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Illegal Logging – Evaluation of EU Rules (Fitness Check)

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Illegal logging – evaluation of EU rules (fitness check) February 28, 2020 Please accept this feedback from the Partnership for Policy Integrity, a US based NGO working with allies across Europe for the protection and restoration of natural forests.1 The European Union Timber Regulation (EUTR) is a step in the right direction and there are good examples of it being used effectively by the Commission, Member States, and NGOs.2 However, illegal logging remains a serious problem across Europe.3 As the EU Council has recognised,4 addressing illegal logging requires effective implementation of the EUTR, but also curbing demand for the timber that is driving illegal logging. Taking each of these in turn we make the following recommendations: 1. Strengthen the EUTR by: - Including all forest related products in the annex. This will become even more relevant as the concept of a bioeconomy expands. - Guaranteeing checks across the whole of the supply chain. The supply chains are often long, and laundering of timber can occur at various points along the supply chain. - Allocating more resources to National Competent Authorities to conduct industry checks across the whole supply chain. - Allocate greater resources for on-the-ground enforcement. 2. Curb the demand for legal wood products/forest products posed by the RED II : halt subsidies for biomass. 1 Partnership for Policy Integrity website: https://www.pfpi.net/ 2 Clientearth resources at https://www.clientearth.org/illegal-logging/ 3 European Data Journalism Network, “Timber mafia and deforestation in Romania”, 18 February 2020, https://www.europeandatajournalism.eu/eng/News/Data-news/Timber-mafia-and-deforestation-in-Romania 4 Conclusions of the Council and of the Governments of the Member States sitting in the Council on the Communication on Stepping Up EU Action to Protect and Restore the World’s Forests - Council conclusions, 16 December 2019, https://www.consilium.europa.eu/media/41860/st15151-en19.pdf To reduce illegal logging, it is vital that the EU does what it can to reduce demand for forest products, including reducing the unprecedented and staggering demand for wood fuel both for residential heating and commercial/industrial biomass energy. The treatment of wood as providing “renewable energy” under the existing Renewable Energy Directive (RED) and the RED II (which comes into effect in 2021) is responsible for a large increase in wood burning in Europe. Wood burning for residential heating currently constitutes about 60% of reported wood use for energy in the EU. The EU’s own reporting (JRC report from Camia et al, “Biomass production, supply, uses and flows in the European Union”) shows that about 13% of the wood used in the EU comes from “unaccounted,” possibly illegal sources. Some countries have seen large increases in wood- burning, for example Italy, where government policies encourage use of wood as fuel. About 80% of all wood use in Italy is for energy, and about 75% of that is for residential heating. According to Camia et al, a full 40% of the wood used in Italy comes from “unaccounted sources,” and there is strong evidence to indicate that some of this wood is illegally logged in Romania’s Carpathian mountains. That the wood pellet industry is in part using illegally logged timber has been well-established.5 Romanian activists have recently uncovered data showing illegal harvesting of 20 million m3 per year,6 for a total of around 39 million m3 annually. This is in contrast to the Eurostat-reported data of 14.5 million m3 for 2017. These concerns cannot be rectified through the sustainability criteria for biomass within the RED II; it is the sheer scale of the demand for biomass which inevitably renders the project for biomass a disaster for forests. At such a precarious moment for people and planet it is vital that “solutions” to the climate crisis do not exacerbate it. The EU needs to face up to its biomass problem and acknowledge that providing lucrative subsidies for biomass, which is sourced from “low value” wood, is a major driver for illegal logging in Europe. Existing use of wood is already undermining the EU’s forest carbon sink and exacerbating illegal logging – we cannot afford continued and accelerated exploitation of forests for fuel. Thank you for the opportunity to submit comments. Mary S. Booth, Director, PFPI 5 EIA and Agent Green. 2015. Stealing the Last Forest. https://www.illegal- logging.info/sites/files/chlogging/EIA%20(2015)%20Romania%20Report.pdf; also Fern, 2016, “Up in flames How biomass burning wrecks Europe’s forests” (2016), https://www.fern.org/fileadmin/uploads/fern/Documents/Up%20in%20Flames.pdf 6 https://www.romania-insider.com/minister-confirms-illegal-logging-report .
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