woodland key habitats (WKH) are specifically designated areas in the Swedish forest landscape which are rich in biodiversity. The National Forest Stewardship Standard (NFSS) in Sweden explicitly provides protection to WKH that are a part of FSC-certified forests because they are considered to be a proxy for high conservation value areas. According to FSC’s Centralized National Risk Assessment (CNRA) for Sweden, controlled wood certificate holders are required to conduct conservation value assessments as part of the site planning to ensure that wood from WKH does not enter the FSC system.  

The investigation’s findings  

The provisions in FSC Sweden’s normative framework – the NFSS and CNRA – about the protection of WKH are not rigorous enough to ensure that wood from these areas is not harvested.  

• For forest management certificate holders, the NFSS requirements for ensuring robust assessments and conservation of WKH are ambiguous and open to different interpretations regarding the preharvest natural value assessment methodology to be applied. Thus, certificate holders have room to apply less stringent methodologies for the identification of WKH. 
• The CNRA does not provide any guidance on how the preharvest natural value assessments should be conducted. According to environmental stakeholders, the preharvest nature value assessments conducted by controlled wood certificate holders are not rigorous enough. 

The findings of this investigation also show that the complaints are partially driven by external factors:  

• The loss of competence of the State Forest Agency to provide guidance on how to identify and set aside WKH areas in private forest lands. 
• The reduction of public funding to compensate forest landowners for setting aside WKH for conservation.  
• The Swedish law does not fully protect the habitats of red listed species; thus, environmental stakeholders are turning to the EU Habitats Directive as a subsidiary argument to protect WKH. 

ASI’s recommendations for improving the FSC system  

There is a need to strengthen the NFSS so that forest management practices can be audited more rigorously. It is recommended that during the next revision of Sweden’s NFSS, the requirements for identifying and protecting WKH and areas rich in red listed species are strengthened.  

To ensure that controlled wood certificate holders avoid purchasing timber originating from WKH, the CNRA for Sweden should be amended to include preharvest conservation value assessment as a mandatory control measure for sourcing controlled wood. FSC should develop a system to facilitate early-stage identification of WKH. 

Due to the active engagement of various environmental sector stakeholders in the FSC Sweden system, the resolution of disputes and grievances would benefit from more engagement opportunities around issues like delineation practices for WKH. 

This investigation also revealed a need for centralizing the complaints redressal mechanism in the wider FSC system. Development of a centralized repository of complaints received across the system would enable various stakeholders involved in FSC’s certification system to coordinate the redressal of grievances and complaints in a more efficient manner.  

Next steps 

FSC International and FSC Sweden are assessing the implications of the findings and recommendations of this investigation. The FSC Sweden Standards Committee will consider recommendations regarding Controlled Wood Risk Assessment. The recommendations regarding the National Forest Stewardship Standard for Sweden will be considered during the revision process scheduled to start in 2024.  

Finally, a task force will be constituted to provide suggestions on ways to improve the national implementation of the FSC complaints system. They will use the results of the report as background information. This task force is mandated by the approval of a motion at the FSC Sweden Annual Meeting in May 2023. 

FSC believes that the protection of the certification system’s integrity requires a holistic approach – from a geographical perspective as well as the tools used to conduct investigations into possible risks. This investigation is one such example. In this case, FSC decided to work with ASI to develop a unique investigative methodology that would be able to unravel the complexities of the problems raised by stakeholders in Sweden and provide recommendations for improvements in the certification system. 

Update: A public summary of the report on the investigation is available here.