No Magic Bullet: What forest certification won't do

Martin von Mirbach

"The current interest in forest certification can be seen in the context of two influential factors. The first has to do with a growing public concern about forests and forest management around the world. The second factor is the series of shifts taking place in the role of governments as regulators."

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The current interest in forest certification can be seen in the context of two influential factors. The first has to do with a growing public concern about forests and forest management around the world. In the late 1980s, in response to this concern, products began to be marketed with some claim about sustainability attached to it, such as "From sustainably managed forests." These claims were made by producers, manufacturers and retailers. In 1991, WWF International conducted a study of 81 of these claims and discovered that only three could in any way be substantiated. It was evident that there was a need for some independent way to evaluate and validate environmental claims being made about forest products (FOE 1993).

The second factor is the series of shifts taking place in the role of governments as regulators. A variety of trends have emerged, including regulatory "efficiency," deregulation, downshifting regulatory responsibilities to regional and local governments, off-loading them to the private sector, and an increasing reliance on voluntary measures to supplant regulatory ones. Forest certification is, in part, a response to the perceived inability or unwillingness of governments to set and enforce adequate standards and, in part, a furtherance of the trend towards voluntary measures in place of regulatory ones.

Forest certification exists at the intersection of these diverse and, at times, conflicting factors. As a result, there is a bewildering variety of expectations among various interests with respect to forest certification. This article will outline those expectations, briefly discuss the strengths and weaknesses of the major certification systems in Canada, and outline some of the limitations of, and concerns about certification, in general.

Who wants what from certification?
To begin with, it will be helpful to list some of the major purported benefits of forest certification, from the diverse perspectives of various interests (Upton & Bass 1996).

Consumers are presumed to want assurance that the products they buy derive from well- managed forests, and/or assurance that the companies they do business with are not destroying the environment.

Investors might want to be able to identify the best companies in the forest sector and/or have an "ethical screen" that they can apply when making investing decisions.

Retailers want to project a progressive image; distinguish themselves in a competitive marketplace; capture the "green consumer" market; and/or lessen the risk of boycotts or other protests that might cast their business in a bad light.

Environmental organizations hope that certification will be more effective than governments in bringing about progressive change; improve forest practices on a wide scale; encourage broader application of "best practices;" validate models of forestry that are an alternative to the industrial paradigm; and/or aid in ameliorating some of the underlying causes of deforestation and forest degradation.

Producers expect certification to project a progressive corporate image to the public; improve company morale; help to attract and retain good employees; foster good relations with third parties; lower insurance and financing costs; provide liability protection for boards of directors; improve operations; replace rigid regulatory regimes; protect market access from possible boycotts; enhance market access to new "green" markets; and/or provide a "green premium."

In listing these purported benefits of certification, I am not suggesting that all interests in each sector hope to obtain all the benefits described. For instance, not all environmentalists want to overturn the industrial paradigm, and not all producers expect to receive a green premium. But some do, and for that reason it's important to assess how realistic these expectations are.

Strengths and weaknesses of the main Canadian forest certification systems
The Forest Stewardship Council (FSC)

More than any other certification system, the FSC is geared to the expectation that there is a market for green forest products. That is why the requirement to establish a verifiable chain of custody is a central aspect of FSC certification. Support for the FSC is high in the consumer countries, especially Europe (White 1996).

As well, the FSC is constituted in such a way as to incorporate a balance of social, environmental and economic interests, as well as a balance between northern and southern interests. This balance is achieved, not just through the formation of multi-stakeholder committees but also in the actual governance of the organization, in the makeup of its board of directors and in its voting procedures. While it is not a perfect system, it remains the case that no other certification system comes close to being as inclusive of southern interests as the FSC.

The FSC has the endorsement of major buyers' groups, which recognize that the FSC is the only currently credible independent certification and labelling system (WWF International 1996). The FSC is more likely than other certification system to meet the expectations of consumers and retailers.

The requirement to track chain of custody makes FSC certification technically difficult for large producers who purchase raw materials from a variety of different suppliers (Rainey 1997). This is particularly true for paper products, since a roll of paper is usually made with wood from a variety of sources. The FSC continues to grapple with the question of "percentage-based claims," striving to develop a policy that will be both credible and practical, a goal that has, so far, proved elusive.

FSC has a set of Principles and Criteria, but these are quite vague, since they are meant to be international in scope (FSC 1996). Several efforts are currently underway in Canada to develop regional standards that interpret the Principles and Criteria within a particular social, economic and environmental context. The Acadian Standards (applicable in the Maritime provinces) are the only Canadian standards that have been approved by FSC International.

It is proving to be extremely difficult for the FSC to develop site-specific performance standards that are credible, practical and internationally consistent. Efforts to do so are forcing FSC supporters to grapple with some of the conflicting expectations that are at the heart of the forest debate. How good is good enough? Is the role of the FSC to reward the very best companies, or to improve the sector as a whole? How is it possible to reconcile the conflicting requirements of international consistency and local flexibility? Finding answers to questions such as these is always a challenge for any group of diverse interests, and the FSC is no exception to this rule.

ISO 14001
The International Organization for Standardization (ISO) began developing a series of environmental standards (the ISO 14000 series) in the early 1990s. ISO 14001 outlines the requirements for an environmental management system (EMS), detailing the internal processes and procedures that need to be in place in order to effectively set environmental objectives, develop a process of implementing those objectives, monitor the results and use this information to improve and fine-tune the EMS. It is a generic standard, meaning that it is applicable to any number of possible endeavours. The standard could be used by a forestry company, an automobile parts factory, a hospital, a government department or a sporting event, to name just five diverse examples. The standard does not set minimum performance requirements other than conformity with the law. There is no requirement for public participation in developing the EMS, nor any requirement for public disclosure of any information pertaining to the system.

The ISO 14001 standard is perhaps most useful in helping transnational corporations ensure that there is some consistency in the activities of far-flung operations around the world with which they are involved. This is of particular interest to boards of directors, concerned about possible liability and the need to demonstrate due diligence in avoiding environmental catastrophes. It is not a particularly effective way to address public concerns about forestry operations, especially in Canada where the majority of forestry operations are carried out on publicly owned land. Several companies in Canada have indicated that they are working toward ISO 14001 certification, although it is not clear whether they are doing this in order to help them in the marketplace or simply to improve their internal management processes.

The Canadian Standards Association (CSA)
The CSA standard attempts to describe what sustainable forest management might mean in a Canadian context. It accomplishes this primarily by integrating into its standard the Criteria for sustainable forest management that were developed under the auspices of the Canadian Council of Forest Ministers (CSA 1996a). The CCFM C&I provide a distinctly Canadian "flavour" to its definition of SFM, most evident in the sixth criterion's requirements for public participation and provision for Aboriginal interests (CCFM 1996).

The CSA's approach to setting performance standards is quite different from other forest certification schemes. There is actually no CSA performance standard as such; instead, the CSA requires applicants to set their own performance standard, using the CCFM Criteria as a framework. Although the CSA standard has rigorous requirements with respect to public consultation in developing those standards, the forest manager is only obliged to solicit, consider and respond to public input, but not to actually incorporate that input in its performance objectives (CSA 1996b).

The CSA SFM standard was developed in such a way as to be compatible with the requirements of ISO 14001 (ISO 1996). Some interests within Canada sought to have the CSA standard formally recognized by the ISO, but these efforts were rebuffed by the ISO (Hauselmann 1996). Instead, the ISO approved a technical report that simply describes how various forestry standards might complement and support the ISO standard. Nevertheless, it remains the case that it will be comparatively easy to certify to ISO14000 once CSA-SFM certification has been obtained.

The CSA standard is a registration system, not an ecolabelling system; and it does not require the tracking of chain of custody. This means that it cannot actually offer any assurances to consumers or retailers about the provenance of products produced by CSA-registered companies. The products themselves may or may not derive from forests that have been managed according to the CSA standard. At best, the CSA can claim that a particular object was produced using wood from a company that has in place an SFM management system (Elliott & Hackman 1996). This relatively weak claim may not address concerns of retailers and consumers, and certainly doesn't address the concerns of many environmentalists.

General limitations of certification
What sometimes gets lost in the discussion of specific certification systems is a critical awareness of what forest problems are beyond the scope of any certification system. We need to be continually reminded of these.

1. The potential global impact of forest certification is extremely limited. There are several factors that limit the impact of certification. More than half of all wood cut worldwide is used for energy; certification won't have any impact on it. Much timber is traded locally, where certification's potential impact is severely reduced. The consumer interest in certification is primarily limited to western Europe and certain sectors of the market in North America and Japan. There is little or no market for certified product in developing countries, emerging markets or Eastern Europe.

2. Certification does not provide an effective mechanism for internalizing social and environmental costs. Some people argue that much of the world's deforestation and forest degradation comes about because we lack adequate mechanisms to internalize the social and environmental costs of exploitative logging and other activities which destroy forests. If such mechanisms were in place, then good forest management would become more profitable than the alternative. Unfortunately, certification is not a particularly helpful tool in this regard.

3. Certification will not change bad land-use decisions, and will not correct policy failures or other underlying causes of deforestation and forest degradation. Some examples include poor rent capture; inadequate or unjust land tenure; deforestation as a result of development pressures and other forms of greed; deforestation as a result of agricultural conversion arising from pressures due to poverty and overpopulation; pressures due to macroeconomic policies and structural adjustment programs, etc (IPF 1996). Certification is more or less powerless to influence these factors.

4. Certification does not deal with unsustainable consumption patterns. On the contrary, certification relies on "green consumerism" to maximize its impact. This means that promoting certification actually works against programs that might seek to reduce the use of forest products in those countries where per capita consumption is highest.

5. Certification tends to discriminate against small producers. Because there are some fixed costs to certification, especially in the planning stages, these costs will impose a comparatively heavy burden on small producers. Both the FSC and the CSA have acknowledged this problem and are attempting to deal with it, but it is not yet certain that they can do so without undermining the credibility of the system.

General concerns
In addition to the limitations outlined above, there are a number of critical questions which should be asked about certification in general. These questions don't have simple answers but rather point to additional limitations or other reasons to be sceptical about the purported benefits of certification.

How strong is the demand for certified forest products? Is there a "green premium"? Although surveys exist to show that consumers are interested in obtaining certified forest products and even that they are willing to pay a premium, it is nevertheless the case that what consumers say they'll do is not necessarily the same as what they actually do (Upton & Bass 1996). There is not enough certified products in the stores to be able to assess whether or not consumers seek out retailers who advertise that they carry certified products, or choose to specify the use of certified products in building contracts, or whether they'll pay a premium for certified product, or how much of a premium they'll pay, and under what circumstances.

The example of certified organic agriculture, which has been around a lot longer, is not necessarily a reliable comparison point. On the one hand, public interest in and concern about forests tends to be higher than concern about agriculture. On the other hand, organic produce has a compelling selling point since it involves food that we ingest into our bodies. A decision to buy organic produce may be mostly driven by health concerns and have little to do with larger environmental issues. This direct self-interest hardly comes into play with certified paper and timber products.

What will the impact of forest certification be in developing countries? I have already outlined a significant limitation to certification in that most wood cut in developing countries never enters the international market. But what about those developing countries which do have a significant export-driven forest industry, especially countries with extensive tropical forests? Pessimistic scenarios suggest that developing countries will have a harder time competing in an international marketplace that seeks certified forest products since, in many cases, they lack the basic infrastructure needed to carry out the kind of management planning that every credible certification system requires. This means that, far from helping poor countries to improve their forest management, it may have the opposite effect. If these countries lose export revenue due to their inability to meet certification requirements, the likelihood increases that the forests will simply be stripped bare through exploitative logging and/or conversion to other uses.

Is certification in violation of World Trade Organization rules regarding non-tariff trade barriers? There is much uncertainty about how forest certification might relate to, and possibly infringe upon, international trading rules (Cook et al 1997, Michaelowa 1996, Vaughan 1996). The General Agreement on Tariffs and Trade (GATT), which is administered by the WTO, places strict limitations on the use of trade measures that distinguish between "like products" based on how those products were produced, which is exactly what forest certification does.

Strictly speaking, any purely voluntary certification scheme should fall outside the purview of the WTO, whose membership is restricted to countries. However, some countries, including Canada, argue that governments have an obligation to endeavour to ensure that certification schemes applied in their jurisdiction are consistent with WTO rules (Government of Canada 1996). As well, certification schemes may no longer be purely voluntary if they are referenced in legislation or regulation, or if they become so widespread as to be considered normative.

Many views have been expressed about how forest certification might or might not run afoul of the WTO but, in the absence of a specific panel ruling, it is not always easy to distinguish between informed opinion, wishful thinking and special pleading. In general, however, it can be said that the more successful any certification scheme is at providing market access to producers, the more likely it is to be challenged as a non-tariff trade barrier.

Conclusions
At this point, a wide variety of interests have demonstrated an interest in forest certification as a tool to meet their different objectives. It will be important, first of all, for everyone to realistically assess what forest certification is likely to accomplish, and what it cannot. Then, it will be necessary to decide which practical interests are foremost and to work within the appropriate certification framework to meet those primary objectives.

Producers who wish to use forest certification to gain market access will likely have to work within an ecolabelling system which can result in a product label that has high credibility and widespread support. On the other hand, producers who are interested only in improving their corporate image and/or environmental management system, may be better off certifying to ISO 14000, bypassing entirely the more onerous requirements of forest-sector standards. Above all, it is worth noting that any certification system can potentially help to improve company operations, but only if it is backed by a genuine commitment at all levels that translates into significant on-the-ground changes. (Ironically, if the commitment is there, then certification may very well prove to be redundant.) In the end, however, no certification system can perform the magic trick of addressing public concerns about forestry without addressing the concerns of the environmental organizations which have stimulated those concerns in the first place.

Environmentalists will have to revise some of their overly high expectations of what certification can be expected to accomplish and, in certain cases, redirect their efforts towards initiatives that are more likely to produce results. No certification system can, at one and the same time, use global trading patterns to bring about changes in the forest industry as well as promote alternative models to the industrial paradigm.

It is not yet clear whether there is the ability and the will to find sufficient common ground among producer, consumer and conservation interests to make certification a useful and credible tool. Moreover, forest certification is still in its infancy and is far from robust. It is entirely possible that competition and public disputes among proponents of specific systems will confuse and alienate the consumers that are supposedly the main driving force behind certification, thus rendering certification ineffective as a market-driven tool.

On the other hand, no certification system is likely to prevail over all others in the international arena. There would be too many "losers" in such an event, who can be expected to ensure that no single certification system would remain triumphant for long.

An alternate scenario, and perhaps a more constructive one, would be to explore ways in which different certification systems might thrive independent from each other, each one used according to its particular strengths and freed from hyperbole and inflated claims. This will require considerable discipline to prevent misleading or exaggerated claims from proliferating. In all likelihood, however, it is the best way to ensure that certification remains a viable tool.

Above all, the focus should be on good forest management, good decisions and good practices. It does not take new concepts, new initiatives or new buzzwords to make this happen. Certification can be a tool to help but it is not the only one or necessarily the best one. What is ultimately required is a combination of knowledge, experience, resources and political will to create the conditions which allow for good forest management, which facilitate it, encourage it and make it seem like a natural process.

Martin von Mirbach is the Sustainable Development Chair at the Centre for Forest and Environmental Studies in Corner Brook, Newfoundland. E-mail will reach him at martin.vonmirbach@northatlantic.nf.ca This article is adapted from a presentation given at a conference of the Canadian Institute of Forestry in September 1997.

© 2000 Ecoforestry Institute
Originally published in Ecoforestry 15(1):6-13

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