General Comments The Executive Summary of Failing the Forests clearly recognises the need to derive estimates for the percentages of illegal timber in trade that are much more robust than those adopted in the report (please see detailed comments, para 1). A formal request was made by industry, research institutions and NGOs to Ministers prior to the G8 Summit in March 2005 with that in mind. Failing the Forests sets out to forecast levels of trade in wood-based products in general (and trade in illegal timber in particular) up to the year 2015. The estimated percentages of illegal timber were adopted in order to provide a starting point for those forecasts. The forecasts themselves are a combination of qualitative and quantitative assessment to show what might happen given certain assumptions. The ranking of countries by their potential illegal timber imports provided in the Executive Summary of Failing the Forests is, for the leading importers, the same as that in the FIIL critique (which covers a narrower range of products than Failing the Forests). The overall percentage suggested in the FIIL critique is, in qualitative terms, also largely the same as that suggested in Failing the Forests. Both indicate that roughly one quarter of the EU's timber imports are likely to comprise illegal timber. The difference in quantitative terms is of less relevance than the essential point that the proportion suggested by each is high enough to warrant concerted remedial action. Failing the Forests does recognise (and commends) the efforts of the industry to improve the traceability of imported wood products and filter out illegal material from supply chains. Failing the Forests also recognises the need to measure & evaluate any reduction in illegal timber imports that those efforts have achieved. Further, Failing the Forests recognises that progress under FLEGT (the EU action plan on Forest Law Enforcement Governance and Trade) towards minimising EU imports of illegal timber may not be sufficiently rapid or widespread to have a very positive impact on trade in illegal timber from the countries of the six regions. This does not imply a lack of support for the current FLEGT process but more that WWF believes that additional measures and actions will also be necessary. Failing the Forests focuses on the EU as a bloc that one might regard as a role model for other parts of the world whose impact on illegal timber production and trade may be greater than that of the EU. Indeed, Failing the Forests stresses the importance of involving China and the USA into the process. Detailed Comments on the FII independent appraisal of the WWF “Failing the Forests” report 1.Inadequate data The Failing the Forest report (executive summary and the full report) highlights that there are no consistently available published estimates of the proportion of illegal timber in countries’ exports of wood-based products. We have set out how we have calculated the figures both in the exec summary and in more detail in the full report. I.e. that we have assumed that the percentage of illegal wood products exported is the same as the estimated percentage of illegal logging in a country. The report considers that the robustness of this assumption would rise as the share of production that is exported rises. The report also recognises that actual illegal logging & trade may be significantly different to this, depending on characteristics of the trade flows and any steps being taken by industries and governments. There is however no official data available to describe the situation. WWF would be pleased to participate in studies to clarify the scale and scope of the issue. The methodology which the report has used for calculating the estimated illegal timber imports is not new. The European Forest Institute published a report at the start of November, which said that 10-15% illegal logging estimated for NW Russia applies to both production & export. The “Failing the Forests” report has used this same logic for its data calculations. 2. Controversial definition of “illegal logging” The definition in the glossary of the full report (which are not necessarily endorsed by WWF) and on which both the findings of the report are based is as follows: “Illegal Timber” Wood-based products deriving from forestry practices or activities connected with wood harvesting, processing and trade that do not conform to national law. Given that major capital investments follow the allocation of forest ownership, logging rights and approvals for mill development, there is particular need for transparency in the allocation process so as to minimise the risk of corruption and money laundering.” WWF deliberately avoided controversy in terms of the definition we used for this report to keep things as clear as possible. Again the definition used is not necessarily endorsed by WWF. However, some of the data used in the report is sourced from reports which have a wider definition of illegal timber. Some initial attempts were made to adjust the figures accordingly, however it was deemed better to stick with the existing data for sourcing and reference purposes. 3. documents…which exploit weaknesses in available information on levels of illegal logging and trade in an effort to encourage policy makers in a particular direction The report does not attempt to exploit these weaknesses but rather highlight them and call again for significant improvements in this area. These weaknesses were highlighted as an issue in the full report (“Issues around data interpretation”). The forecasting undertaken by the report is based on overall trends and a number of assumptions which highlight the risks and opportunities associated with what might happen to the trade in timber and pulp and paper. The weaknesses in the data currently available does not affect these forecasts. 4. Publication of the Failing the Forests report….may also be contributing to a myth that an accurate assessment of levels of trade in “illegal” wood can be carried out. See our comments above on issues around available data. As already stated we have made as accurate assessments as are possible given current available data. Also there are very clear caveats both in the Executive Summary and the full report; to quote from the table in the Exec Summary which presented the league table: “Note that amounts shown are estimates (particularly those pertaining to illegal timber) and exclude indirect imports via third countries, notably China. 5. Failing the Forests….should be subject to peer review Actively welcome this proposal and any open discussion of the issues the report raises. This was one of the key reasons why the report was commissioned. In particular we would welcome an evaluation on how effective government and industry measures to tackle the trade in illegal and unsustainable timber have been so far and what impact this has had on the current estimated data. A full copy of the report has been available on request since the launch of the Executive Summary (we received no such request from Forest Industries Intelligence). The report will be put on the WWF-UK website on December 2nd . There will also be a limited number of hard copies available after December 2nd. 6. Statements of apparent “fact” by national newspapers and other respected institutions It was unfortunate that two national newspapers made mistakes in their articles: The UK Independent miscalculated the % UK imports on the basis that they did not recognise that the report covered 6 producing regions/countries and not the whole world. The Telegraph quoted from figures from the WWF press release which calculated an area estimate for the UK based on the estimated figures arising from the report. The Telegraph figures quoted by Forest Industries Intelligence are correct. However the Telegraph were incorrect when they quoted an import value of £2 billion for the UK. This should have been for the EU. Chatham House quoted correctly from the WWF press release which used data direct from the report. We have no control over how the journalists choose to cover the issue or how they write their articles.