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Report from
Europe
Dutch and Belgian importers＊ views on FLEGT
Although the EU Timber Regulation (EUTR) has
narrowed the supply base for tropical timber imported into
the EU, traders in Belgium and the Netherlands strongly
support the FLEGT regulatory approach 每 combining
licensing with EUTR 每 as a platform to help rebuild
confidence in tropical timber in the EU market.
FLEGT licensing is helping importers to comply with
EUTR, while the forest sector reforms and new procedures
implemented during the FLEGT VPA process form part of
a positive narrative that now needs to be communicated
more widely to buyers and procurement officials in the
EU.
These were key messages of the latest European trade
consultation, which targeted Belgian and Dutch traders,
hosted by the FLEGT Independent Market Monitor
(IMM), an ITTO project funded by the EU (more details
of IMM and the trade consultation are available at
(www.flegtimm.eu).
The event held in the Belgian port of Antwerp formed part
of a series of consultations to inform IMM work to assess
market drivers and market impacts and perceptions of
FLEGT. Similar consultations were held last year in
France, Germany and the UK, and others are planned in
Spain and Italy later in 2019.
An audience of 50 attended the event co-organised with
Belgian and Dutch trade federations Fedustria and the
VVNH. Delegates included timber importers and
distributors, end-users, retailers and representatives from
trade associations, EU Timber Regulation and FLEGT
competent authorities (CAs) and government agencies.
Participants mainly came from Belgium and the
Netherlands and operated in a wide variety of product
areas including plywood, hardwood for interior fittings,
such as mouldings, interior furniture and other
manufactured goods, laminated components and exterior
products, including decking, cladding, fencing and garden
furniture.
Participating companies sourced from suppliers
worldwide. Among those listed were Bolivia, Brazil,
Cameroon, China, Congo, Gabon, Indonesia, Malaysia,
Peru, Russia, Thailand, and Vietnam. Their customers
included the construction sector, merchants and
distributors, flooring, furniture, packaging and other
manufacturers, and, in the case of retailer delegates,
consumers.
Apart from the number and range of participants, the
insights from the Antwerp consultation were made more
relevant by recent tropical timber trade flow trends in the
EU. The consultation was an opportunity to explore the
views of traders playing an increasingly prominent role as
gatekeepers for the wider European trade in tropical
timbers.
Imports of tropical wood products into Belgium and the
Netherlands have held up more strongly than most other
EU countries following the economic crises in 2008 and
2009. In 2018, 38% of total EU imports of tropical timber
primary products (logs, sawn, veneer, mouldings and
plywood) were landed in Belgium and the Netherlands
compared to 23% in 2004.
The agenda featured presentations on global trends in the
tropical timber trade, and notably European trade with
VPA countries, private and public sector timber
procurement policy and the Dutch CA＊s experience with
FLEGT-licensed timber. Individual trade bodies and
operators gave their perspectives on tropical timber trade
developments, the FLEGT initiative and links to forest
management certification.
Opening the consultation, IMM Lead Consultant Sarah
Storck reported the results of the IMM 2018 trade survey
which showed the EU timber sector has become quickly
accustomed to the FLEGT licensing system. ※In 2017 a
significant minority of respondents had said it was more
complex than undertaking due diligence under the EUTR.
But in the 2018 survey only 1% of respondents still felt
that, whereas the vast majority said it made importing
easier§.
Commenting on the direct impacts of FLEGT-licensing
and the EUTR on EU tropical timber imports, Ms. Storck
said that the market introduction of FLEGT-licensed
timber was felt to have had a small positive impact by EU
trade respondents to the 2018 IMM survey.
At the same time, around 35% maintained that the EUTR
had negatively impacted tropical timber imports
(compared to 63% indicating no impact and 2% indicating
a slight increase).
Nonetheless, according to Ms. Storck, trade
representatives interviewed by IMM for the 2018 survey
emphasised that they were supportive of the EUTR and
saw it as an opportunity for the tropical timber trade in the
medium and long-term 每 as long as it was effectively
implemented.
Rising Dutch imports of FLEGT licensed timber
These results were consistent with comments made at the
consultation by Meriam Wortel, representing the NVWA,
the Dutch CA for EUTR and FLEGT. A role of NVWA is
to monitor volume trends in Indonesian forest product
imports into the Netherlands since the start of FLEGT
licensing.
Ms. Wortel said that ※while, pulp and paper trade is more
prone to fluctuation, the overall direction [of Indonesian
timber imports into the Netherlands] has been upwards,
with latest figures for timber and wood furniture showing
further rises. However, while we can say licensing has
had no negative effects, it is not yet clear to what degree or
if FLEGT licensing is a factor in this positive trade trend.§
According to Ms. Wortel, the NVWA is processing more
FLEGT licences than any other CA, a total last year of
8546. The Dutch CA is also one of the driving forces
behind developing a fully electronic FLEGT-licensing
system in cooperation with Indonesia and the EC.
Initial administrative teething problems dealing with
licences had been overcome as the trade grew accustomed
to the process, said Ms Wortel. However, an ongoing issue
was mismatches between HS codes on licences and those
applied in the Netherlands.
※We＊ve raised this with the Indonesian authorities and
liaised with other CAs, but, while the incidence of
mismatches decreased last year, it has recently risen
again,§ said Ms. Wortel. ※So, there＊s continuing need to
stress to exporters they must get license details right.§
During the subsequent discussion, participants highlighted
that perceived ※mismatches§ were sometimes not due to
mistakes on the FLEGT-licenses or importers＊
documentation but to limited product knowledge and
mistranslations on the part of customs＊ officials.
※Laminated§ joinery products, for example, would
sometimes be expected by customs officials to be ※filmfaced§.
One or two participants complained that sorting
out such issues and getting customs authorities to accept
that the mistake was in fact their own would sometimes
involve lengthy negotiations.
Ms Wortel added that the NVWA anticipated fewer
mismatch issues with imports from Ghana when it starts
licensing due to its less complex product mix and the
different system of applying for and issuing FLEGTlicenses.
She also said that the goal was that the process of
FLEGT-licensing in Ghana should be fully electronic right
from the start.
Potential of FLEGT licensing as platform to rebuild
market share
Much discussion at the Antwerp consultation was directed
towards exploring whether the long-term declining trend
in EU tropical timber consumption can be changed and the
potential for FLEGT licensing as a platform to rebuild
market share.
A presentation by IMM Trade Analyst, Rupert Oliver, set
the stage by highlighting that the share of tropical timber
in total EU imports was only 19.7% in 2018, down from
20.3% in 2017 and the third consecutive year of decline
(after a brief rebound in 2015). Longer term, the share of
tropical countries in EU imports has fallen from well over
30% before the financial crises in 2007-2008.
Participants were invited to identify and rate the factors
that may be restricting their sales of timber from VPA
partner countries. ※Environmental prejudices and
uncoordinated marketing§ was rated the most significant
constraint by this audience, followed by ※product
substitution§. The factors of ※competition from China§
and ※diversion of wood supply to other markets§ were
viewed as the next most significant, in line with previous
IMM research.
In contrast to previous IMM research, participants in
Antwerp rated the ※economic downturn and slow
economic recovery§ as a less significant factor limiting
EU imports from VPA partner countries. This may simply
be a sign that as time passes, memories of the economic
downturn are gradually receding and there is growing
acceptance that slow economic growth is the ※new
normal§.
And in the Netherlands, where economic growth has been
reasonably robust in the last 2 years, it＊s unlikely now to
be viewed as such a significant market factor.
In addition to these various factors, participants suggested
that the EU Timber Regulation (EUTR) has shaken up EU
importers＊ supplier selection process. There was a
widespread view amongst Belgian and Dutch traders at the
consultation that they now put their supply chains through
greater scrutiny than ever. Illegality risk assessment and
the capacity of suppliers to provide adequate information
to satisfy the due diligence requirement of the EUTR, was
a priority.
※If a supplier can＊t meet our due diligence needs or supply
the further proof of legality for risk mitigation, then we
don＊t pursue the relationship further,§ said one plywood
operator. As a result, said some traders, their tropical
supply pool and consequently the variety of tropical
products available to them, had narrowed.
While EUTR may be placing constraints on supply of
tropical timber to EU importers, there was strong support
for the regulatory approach adopted by the EU, combining
FLEGT licensing with EUTR, when participants were
asked, in another exercise, to rank overall strategies that
might be adopted to improve the position of tropical wood
products in the European market.
Of various strategies identified during the consultation, the
FLEGT regulatory approach was by far the most popular
amongst Antwerp participants. No single participant
reckoned that the opposite strategy, of repealing the
FLEGT licensing measures and EUTR (and thereby in
theory reducing the regulatory burden of importing timber
products) would help to improve tropical timber＊s position
in this market.
Can the EU market for tropical timber be turned
around?
In addition to rating market constraints and opportunities
for timber products from VPA partner countries,
participants at the Antwerp consultation were asked to
provide feedback on three questions: (1) can the market
for VPA partner timber products in Belgium/Netherlands
and wider EU be turned around; (2) if so, how; and (3)
what role do you think the FLEGT process can play in
turning the market around?
On the first question, quite a few participants felt there
was little or no prospect of the market turning around,
suggesting that share has now been irretrievably lost to
other materials and demand for tropical wood has shifted
elsewhere in the world. However, others responded with a
cautious ※yes, in some specific market sectors§.
On the second question, of ※how to turn the market
around§, it was noted that trying to encourage more
demand just by focusing on traditional product groups for
tropical timber products and business-to-business
communication channels, and trade servicing activities,
was unlikely to lead to any significant increase.
On the other hand, there was some optimism that new
opportunities could arise through the introduction of better
organised and targeted marketing campaigns, involving
considered analysis to match specific VPA partner
products to niche markets, and backed by widespread
certification and/or licensing, and concerted efforts to
explain the FLEGT narrative to customers.
Views were divided on the third question, just how
important is FLEGT licensing likely to be as part of the
process? Some participants seemed sceptical that licensing
had an important role to play, others were more
enthusiastic.
To some extent this split reflected the experience to date
of marketing Indonesian FLEGT products. Feedback from
the Antwerp consultation suggests that FLEGT licensing is
helping those importers that have traditionally purchased
Indonesian products as it greatly simplifies EUTR
conformance for these products.
However, licensing has yet to encourage any broader
interest in Indonesian products in the European market.
There was a widespread view in the room that companies
so far have not been switching to Indonesian products due
to the availability of FLEGT licenses. As things stand,
participants also suggested that price premiums could not
be charged for FLEGT-licensed products in the EU
market.
Longer term, FLEGT licensing was expected by some
participants to play a larger role in expanding the EU
market for timber products from VPA countries if the
range of countries and products covered by licensing
increased.
The forest sector reforms and new procedures
implemented during the FLEGT VPA process were seen
as part of a positive narrative that could help at least to
maintain, if not necessarily grow, market share in the EU.
However, for this to happen, participants stressed there
needs to be more concerted efforts to improve awareness
and recognition of the role of the FLEGT process down
the supply chain, amongst retailers, manufacturers, and
other buyers.
A clear, consistent and widely agreed message on
FLEGT＊s sustainability credentials in terms of wider
environmental, economic and social impacts, would also
help, as would greater recognition of FLEGT licences in
government timber procurement policy in all 28 EU
member states.
Participants flagged up a lack of awareness of the wider
benefits of FLEGT VPAs among decision makers shaping
EU public procurement policies and decision makers
specifying timber for public projects, especially at local
level. It was noted that government recognition and
procurement of FLEGT-licensed timber would help drive
private sector consumption.
The topic of creating a logo for FLEGT was also raised
once more, with some participants suggesting it needed to
become a trademark. Participants also highlighted that
lack of a chain-of-custody system for FLEGT licensed
timber once it enters the EU supply chain is a barrier to
FLEGT-licensed timber being accepted in EU public
procurement.
Participants in Antwerp strongly favoured combining the
FLEGT regulatory approach with further efforts to expand
supply of third-party certified tropical timber. Perhaps
unsurprising in this part of the EU where there has been
particularly strong support for timber procurement policies
favouring FSC and PEFC certified timber.
Participants emphasised that FSC and PEFC certification
is still a greater purchasing preference amongst importers
in the Netherlands and Belgium and their customers than a
FLEGT licence.
Far reaching CSR commitments necessary to build EU
market for tropical timber
Participants also strongly endorsed a view that NGOs need
to be actively engaged in efforts to improve the market
position of tropical timber in the EU.
Specifically, participants noted that the three NGOs which,
probably, have been most influential on forestry issues in
the EU (WWF, FoE and Greenpeace) need to be
convinced of the ※use it or lose it§ message and to be more
visible in their support for the FLEGT process.
Taken together, the demand for a regulatory approach in
combination with wide-ranging commitment to private
sector certification, and direct liaison with NGOs, mirrors
the high ranking accorded to ※environmental prejudices§
as a key driver of tropical wood＊s decline in this part of
the EU.
There was a strong feeling in this audience that the poor
environmental reputation of tropical timber products,
irrespective of just how well deserved, must be rectified
by far-reaching corporate commitments to good practice,
backed by regulation, as an essential pre-requisite to
maintain or rebuild market share.
Another clear message from the Antwerp consultation was
that while FLEGT licenses and other environmental
assurance mechanisms provide essential platforms to help
build market share, there are broader competitiveness
issues that also need to be addressed. Suppliers of FLEGT
licensed products must still compete on price, availability,
quality and consistent delivery.
A plywood importer illustrated this point by noting that
※cheaper Russian plywood, which due to greater
investment in technology has also become a better quality,
more consistent product, has been taking Indonesian
market share§.
Improved tropical wood marketing in Europe, with
strong focus on certification
Europe＊s timber and wood products sector has stepped up
the level of its marketing and advertising activity and the
clarity, cohesion and effectiveness of its communications
in recent years. This includes marketing initiatives related
to tropical timber which currently focus more on third
party forest management certification programs than on
FLEGT-related activities.
The focus on certification is partly due to the more limited
range of FLEGT licensed products currently available on
the EU market and partly to continuing lack of clarity in
EU procurement policies and practices on the status of
FLEGT licensing relative to systems like FSC and PEFC.
These are key conclusions of a new study on EU wood
promotion programs issued by the Independent Market
Monitor (IMM), the project hosted by ITTO with EU
funding, to assess the market impact of FLEGT Licensing.
The study draws on a series of interviews and a literature
survey conducted in the spring of 2019. In total twentyfive
interviews were conducted across a range of EU
member states and from a variety of perspectives 每
including wood promotional campaigns, timber trade
federations, civil society organisations, companies and
other industry commentators.
The IMM study shows that Europe＊s timber and wood
products sector has developed a wide range of national and
international marketing programs and campaigns. The
sector has focused particularly on promotion and
communications of timber＊s environmental performance,
in recognition that its key markets, notably construction,
but also government decision makers are increasingly
environmentally aware and informed and addressing
climate change issues ever more urgently.
Campaigns incorporate latest findings on wood＊s carbon
and climate mitigation benefits, its life cycle analysis
performance in relation to competing man-made materials
and its potential role in developing a circular, bioeconomy.
There is also a stress on timber＊s renewability and
sustainability and the role sustainable forest management
can play in maintaining the forest resource, with the
carbon and biodiversity gains that entails. The stress here
is very much on third-party forest and chain of custody
certification as assurance that timber is from a sustainably
managed forest.
Europe＊s timber trade federations are involved both in
these wider promotion campaigns and also conduct their
own campaigns to highlight the industry＊s efforts to assure
legality of timber placed on the European market and
combat illegal logging, with the main focus in this area on
the EU Timber Regulation and associated due diligence.
On promotion of FLEGT and FLEGT licensing, there is a
central communications hub in the EFI FLEGT Facility,
which continues to develop its content, strategy and
outreach. The UK Timber Trade Federation ran an
exhibition exclusively focused on FLEGT, a UK initiative
supporting development of Indonesian FLEGT marketing
strategies is underway and other trade federations do
communicate the facts on FLEGT.
But otherwise the profile of FLEGT licenses in industry
promotion and marketing is low relative to third party
forest certification. Europe＊s two main tropical timber
promotion campaigns 每 the Sustainable Tropical Timber
Coalition (STTC) and the ATIBT ※Fair and Precious§
branding exercise - commend only forest certification as a
procurement criterion, although FLEGT licenses are seen
to have potential to make the market more tropical timberfriendly
generally and do not rule out more
communication on FLEGT in the future.
The emphasis of European NGOs in their forestry and
timber sector campaigning is also on sustainable forest
management linked to third party certification. There is,
however, communication of FLEGT and some active
NGO advocacy for the FLEGT VPA process in the sector.
Some in the European timber industry believe there is
potential for raising FLEGT＊s profile in communications
and promotion further, given a more holistic approach.
That includes greater emphasis on its wider social,
environmental and economic impacts, but also a still
greater trade focus, with more information on the actual
products available with licences.
Another influence on the direction of wood promotion
generally must be that rival materials sectors＊ increasing
communication of their environmental credentials, as the
IMM report shows, is focused very much on issues of
sustainability, carbon and climate.
The report recommends provision of targeted information
on FLEGT to the managers of existing timber promotion
campaigns, linked to a strong focus on continuing efforts
to increase availability of FLEGT licenced products in the
EU market, and further research and consultation to clarify
the status of FLEGT Licencing compared to third party
certification.
It also recommends measures to facilitate VPA signatory
countries to themselves lead the process of communicating
the role and positive impacts of the timber legality
assurance systems being developed under the terms of
FLEGT VPAs.
The report can be downloaded at
http://www.flegtimm.eu/index.php/latest-newsletter-autumn-
2018/141-flegt-s-profile-in-promotion-and-marketing-is-lowrelative-
to-certification
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