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A point of difference amongst organisations providing feedback to the EU is the role of private sector certification systems like FSC and PEFC in EUTR. Some private sector interests suggested there should be greater recognition for the risk mitigation role of certification in the regulation.

The European Panels Federation (EPF) said that EUTR should “recognise 3rd party verification and certification bodies (e.g. SFI, ATFS, FSC, PEFC or ISO 38200) as enough risk minimisation especially for complex supply chains such as panels and paper since operators do not always have access through the supply chain to all the necessary information on the origin of the processed wood in their purchased product.”

The Finnish Forest Industry Federation (FFIF)  didn’t go so far to ask for a green lane through EUTR for certified products but called for “greater coherence with forest certification initiatives” and that the “role of forest certification, as tools to verify the legal origin of raw-materials, should be better acknowledged when evaluating needs of possible revision of the EU legislative framework”

Similarly IKEA said that the EU should “create a common approach to third-party certification: agree upon and recognize internationally-accepted forest certification systems, like FSC, as one important part of the many parts necessary to build a solid due diligence system”.

However, this proposal for a greater role for certification was flatly rejected by some. For example, the NGO Earthsight said that: “Our organisation has researched and documented several instances where timber products at very high risk of being procured or traded illegally have entered EU states, and have made them publicly available via our Timberleaks platform or in-depth reports. We have also sent these directly to EUTR competent authorities.” “One of the common threads running through our investigations is that almost all the companies we have named in them as being connected to illegal deforestation, bribery or corruption, are certified, mainly buy certified wood, and source timber from certified forests”.

Earthsight went on to suggest that “Timber industry bodies have acknowledged that certification is no guarantee of legality and that companies must do more to ensure products they are importing are not illegally sourced. Although certification can lead to better forest governance and protection in some cases, reports have shown this impact is reduced in countries with high levels of corruption and poor levels of governance.

The FSC has acknowledged that voluntary standards were not designed to deal with corruption and that certification is no substitute for the role of the state”.

A call for a more measured role for certification in EUTR also came from the Polish State Forests National Forest Holding (PSFNFH), particularly significant because this organisation oversees about 7.5 million hectares of forest in Poland, of which nearly 7 million hectares are FSC certified.

PSFNFH noted that “having in mind that in accordance with EUTR ‘… certification or other third party verified schemes that include verification of compliance with applicable legislation may be used in the risk assessment procedure’, it must be emphasized that forest certification is mostly [a] marketing tool. It means that, operators placing timber or wood products on a market, should rely on their own risk assessment and mitigation of the risk identified. Operators fulfilling requirements of this Regulation must be fully responsible for their DDS”.

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