Thoughts on the SFI “Misrepresentations” document…

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Thoughts on the SFI “Misrepresentations” document… Powered By Docstoc
					To:            BIFMA e3 Furniture Sustainability Standard Joint Committee members

From:          Caroline Pufalt, on behalf of the Sierra Club Forest Certification Committee
               Rolf Skar, Greenpeace
               Peter Goldman, Washington Forest Law Center

Date:          October 22, 2010

Re:            Letters submitted to Joint Committee Chair Dr. Matthew Realff by the
               Sustainable Forestry Initiative (SFI) and Weyerhaeuser dated September 20, 2010

Overview
The key decision that BIFMA confronts with respect to certified wood and forest certification is
whether FSC and SFI in fact represent equivalent levels of environmental and social
performance and therefore merit equal weighting in the level e3 Furniture Sustainability
Standard.

Through the deliberations of the Wood Sub-group, we believe it will become clear to the Joint
Committee that there are indeed significant differences in the rigor and quality of FSC and
competing forest certification programs that merit differential treatment. The nature of forest
certification is such that analysis and debate must involve complex technical details.
Unfortunately, the focus on detail needed to clarify the differences between systems is often
confusing (especially to those who are not experts in forest management, the forest products
industry, and forest certification) and in fact can obscure rather than elucidate the most profound
distinction between FSC and SFI. Hence, we would like to take this opportunity to throw light
upon this most basic difference.

FSC is a true leadership standard. Like other leadership standards (LEED is a notable example),
its basic purpose is to codify practices that reach well beyond the status quo with the goal of
driving market transformation to sustainability. Sierra Club, Greenpeace, ForestEthics and over
140 other environmental groups support FSC precisely because we believe FSC is pulling the
forest products industry toward greater sustainability -- and because we have a significant and
continuing role in shaping FSC‘s certification standards, correcting its deficiencies, and driving
its improvement.

By contrast, SFI was created by the U.S. mainstream forest products industry as a foil to FSC,
and its basic purpose has always been to slow or stall market transformation. As the creature of
vested interests, SFI‘s fundamental goal and raison d’être is to protect and further those
interests—most importantly, a model of intensive, industrial forest management that seeks to
maximize fiber production and profitability. It is therefore no surprise that many of the
environmental and social measures in the SFI standard amount to vaguely-worded, loophole-
ridden window dressing (see, for example, pg. 11 below) that seek to disguise its central
purpose—not just to defend, but to legitimize status quo industrial forestry as somehow
responsible and ―sustainable.‖



                                                                                                     1
Consider:

      SFI is the creation of the largest forest products industry trade association, the American
       Forest & Paper Association (AF&PA). It was launched in 1994, a year after the founding
       of the Forest Stewardship Council (FSC), as an industry-based, industry-controlled
       response to FSC.

      There is no evidence that SFI receives meaningful financial support from organizations
       outside the forest products industry. According to the 2006 and 2007 IRS 990 forms filed
       by SFI, the newly ―independent‖ organization expanded from $675,000 in total revenue
       in 2006 to $5,500,000 in 2007. SFI refuses to make publicly available the sources of this
       enormous investment in their program. In the absence of evidence to the contrary, it is
       reasonable to conclude that it is almost entirely derived from its forest products industry
       creators. In its communications, its lobbying activities, and its management style, SFI
       operates more like a trade association than the public charity it claims to be.

      SFI is not a democratic, membership-based organization — in fact, Article II of the SFI
       by-laws states that ―The Corporation shall not have members.‖ In other words, SFI has
       no mechanism for organizations or individuals to join, participate in decision-making,
       and elect directors like FSC does. Instead, SFI has program participants that are all forest
       products companies and committees that are dominated by companies. Far from equally
       representing environmental, social, and economic stakeholders, from a participation
       standpoint, SFI is heavily weighted to only one leg of the 3-legged sustainability stool.

      The SFI Board of Directors is an appointed body, and new board members are appointed
       by the existing board. SFI cannot fairly claim to equally represent environmental, social,
       and economic interests as long as they continue to hand pick their board members.

      While it‘s true that a relative handful of conservation organizations are represented on the
       SFI Inc. Board of Directors, the overwhelming majority of environmental groups most
       active in forest conservation and certification oppose SFI.

      On its website, SFI‘s definition of social interests is ―[b]oard members representing the
       social sector, which includes community or social interest groups such as universities,
       labor, professional loggers, family forest owners or government agencies‖ (emphasis
       added). Current and/or recent past SFI ―social sector‖ board members include a state
       forester for the Oregon Department of Forestry and a representative of the American
       Loggers Council. The latter would be considered Economic Chamber members in the
       FSC, whose Social Chamber comprises representatives of indigenous peoples
       associations, labor unions, and other genuine social interests.




                                                                                                   2
At its lowest common denominator, the SFI standard generally defaults to forest laws and state-
developed Best Management Practices (BMPs).1 Compliance with laws and BMPs alone by no
means represents exemplary forestry — quite naturally, it more often represents status quo
forestry, and in other cases only modest improvements over status quo practices that still fall
well short of genuine environmental and social responsibility, to say nothing of ecological
sustainability. Under SFI, the removal and conversion of large blocks of mature and complex
forests to short-rotation clone plantations passes for ―sustainable‖ forestry.

SFI and its industry supporters often argue that choice and competition between forest
certification systems is good for everyone. Choice between forest certification systems can
indeed be beneficial to the extent that competition can drive improvement among all systems.
However, to the extent that ―choice‖ confuses the marketplace and falsely professes equivalence
between standards and practices that do not represent the same level of environmental and social
performance, it is far from being beneficial. In fact, it is deceptive and harmful greenwashing.

Suppose that there is a choice between two green building rating systems. The first defines a
building as ―green‖ if it incorporates a comprehensive host of innovative techniques and
materials and represents dramatic resource savings and occupant health benefits over
conventional practice. The second defines a building as ―green‖ if it meets state building codes
and uses compact-fluorescent light bulbs and low-flush toilets. Is such a choice ―good‖? If the
two are accepted as equivalent, then who benefits, and who is encouraged to improve?

Choice between forest certification systems does not benefit the public interest when it disguises
rather than reveals real, substantive differences between standards and practices. It does not raise
the bar on forest management or deliver progress on the ground unless all the forest certification
system alternatives reach well beyond status quo practices.

Choice is good only if everyone is operating on a level playing field. Consider this: SFI permits
intensive industrial forest practices that represent substantially lower operating costs for forest
products companies than FSC which requires higher levels of environmental and social
performance; otherwise stated, the costs of SFI forestry are generally lower because SFI
externalizes costs that FSC internalizes. This means that SFI forestry offers the potential for
higher short-term profits than does FSC forestry, e.g. by maximizing the production of
commercial species regardless of negative environmental and social impacts. If SFI and FSC are
represented as functionally equivalent, then a ―choice‖ between the two harms both the leaders
and risk-takers certified under FSC‘s more stringent system as well as the consumers who are led
to believe that they are buying the same thing—when in fact they are absolutely not.

It all comes down to integrity and high standards. We will not conserve and protect the world‘s
forests without market transformation in the global forest products industry, and market
transformation can only be driven by standards that represent true environmental and social
leadership.

                                                      * * *

1
  It should be noted that we refer to these state-developed and industry-friendly guidelines as BMPs solely because
state agencies and industry practitioners refer to them as such.


                                                                                                                      3
In two letters dated September 20, 2010, Weyerhaeuser and SFI argue strenuously against certain
assertions made by Sierra Club, Greenpeace, and ForestEthics. They attribute the letter that
contains these assertions to a single individual, Jason Grant. Let us start by correcting this
recurring error: while Mr. Grant had a hand in the letter that the environmental groups submitted
to BIFMA, he was neither its sole nor its principal author. The views expressed in the letter were
a group effort and are shared by all of its signatories and their organizations.

SFI and Weyerhaeuser take rather different approaches in their letters, but they also make the
same or similar arguments on certain points. We begin by responding to the overlapping
arguments and then proceed to those that are unique to each.

Variability of FSC Standards
SFI/Weyerhaeuser argument:

FSC standards are variable, both within the United States and in the more than 50 companies in
which FSC operates, and FSC-certified products can come from a wide variety of practices. The
implication is that, with FSC, the variation in standards is indicative of a lack of consistency and
rigor. By contrast, they argue, ―SFI certification represents a secure, legal, third-party certified
source of fiber from the United States and Canada, countries with a foundation of strong social,
economic and environmental laws.‖

ENGO response:

It is true that the FSC system has mechanisms that allow for, and indeed encourage, the tailoring
of FSC forest management standards to address the specific environmental and social
characteristics of the areas around the world where it operates. This is entirely appropriate given
the variation among the forests, plantations and countries in which FSC is applied. Responsible
forestry in the tropical rainforests of Papua New Guinea will not exactly resemble responsible
forestry in the Canadian boreal.

What SFI/Weyerhaesuer consistently neglect to mention is that FSC's tailoring process takes
place at the level of relatively fine detail (what are called Indicators), and that the standards
remain universally consistent at a higher level (the Principles and Criteria). For example, the
requirement for riparian protection is universal, but the exact size of the prescribed streamside
buffers may vary depending on the type of forest landscape.

Another thing that SFI omits is that there is variation in the state legal structures and BMPs that
form the foundation for its forest management standards that often exceeds that of FSC. For
example, under SFI, forest buffers for a certain stream class must be 80 feet in the state of
Washington and range from 50-100 feet (dependent on slope) in California. In Oregon,
clearcutting can go right down to the stream edge with no required buffer. FSC requires a 100-
foot buffer across all three states.




                                                                                                      4
SFI also omits the fact that it treats fiber that is certified not by SFI but by Canadian Standards
Association (CSA) and American Tree Farm System (ATFS) as certified content for the
purposes of SFI product claims and labeling. A forest certification system is only as stringent as
its lowest common denominator. Because SFI accepts CSA- and ATFS-certified wood as fully
equivalent to SFI-certified wood in its system, the weaknesses of those certification programs are
SFI‘s weaknesses as well – and make the SFI system far more variable and less consistent than
SFI and Weyerhaeuser imply.

For instance, under ATFS:

-- there are no required protections for High Conservation Value Forests
-- there are no required limits on deforestation
-- there are no requirements for public consultation and stakeholder input
-- there is no protection of rare or threatened beyond the protections afforded by law
-- there is no requirement to retain key elements of forest ecosystems and their functions

SFI asserts that the United States and Canada have ―a foundation of strong social, economic and
environmental laws‖ and implies that this should provide a basis for confidence in SFI-certified
products. However, such laws have proven inadequate to curtail the patently negative
environmental impacts of the SFI-certified forest practices pictured in the following pages:




                                                                                                   5
Above: SFI-certified Weyerhaeuser clearcuts and multiple landslides on slopes with gradients
up to 120% with highly unstable and highly erodible soils (Seattle Times December 2007)


                                                                                               6
Below: SFI-certified logging, Nova Scotia, 2009




                                                  7
We agree that U.S. and Canadian forest laws provide a necessary foundation of minimal
acceptability, but they do not represent ―strong‖ environmental standards, much less exemplary
or sustainable forest management. Federal, provincial, or state statutes and regulations or state
programs like BMPs inadequately address a host of crucial environmental and social concerns.
Most states do not adequately protect imperiled wildlife, restrict the conversion of forests to
plantations and non-forest land uses, protect old growth and other rare ecological communities
on commercial forestlands, or require forests impacted by past management to be managed in a
way that begins restoring their ecological integrity. If legal protections were in place that
adequately addressed these issues, then the need for a leadership standard in forest certification
like FSC would be much reduced, at least in the North American context.

It‘s bad enough to cite mere legal compliance as the basis for claims of ―sustainability,‖ but in
the recent past SFI has done far worse by certifying companies that conduct illegal logging in the
U.S. and Canada. According to the Natural Resources Council of Maine,2 Plum Creek has
clearcut so aggressively that they received the largest civil penalties in the history of the Maine
Forest Practices Act. Plum Creek also violated Land Use Regulation Commission rules when it
developed a 7,500-foot-long power line corridor without a permit. In addition, Plum Creek
conducted road work in a manner noncompliant with the Commission‘s standards, which
polluted streams with sediment and violated water quality standards. In another example, the
Environmental Protection Information Center documented more than 325 violations issued to
SFI-certified Maxxam/Pacific Lumber Company from 1999-2004.3 Violations included the
illegal harvest of trees from riparian management zones, Marbled Murrelet and Spotted Owl
habitat conservation areas, as well as damage to protected plant species, unlawful herbicide
spraying, and failing to meet post-logging stocking requirements. Maxxam/Pacific Lumber‘s
track record was so bad it became the first logging company ever to lose its license to operate in
California, yet from 2001 when the company was first SFI certified right up to 2007 when it filed
for bankruptcy, it retained its SFI certification.

Old-growth forests, high-conservation value forests, and logging of
threatened and endangered species’ habitats
SFI/Weyerhaeuser arguments:

―FSC standards allow the harvest of rare old-growth forest in the U.S. and elsewhere, in some
cases at considerable scale.‖ (Weyerhaeuser)

The SFI standard ―requires program participants to identify and protect ecologically significant
forests, including old-growth forests and Forest with Exceptional Conservation Value.‖ (SFI)

SFI program participants are ―required to protect threatened and endangered species [and]
promote the conservation of native biological diversity…‖ (SFI)



2
    Environews Report: Investigation Exposes Plum Creek Timber Violations (www.maineenvironment.org).
3
    Pacific Lumber's Record: Lawless Logging Continues (http://www.wildcalifornia.org/pages/page-157).


                                                                                                         8
ENGO response:

While they are made separately by Weyerhaeuser and SFI respectively, taken together the first
two statements suggest that SFI offers superior protections when it comes to old-growth and/or
high-conservation value forest than does FSC. The opposite is true.

SFI standards do not require the conservation of old-growth forests on the Program Participant‘s
lands. Instead, SFI requires landowners to ―support‖ plans ―in the region of ownership‖— a
requirement whose effectiveness is doubtful at best. Such plans can have very indeterminate
goals, and ―support‖ could merely consist of a public statement. In fact, the logging of old-
growth forests has been documented for a number of SFI-certified companies on lands they own
in the U.S. and Canada, including Maxxam/Pacific Lumber, Sierra Pacific Industries, Plum
Creek Timber, Stimson Lumber, the Timber Products Company, the Hinton division of
Weldwood (an International Paper subsidiary), and TimberWest. Old-growth forest has also
been harvested on publicly-owned lands by SFI-certified companies, such as Sierra Pacific
Industries, Boise Cascade, Hampton Resources, and Rosboro Lumber.4

The logging of old growth by these SFI-certified companies has led to the liquidation of some
extensive forest stands of exceptionally high conservation value and an elimination of the values
associated with these forested areas.

The FSC approach to protection of old growth is fundamentally different. A central difference
between FSC and SFI is that FSC may allow logging of old growth under exceptional
circumstances, but ensures the protection of the values associated with those forests.

For old growth in the U.S., FSC requires that all Type 1 old growth (never logged) be protected
from harvesting and that type 2 old growth (entered, but with old growth characteristics) be
protected from harvesting to the extent necessary to maintain the old growth structure and
function (Indicator 6.3.a.3). Old, legacy trees are not allowed to be harvested (Indicator 6.3.f).

FSC does allow, and encourages, forest management practices whose continuation will gradually
lead to old growth conditions. Thus, long rotation forestry that creates ecological conditions
approaching old growth is encouraged and trees are allowed to be harvested as long as the spatial
extent and values associated with the old growth are maintained. When old trees are grown, old
trees can be harvested. The Hoopa Tribe is one of the few tribes that kept their tribal lands out of
reach of heavy logging pressures in the 1900s. FSC has a policy unique to harvest of old growth
on tribal lands where tribes have documented a commitment to ensuring the maintenance of old
growth values on the Forest Management Unit (FMU).

SFI standards fail to protect ―endangered forests‖, which are defined as ―native forest ecosystems
of high ecological value that require protection from intensive industrial use to maintain these
values.‖5 Ecological components used to define endangered forests include:


4
  A Review of the American Forest & Paper Association‘s Sustainable Forestry Initiative, American Lands Alliance
(2003).
5
  Ecological Components Of Endangered Forests, Forest Ethics et al. (2006).


                                                                                                               9
    1. Intact forest landscapes
    2. Remnant forests and restoration cores, including:
           a. Landscape connectivity
           b. Rare forest types (composition and structure)
           c. Forests of high species richness (alpha and beta diversity)
           d. Forests containing high concentrations of rare and endangered species
           e. Forests of high endemism
           f. Core habitat for focal species (aquatic and terrestrial)
           g. Forests exhibiting rare ecological and evolutionary phenomena

Likewise, SFI doesn‘t require identification and protection of most of what‘s covered under the
FSC‘s definition of ―high conservation value forests,‖ which has become a worldwide standard
well beyond its use by the FSC.

SFI does require that ―procurement must not compromise the conservation of biodiversity
hotspots and major tropical wilderness areas‖ [emphasis added] when it is sourced from non-
certified land outside of the U.S. and Canada, but this does not preclude the harvest of timber
from these areas. In addition, biodiversity hotspots and major tropical wilderness areas are
geographically limited and biased toward the tropics, hence the need for explicit protection of
temperate and boreal old-growth and endangered forests in North America as well.

As for SFI‘s statement regarding the protection of endangered and threatened species listed
under the Endangered Species Act (ESA), SFI appropriately protects species that are critically
imperiled (G1) and imperiled (G2) on a global scale, but not all threatened and endangered
species are classified as such or receive the same level of protection. In contrast, FSC standards
require protection of Rare, Threatened and Endangered (RTE) species and communities, which
include G1-G3, S1-S2, and some S3 (subnational, vulnerable) species. Further, SFI does not
require its Program Participants to conduct surveys to determine the presence or absence of
critically imperiled and imperiled species prior to conducting management activities,6 which may
allowing their habitat to be destroyed. If there is a likely presence of RTE species in an FSC-
certified forest, then ―either a field survey to verify the species' presence or absence is conducted
prior to site-disturbing management activities, or management occurs with the assumption that
potential RTE species are present‖ (Indicator 6.2.a).

Even though the SFI standard requires landowners to develop programs to protect species listed
as threatened and endangered, SFI has been certifying landowners who have ESA ―take‖
permits, allowing the destruction of most and in some cases all of the remaining species‘ habitats
and populations on their certified properties. For example, a Habitat Conservation Plan
developed by SFI Program Participant Plum Creek plans for the destruction or degradation of
over 20,000 acres of habitat for the threatened Northern Spotted Owl, including 107 owl nest
sites. Grizzly bears will lose 71% of their foraging and prey habitat, and a host of other species
will lose 3 to 26% of their primary habitat areas.



6
 Interpretations for the SFI 2010-2014 Program Requirements: Standards, Rules for Label Use, Procedures and
Guidance, section 4.5.


                                                                                                              10
Some SFI-certified companies without ESA ―take‖ permits have illegally ―taken‖ (or harmed)
threatened and endangered species. In 2007, SFI-certified Weyerhaeuser was legally enjoined
from additional logging of suitable habitat within four Spotted Owl breeding territories to
prevent further ―harm‖ to the owls.7

SFI standards generally do not offer strong environmental protections because they typically lack
clear, enforceable criteria, and excessive discretion is allowed in their interpretation. The vast
majority of performance measures (PMs) and indicators require only the development of a
―plan‖ or ―policy‖ without specific environmental, social, or economic outcomes to make
Program Participants accountable for their practices. Loopholes and considerable subjective
discretion in the ―appropriateness‖ of adherence to standards can be found throughout the SFI
standards, for example:

        ―Artificial reforestation programs that consider [as opposed to minimize] potential
         ecological impacts of a different species or species mix from that which was harvested‖
         (PM 2.1, Indicator 5).
        ―Program addressing [as opposed to requiring] management and protection of rivers,
         streams, lakes, and other water bodies and riparian zones‖ (PM 3.2, Indicator 1).
        ―Support of and participation in plans or programs for the conservation of old-growth
         forests in the region of ownership‖ [as opposed to their own lands] (PM 4.1, Indicator 6).
        ―Trees in clearcut harvest areas are at least 3 years old or 5 feet (1.5 meters) high at the
         desired level of stocking before adjacent areas are clearcut, or as appropriate to address
         operational and economic considerations, alternative methods to reach the performance
         measure are utilized by the Program Participant‖(PM 5.3, Indicator 3).
        ―Although conformance with laws is the intent, certification bodies are directed to look for
         a spirit and general record of compliance rather than isolated or unusual instances of
         deviation [condoning of illegal activities]…‖ (emphases and bracketed comments added)

Conversion of natural forests to plantations and to non-forest uses
SFI/Weyerhaeuser arguments:

―FSC standards allow the conversion of natural forest to plantations.‖ (Weyerhaeuser)

―Lands being converted at any significant scale to non-forest uses cannot be certified under any
of the forest certification standards.‖ (Weyerhaeuser)

―According to U.S. Forest Service data, conversion of forestlands is at a rate of less than 1/10th
of one percent per year. The major cause of conversion is not natural forests to plantation, but
forests being sold for development and other non-forest uses.‖ (SFI)




7
    Seattle Audubon, et al. v. Doug Sutherland, et al.


                                                                                                     11
ENGO response:

SFI does nothing to restrict the conversion of natural forests to plantations of the conversion of
forests of all kinds to non-forest uses.

Weyerhaeuser‘s claims that ―Lands being converted at any significant scale to non-forest uses
cannot be certified under any of the forest certification standards‖ are misleading. Under SFI,
the wood coming from that land cannot be claimed as certified, but nothing happens to the
certificate holder and all the other wood produced by that owner remains certified. In the FSC
system, by contrast, such practices are grounds for the certificate holder to lose their certificate
and thus none of the wood from that owner will remain certified. FSC prohibits certified timber
companies from converting forests on both their certified and uncertified lands.

SFI does not prohibit its certified timber companies from converting their lands from forest to
urban uses, and these companies often form separate real estate and development branches for
this express purpose. For example, the Weyerhaeuser Real Estate Company (WRECO) sells
―forested parcels…complete with forest management plans—for home sites.‖ They boast of
being ―the umbrella company for six homebuilding-related businesses, [and] one of the 20
largest homebuilders in the country.‖8 Plum Creek is another SFI-certified company that is
actively converting portions of its forests to non-forest land uses. For instance, Plum Creek
intends to sell 225,000 acres (of its 8 million acres of land holdings) for real estate development.9
SFI even has a definition for ―conversion sources‖ of wood as ―roundwood and/or chips
produced from conversion of forestland to other land uses. Manufacturers can use this wood to
avoid wasting it but cannot include it when calculating certified forest content component.‖10 If
converted land holdings are simply removed from an SFI certificate, it doesn‘t change the fact
that once-certified lands have been permanently converted to non-forest uses.

A conversion rate of 1/10th of one percent translates into approximately one million acres of
forest conversion per year in the U.S., and this is one million acres too many—especially when
that conversion occurs in increasingly rare natural forest types. A misleading statistic that‘s often
quoted by some forest industry advocates is that the amount of forest land in the U.S. is
relatively constant since the early 1900s. This says nothing about the ecological makeup, the
biodiversity, and the social values of the forest. Conversion of biodiverse natural forests to
depauperate monoculture plantations does not show up in statistics addressing loss of
forestlands. Further, just because the quantity of forest conversion represents a small proportion
of the forest extent in the U.S. doesn‘t mean that it‘s okay and can be supported by a credible
forest certification system.

FSC recognizes that tree plantations can play a role in forest conservation only under restricted
conditions when they contribute to the preservation or restoration of natural forests. FSC
standards preclude certification of forests converted to plantation since 1994 except under highly
extenuating circumstances, such as when the owner was not responsible for the conversion and

8
  http://www.weyerhaeuser.com/Businesses/Wreco
9
  http://phx.corporate-ir.net/phoenix.zhtml?c=68740&p=irol-newsArticle&ID=851604&highlight=.
10
   Requirements for the SFI 2010-2014 Program: Standards, Rules for Label Use, Procedures and Guidance.


                                                                                                          12
that the principle goal of the plantation is that of restoration (i.e. it is being restored to a natural
forest as fast as is feasible). SFI has no such restriction of certification of plantations created at
the expense of increasingly rare natural forests.

Among the requirements for FSC-certified plantations that were converted prior to 1994 is a
component of maintenance or restoration to natural forests. The percentage of a forest
management area that must be maintained or restored to natural forest conditions varies by
region. There are also restrictions on clearcutting, chemical uses, stream and wetland
management, soil disturbance, and habitat structures, among myriad other conditions that set
FSC-certifiable management apart from SFI-certifiable management.

Chemical Use
SFI/Weyerhaeuser arguments:

FSC certifies ―plantations around the world, without unusual restrictions on chemicals.‖
(Weyerhaeuser)

―All certification standards, including SFI and FSC, recognize the important role of chemicals
and allow for their use in forest management.‖ (SFI)

ENGO response:

While the SFI standards impose some limitations on chemical use, they allow landowners to
place a higher priority on achieving ―management objectives‖ than on minimizing chemical use
(PM 2.2):

    1. ―Minimized chemical use required to achieve management objectives.‖
    2. ―Use of least-toxic and narrowest-spectrum pesticides necessary to achieve management
       objectives.” (emphases added)

Additionally, SFI fails to require forest practices that reduce the need for chemical applications
while maintaining productivity, such as selection forestry, longer timber rotations, pre-
commercial thinning, and thin and release treatments. SFI standards allow landowners to choose
management regimes (like short-rotation, intensive clearcuts) regardless of whether those
regimes tend to require intensive and routine chemical inputs, and only then require landowners
to minimize chemical use in the context of those management regimes.

In contrast, FSC requires that all certificate holders strive to minimize chemical use and FSC-
compliant silvicultural systems tend to require less use of chemicals in the first place.

Finally, FSC has an international policy restricting pesticides that are determined to be ―highly
hazardous‖ including many chemical herbicides and insecticides that are routinely used in status
quo forestry in the U.S. FSC does allow temporary use of some of these chemicals under
extenuating circumstances that requires a rigorous, stakeholder-involved derogation process. US
EPA laws regulating pesticide use is insufficient in some cases: for example some of the


                                                                                                       13
chemicals that are widely used in industrial forest management, such as atrazine, have far-
reaching ill effects, including toxicity to non-target organisms and persistence in soils and water
bodies.

Short-rotation logging that harms soil and water quality
SFI arguments:

―The SFI Standard has strong requirements for soil and water quality. Not only do SFI-certified
companies have specific requirements for lands they manage, but any company procuring fiber
from the forest must meet rigorous requirements for ensuring water quality is looked after on the
lands they source from.‖ (SFI)

ENGO response:

As often is the case, SFI‘s protections for soil and water quality look good on paper, but what
actually happens in SFI-certified forests and the forests covered by SFI fiber sourcing is another
matter entirely.

As we continue to point out, a practice condoned by SFI that is among those most deleterious to
soil and water quality is large-scale, high-intensity clearcutting (even when followed by tree
planting). When it is repeated every 40 or 50 years as is typical in some parts of North America,
large-scale clearcutting contributes to the decline of natural soil fertility, to soil erosion, to the
warming and siltation of waterways with attendant harm to fish spawning grounds, and so forth.

The SFI standard has a single, continent-wide requirement that clearcuts average less than 120
acres. This means that individual clearcuts can be much larger, because when large clearcuts are
coupled with many smaller clearcuts, the average can be kept below 120 acres.

Large-scale clearcutting is an especially harmful practice when it occurs on steep and unstable
slopes. For example, the widespread clearcutting of thousands of acres of steep slopes with high
landslide risk by Weyerhaeuser in southwest Washington was the primary cause of at least 1259
landslides that occurred during a large storm in December 2007 (see pictures on page 6).11
Record flooding of the Chehalis River basin ensued, impairing the water quality, closing the
interstate highway for nearly a week, and devastating local communities downstream. SFI has
not publicly reprimanded Weyerhaeuser for these violations nor have they required stricter
compliance with SFI standards.

By contrast, clearcut limits in the FSC-US standards include maximum sizes of two acres in the
Ozarks, six acres in the Pacific Coast, and ten acres in Appalachia, among others. Clearcuts as
large as 120 acres can only be ecologically justified in North America in rare circumstances,
such as those covered by the FSC Boreal Standard which applies in northern Canada. This is
among the most progressive forest management certification standards in the world because the
requirements are based on regionally-specific ecological conditions and come with a suite of

11
     http://wflc.org/sitefiles/Credforestcertification/EntrixReport/download


                                                                                                     14
compensatory beneficial requirements and conditions. Under the Boreal Standard, the size
allowance for clearcuts is set by foresters and biologists guided by the average size of natural
disturbances that sometimes level forests in the area, i.e. the average extent of forest fires, insect
infestations or blow-downs. Thus, under FSC, harvests replicate what has been happening over
millennia and facilitate natural regeneration.

Additional examples of harm to water quality and aquatic resources by SFI-certified companies
include the degradation of streams from debris flows originating from Sierra Pacific Industry‘s
roads and clearcuts on steep, unstable slopes in the Upper Trinity River Watershed of
California.12 In the Beaver Creek watershed of the Klamath region, many of Timber Products‘
lands have over five miles of road per square mile, contributing to sedimentation that has
destroyed fisheries restoration projects downstream.13

Finally, SFI states that ―any company procuring fiber from the forest must meet rigorous
requirements for ensuring water quality is looked after on the lands they source from.‖ This is an
apparent reference to SFI‘s requirement that companies engaged in SFI fiber sourcing comply
with state Best Management Practices (BMPs), but BMP compliance is not equivalent with
strong protections for soil and water. A clear case can be found in Oregon. The Oregon Forest
Practice Rules addressing water quality on private and state-owned lands are in striking contrast
to those laws protecting water quality in the adjacent states of California and Washington and on
federal lands in Oregon. For example, the states of Washington and California require
substantial buffers on perennial streams and Oregon requires no buffers for many of these
streams and only a minimal buffer on others. The state of Oregon never meaningfully improved
its forestry rules to protect salmon, despite recognition by the federal agencies and independent
scientists that the existing rules were partly responsible for the degradation of salmon habitat and
populations. And yet SFI certifies environmentally-harmful industrial forestry all across the state
of Oregon because it meets the letter of the law.

The case in Oregon is echoed across North America. Even in California, where the regulations
addressing forestry on private lands are commonly accepted as the most stringent in the nation,
there are regular criticisms, even from the California Department of Forestry, that the state
regulations are inadequate to serve their stated purpose of protecting habitats from the adverse
effects of timber operations.

FSC, on the other hand, starts with adherence to all BMPs, but then further specifies protection
for water resources in areas where state BMPs are not sufficient to protect the environmental and
social values of forests (Criterion 6.5). FSC standards also include additional water quality
protection measures such as water crossings, recreation, grazing, and streamside management
zone (SMZ) buffer guidelines.




12
     Pace, F., Klamath Forest Alliance, Etna, CA, personal communication, June 2003.
13
     Pace, F., Klamath Forest Alliance, Etna, CA, personal communication, Jan. 2002.


                                                                                                    15
Indigenous peoples’ rights
SFI/Weyerhaeuser arguments:

―Indigenous peoples‘ rights in the U.S. are protected by mature justice systems that have proven
responsive to resolving indigenous peoples‘ claims.‖ (Weyerhaeuser)

―The SFI program was developed to meet the needs of communities and land managers in North
America… A core principle requires that participants comply with all applicable laws –
including those related to…the rights of Aboriginal peoples…‖ (SFI)

ENGO response:

Unlike FSC, SFI does not require consultation with tribal representatives in developing and
implementing forestry plans or robust public consultation by the certifiers during the audit
process. The SFI standards also lack opportunities for public participation in the forest
management planning process, explicit conformance with the principal of Free, Prior Informed
Consent,14 and independent peer review of certification reports to ensure compliance with SFI
standards and the best scientific information available.

FSC standards require tribal and public participation in multiple parts of the standard (e.g. see
criteria 2.2, 4.4, and 9.2 and all of Principle 3). Additionally, forest managers must use the
information they gather to adjust management activities and goals. This second step is key in
giving a real voice to indigenous peoples and the public on both private and public lands.

In this and other contexts, SFI argues that only forests in North America can be certified to the
SFI Standard, and that in the U.S. and Canada strong laws and enforcement exist to adequately
protect the rights of indigenous peoples as well as those of workers and locally communities.
They argue specifically that SFI adequately addresses the rights of North American indigenous
peoples -- as well as those of workers and communities -- in the following sections of the SFI
Standard:

                    o Performance Measure 14.2.: Program Participants shall take appropriate
                      steps to comply with all applicable social laws at the federal, provincial, state,
                      and local levels in the country in which the Program Participant operates.

                    o Objective 6: Protection of Special Sites. To manage lands that are
                      ecologically, geologically or culturally important in a manner that takes into
                      account their unique qualities.

                    o PM 18.2: Program Participants with forest management responsibilities on
                      public lands shall confer with affected indigenous peoples (emphases added)


14
     United Nations Declaration on the Rights of Indigenous Peoples (2008).


                                                                                                     16
Here as elsewhere, the SFI standard is too weak to ensure adequate protection of indigenous
rights. For example, SFI requires that its Program Participants ―confer with affected indigenous
peoples,‖ but there is no requirement in the SFI standard to do anything in particular with the
information gathered after so conferring. Without a statement requiring use of the information
gathered to form or revise management plans, a certificate holder cannot be held accountable for
protecting community and indigenous values.

This is insufficient for adequate protection of the rights of indigenous peoples because it doesn‘t
require management that‘s consistent with the wishes of the affected peoples, and considerable
SFI certified forestry occurs on private lands. Conformance with the principal of Free, Prior
Informed Consent15 is a much stronger standard for protecting such rights, and is required by the
FSC (Criterion 3.1).

The FSC standards require not only efforts to consult with indigenous peoples on public lands,
but with all local communities and on all properties. SFI‘s requirement to confer with
indigenous peoples on public lands is a very limited scope of application on which to base the
claims that they make.

A central part of FSC certification is dedicated to ensuring that ―the legal and customary rights of
indigenous peoples to own, use and manage their lands, territories, and resources shall be
recognized and respected‖ (Principle 3). Additional principles and criteria place strong
requirements on community benefit and managing for social impacts. Recognition of indigenous
rights on private and public lands is not a given in North America. Contention between tribal
rights and forest management occurs every year in both the U.S. and Canada.

In addition, FSC certification requires a social impact assessment (in conjunction with an
assessment of environmental impacts) to ensure that forest managers and owners are proactive in
understanding the effects of their operations on local communities and requires that information
to be used in adaptive management. Only in cases where local communities are given a chance
to participate in forest management and the information collected in these consultations is used
to shape management can one claim protection of community values.

FSC and SFI auditing, enforcement and accountability
SFI arguments:

―FSC often chooses strong language, but then fails to enforce the requirements…SFI avoids huge
gaps between standards requirements and audit performance that are often the case with FSC. A
quick review of nine FSC audit reports…consistently showed non-conformances…‖




15
     United Nations Declaration on the Rights of Indigenous Peoples (2008).


                                                                                                 17
ENGO response:

It is easy to avoid ―huge gaps between standards requirements and audit performance‖ if
standards are weak, ambiguous, and low, as is the case with SFI. This said, SFI‘s statements
about FSC in this regard are simply misleading.

FSC deals with non-conformances through two types of Corrective Action Requests (CARs).
Major CARs are issued by auditors for substantial non-conformance with the relevant FSC
standard. In the case of initial (evaluation) audits, Major CARs must be resolved before a Forest
Management certificate will be issued. In the case of ongoing (surveillance) audits, Major CARs
must be resolved by a deadline (often within 90 days of the date of the audit report) or the
certificate will be suspended. Minor CARs are issued by auditors for minor isolated and non-
systemic non-conformances with the relevant FSC standard, and these must be resolved by the
time of the next annual audit or they will be elevated to Major CARs. An example of a minor
CAR would be observance of a single stand out of twenty inspected that doesn‘t meet habitat
retention requirements. A major CAR would result if there were systematic failure of
conformance to that requirement.

The number of non-conformances presented by auditors is certainly not indicative of a lack of
rigor in a program – in fact, the contrary will tend to be true, as suggested in a recent academic
study.16 All CARs must be addressed within the allotted time period and can be viewed as
leading to improvements in forest management.

Furthermore, it is truly ironic that SFI would criticize FSC and its certifiers on the basis of
enforcement failures and a gap between what‘s written on paper and what happens on the
ground. Two examples amply illustrate this point:

EXAMPLE 1: Weyerhaeuser logging of occupied spotted owl habitat in SW Washington

Weyerhaeuser (which is SFI-certified on all of its North American lands) has several endangered
spotted owls in its forests in SW Washington. Starting in 1999, Weyerhaeuser began clear-
cutting the suitable owl habitat within four of its spotted owl ―circles‖ (5-mile diameter circles
around owl nest sites designating their essential habitat). Representing the Seattle Audubon
Society, the Washington Forest Law Center went to federal court and got a judge to issue an
injunction against Weyerhaeuser‘s logging. The court found that Weyerhaeuser was in fact
logging this habitat and that the logging posed a risk of harm to the owls. The case was
eventually settled out of court. Bottom line: SFI-certified Weyerhaeuser was found to be likely
to violate the ESA in June of 2007.

Eleven months later, Weyerhaeuser underwent its SFI audit with its auditor, QMI. The audit
report said NOTHING about the logging of spotted owl habitat, the court injunction, or anything
relating to it. In fact, the audit report (pg. 3) says, ―No instances of non-conformance were found
in this audit.‖

16
 Masters, M.; Tikina, A.; and Larson, B. ―Forest Certification Audit Results as Potential Changes in Forest
Management in Canada‖ The Forestry Chronicle, July/Aug. 2010


                                                                                                              18
The Washington Forest Law Center had also filed a complaint against Weyerhaeuser under SFI
to daylight the clear violation of the SFI standards. The complaint was never pursued by SFI, and
Weyerhaeuser required that it be dropped in the out-of-court settlement of Seattle Audubon‘s
lawsuit. Weyerhaeuser is still not protecting spotted owls on many of its forests.

EXAMPLE 2: Weyerhaeuser‘s logging of steep and unstable slopes

Weyerhaeuser owns almost 1 million acres of forest in SW Washington. Over the past 10 years,
Weyerhaeuser has logged these lands aggressively, including logging all of the trees off of slopes
that have gradients as high as 50 degrees. Weyerhaeuser conducted this logging under a 15-year-
old ―watershed analysis,‖ an exception to the state forest practice rules that allows a landowner
to avoid the standard rules in exchange for ―prescriptions‖ of the analysis.

In December 2007, a major storm hit SW Washington. The storm packed record rainfall. As a
result of Weyerhaeuser‘s irresponsible logging of steep and unstable slopes, major landslides
occurred, which led to huge log jams and downstream flooding. The catastrophe was recorded in
a major series by the Seattle Times.17 On behalf of the Sierra Club, the Washington Forest Law
Center hired an expert geologic consulting firm (Entrix) which concluded that Weyerhaeuser‘s
steep slope logging exacerbated the downstream flooding and log jam damage.18

Weyerhaeuser‘s auditor, QMI, conducted its annual SFI audit in July of 2008, seven months after
the landslides and floods. The audit report was silent about any of the landslides and the damage
they wreaked.

On October 1, 2009, the Washington Forest Law Center filed an SFI non-conformance complaint
against Weyerhaeuser on behalf of Sierra Club.19

On October 30, 2009, QMI wrote a letter back stating that ―it may take up to 6 months before we
are in a position to respond fully.‖ In November 2009, Weyerhaeuser itself responded in writing
to the complaint, claiming that they did not violate SFI standards. Under SFI‘s system, QMI
remains responsible for resolving the non-conformance complaint, but has not yet done so.

In December 2009, the Washington Forest Law Center wrote a letter to QMI, Weyerhaeuser and
SFI demanding that Weyerhaeuser be directed to share critical data and other information it
relied upon in its response to the original complaint. In an e-mail dated January 4, 2010,
Weyerhaeuser responded to this letter, stating ―It is the certification body that is charged with the
duty of investigation and disposition of the Complaint and the Response.‖ Weyerhaeuser also
implied that it was not required to provide the documentation that it relied upon for its response
to the complaint.

In June 2010, the Washington Forest Law Center sent a follow-up letter to QMI indicating that
seven months had passed since their last letter, but nothing had been received from QMI.

17
   http://seattletimes.nwsource.com/flatpages/local/landslides.html
18
   http://wflc.org/sitefiles/Credforestcertification/EntrixReport/download
19
   http://seattletimes.nwsource.com/html/localnews/2011140187_forestcetification21m.html


                                                                                                  19
Weyerhaeuser‘s communications were also related to QMI in this letter, and a written update
was requested. As of October 2010, there still has been no response from QMI, even though it
has been almost 12 months since QMI wrote ―it may take up to 6 months‖ for QMI to respond.

In the report for Weyerhaeuser‘s most recent surveillance audit (July 2010), QMI made no
reference to logging on steep and unstable slopes.

These two examples clearly illustrate deficiencies in SFI‘s auditing, enforcement and
accountability of their already weak standards.

“…free” or “free of” claims, chain of custody, non-certified inputs
into certified products, and labeling
Weyerhaeuser arguments:

―[Mr. Grant‘s] suggested approach claims FSC-certified products are entirely or largely ‗free of‘
wood coming from certain practices, and SFI-certified products contain wood from these
practices…‖

Weyerhaeuser suggests that FSC‘s Controlled Wood standard and widespread use of the
―volume credit‖ method by FSC-certified companies allows the inclusion into FSC-Certified
(Mixed) products of wood from all of the controversial sources to which the ENGOs objected in
our letter to BIFMA.

ENGO response:

In our letter, we wrote the following:

The Sustainable Forestry Initiative, the Canadian Standards Association’s Sustainable Forest
Management certification, and other industry-based forest certification programs certify as
“sustainable” forest practices that are the most environmentally damaging allowed by law –
which can include the logging of the rare old-growth forest in the U.S., logging of threatened
and endangered species’ habitats, destruction of other high conservation values, conversion of
natural forests to plantations, conversion of forests to non-forest uses, management for only a
few native species, use of silvicultural regimes that miss opportunities to reduce chemical inputs,
short-rotation logging that harms soil and water quality, and violation of indigenous peoples’
rights, amongst others. In contrast, the Forest Stewardship Council (FSC) is the most credible
and rigorous forest certification program in existence and strictly prohibits or limits the harmful
practices listed above. (emphasis added)

We did not state that FSC products are ―free of‖ wood from all of the forest practices that we
find objectionable – rather, we state that SFI, CSA, etc. actively certify these practices as
―sustainable.‖




                                                                                                 20
In light of Weyerhaeuser‘s comments, we would like to amend the final sentence in the
paragraph above to read as follows:

In contrast, the Forest Stewardship Council (FSC) is the most credible and rigorous forest
certification program in existence and its forest management standards strictly prohibit or limit
the harmful practices listed above.

Aside from this correction, and for all of the reasons articulated above and below, we stand
behind our arguments.

The most crucial differences between FSC and SFI hinge on the forest management practices
that are certifiable under each of the programs. The entire point of forest certification is to codify
acceptable practices in forest management and to create a market mechanism that rewards those
practices, encouraging their growth over time.

Weyerhaeuser is correct in pointing out that both SFI and FSC have come to rely on chain-of-
custody and production systems that mix certified and non-certified inputs. The forest
management standards in each system govern only the certified content in such ―mixed‖
products.

Weyerhaeuser is also correct in stating that the FSC Controlled Wood standard – the standard
that governs acceptable non-certified virgin fiber inputs into FSC Mixed products – takes a risk
management approach to avoiding fiber from controversial sources (defined below), and that a
majority of working forests in North America are currently designated ―low risk‖ for these
factors.

It is important to note that many ENGOS do not agree with this blanket assessment, are critical
of FSC Controlled Wood as it currently functions, and are committed to pushing the system to
improve over time. This said, a majority of members of FSC’s environmental chamber appear to
have accepted Controlled Wood as a “necessary evil” that allows FSC certification to function
and grow in a way that drives actual improvements in forest management.

It is no doubt true that a portion of the North American wood that is covered by FSC Controlled
Wood risk assessments and certificates in fact originates from SFI-certified forests and
plantations, including in some cases the very operations and practices of which we are most
critical. If we knew of a way to address and remedy this flaw in the FSC system, rest assured that
we would do so. However, we are always told that it is impossible to differentiate wood from the
worst practices and operations from those that are less controversial, and that until a practical
mechanism exists to identify and segregate such wood, we will have to live with the current,
highly imperfect system.

The central point is that, under the volume credit system, FSC Controlled Wood attempts to keep
wood from ―the worst‖ sources from being used in FSC Mixed products while always requiring
that a volume of wood that corresponds to the volume of products sold as FSC Mixed Credit in
fact derives from forests and plantations that are certified to FSC standards. Thus, the more




                                                                                                    21
products that are produced using this method and sold as FSC Mixed Credit, the more forests
will be brought under FSC-certified management.

By contrast, SFI certifies as sustainable the very practices and products that Controlled Wood
deems not ―the worst.‖ Where FSC certification, Controlled Wood, and FSC Mixed products are
all part of a strategy to improve forest management practices beyond the status quo, SFI aims to
certify the status quo and market its products as ―green.‖

There are other critical differences between FSC and SFI with respect to non-certified inputs and
labeling. SFI and FSC each attempt to screen out wood from unacceptable sources. Under SFI,
the ―screen‖ – the rough equivalent of FSC‘s Controlled Wood Standard – is their Responsible
Fiber Sourcing Standard.

There are two important points to be made in regard to this Standard and related labeling:

1) SFI allows and encourages the marketing of products that come 100% from merely ―screened‖
sources while FSC does not. In fact, the SFI Fiber Sourcing Label was specifically created for
the purpose of promoting products that contain no SFI-certified content; instead, they come
purely from sources that may not be independently audited to any standard, but use a systems or
risk-assessment based approach to ―ensure‖ that they do not represent the ―worst of the worst.‖
The SFI Fiber Sourcing Label bears a very close visual resemblance to other SFI labels, and its
true meaning is opaque to all but forest certification insiders.

By contrast, FSC does not have a Controlled Wood label, nor does it allow the sale or promotion
of Controlled Wood as such outside of the community of FSC-certified companies. In the FSC
system, Controlled Wood can only be bought and sold in business-to-business transaction for
incorporation into ―Mixed‖ products. FSC does not allow the sale or promotion of Controlled
Wood to the public precisely because FSC stakeholders believe that it is unacceptable to market
wood products as ―responsible‖ if they are not in some way tied to high social and environmental
standards, but instead represent only the attempted avoidance of the worst sources.

2) For all its weaknesses, the ―screen‖ established by FSC Controlled Wood is far more
comprehensive and stringent than that established by SFI Fiber Sourcing. FSC Controlled Wood
explicitly prohibits wood or fiber from five controversial sources:

   a) wood from forest areas where traditional or civil rights are violated
   b) wood from forest areas where high conservation values are threatened by management
      activities
   c) wood from forests in which genetically modified trees are planted
   d) wood that has been harvested illegally
   e) wood harvested from areas which have been converted from natural forest to plantations
      or non-forest uses at a significant scale

By contrast, SFI‘s Responsible Fiber Sourcing Objectives only address one of the five
controversial sources listed above: illegal logging.




                                                                                               22
SFI‘s chain of custody and labeling rules allow non-certified content sourced from foreign
countries, including those with high corruption and poor enforcement records, to enter SFI
labeled products. Up to 100% of the content of a product that bears the SFI Fiber Sourcing label
can come from forests that are not annually audited and certified, even to SFI‘s low standards.
Instead, the content is deemed acceptable by SFI if it flows through a ―certified procurement
system.‖ This means that the only thing that actually gets audited is a ―system‖ for sourcing raw
materials that may be sourced globally through complex supply chains — the supply chains
themselves do not have to be audited, which in turn means that the ultimate forest sources for the
raw material are unmonitored.

Absent an audited chain of custody — and given the complexity of global supply chains coupled
with the fact that materials from multiple sources are typically mixed in manufacturing and
distribution prior to import into the U.S. — there is an extremely high likelihood that the actual
forest source for uncertified raw materials sourced from overseas will be unknown and
unknowable.

Now let‘s take a closer look at what an SFI certified procurement system actually requires.
According to the SFI Chain of Custody Standard, the organization that will use the SFI fiber
sourcing label shall:

“3.6.1.1 Require a signed self-declaration that the supplied raw material does not originate
from controversial sources….

“3.6.1.2 Evaluate the potential risk of procuring raw material from controversial sources and
establish a program to check a sample of self-declarations by suppliers, using second- or third-
party verification…” (emphases added)

In short, to ensure ―responsible sourcing‖ from the 90% of the world‘s forests that are not
certified to any standard — and which may well be located in developing countries where
corruption is endemic, environmentally-destructive logging is typically legal, and illegal logging
widespread — SFI relies on a system of mere self-declarations and risk assessments performed
by SFI-certified companies themselves and their immediate trading partners. Considering how
easily illegal and controversial wood can be laundered through global trade, such a system is
utterly inadequate — particularly as the basis for a so-called ―green label.‖

For all of these reasons, wood and fiber from many types of illegal logging and violations of
indigenous peoples‘ tenure rights can enter into SFI labeled products. SFI does not require
independent verification of forest managers‘ compliance with most national and local laws for
the imported fiber that enters SFI products, nor do these systems require compliance with
international treaties and accords, including treaties with indigenous peoples.

Last but not least, the SFI Certified Chain of Custody label can be used on products that contain
as little as 1% certified content. The threshold for use of the FSC Mixed label with products
made using the percentage system is 70% certified content.




                                                                                                23

				
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