FAQ: Timber from Russia and Belarus considered ‘conflict timber’

Following the announcement that all timber originating from Russia and Belarus is ‘conflict timber’, we have received several questions and requests for further clarification. 

You can find answers to all questions we have been asked on this page. We will continue to update this page as we receive more questions. If you have a question that is not answered on this page, please contact us at conflict-timber@pefc.org.

Modifications:

• 8 April 2022: Moved General Questions 3) to Implementation Questions ("Is timber originating from the Ukraine considered 'conflict timber'?")
• 8 April 2022: Added Implementation Questions 14) and 15) and General Questions 6)

Implementation questions

1. When does the clarification take effect?
   The clarification is effective as of the date and time the results of the vote of the UN General Assembly Resolution A/ES-11/L.1 (2 March 2022) "Aggression against Ukraine" during the 11th Emergency Special Session 2 March 2022, 11:55 am EST.
2. How do companies implement this clarification in practice?
   Material originating in Russia and Belarus for which a PEFC DDS was applied after 2 March 2022, 11:55 am EST is considered conflict timber, therefore controversial, and cannot be used in the PEFC chain of custody, neither as PEFC certified nor as PEFC controlled sources.
3. What about timber originating from Russia and Belarus before 2 March 2022?
   Material originating in Russia and Belarus for which a PEFC DDS was applied before this 2 March 2022 11:55 EST and for which the DDS resulted in negligible risk can be used and be placed on the market.
   Examples:
   • Timber originating from Russia or Belarus for which a DDS was applied before the deadline and is transported from the forest to a sawmill after the deadline can be used with a PEFC claim.
   • Timber originating from Russia or Belarus which is already in storage, potentially even outside of the two countries, but no PEFC DDS has been applied, is considered as ‘conflict timber’ and cannot be used.
4. Does ‘conflict timber’ only apply to timber or also to other forest-based products? 
   The categorisation applies to all forest and tree-based material and products. For ease of reading, this document refers to ‘timber’, but this shall be understood as ‘forest and tree-based products’.
5. Does the clarification only apply to timber originating from PEFC-certified forests in Russia and Belarus? What about timber originating from uncertified forests or timber certified by other forest certification systems?
   The clarification applies to all timber originating from Russia and Belarus (PEFC certified forests, forests certified by other certification systems, and uncertified forests).
6. Does the clarification apply to PEFC-certified material as well as to PEFC controlled sources?
   The clarification applies to any material entering a PEFC chain of custody and therefore includes both PEFC-certified material as well as controlled sources.
7. Are all deliveries received before 2 March 2022 automatically considered as NO conflict timber?
   No. Only deliveries for which the DDS was applied and resulted in negligible risk before the 2nd March 2022 are considered ‘no conflict timber’.
8. Company A buys material originating from a Russian/Belarussian forest and conducts DDS on the 1st March. It sells the material to Company B, which conducts the DDS on the 5th of April? How does the clarification apply in this scenario?
   • If company A applied the DDS before the 2 March 2022 resulting in negligible risk, the clarification does not apply.
   • Although company B conducts the DDS after 2 March 2022, the clarification does not apply to Company B if a first DDS was conducted to the material by company A before 2 March 2022 and resulted in negligible risk.
9. Is it possible to use PEFC credits accumulated through material originating from forests in Russia or Belarus for producing new PEFC products if the DDS was applied before 2 March 2022?
   Yes. PEFC credits from material for which a PEFC DDS was applied before 2 March 2022 and the DDS resulted in negligible risk can still be used.
10. Can already produced and PEFC labelled products still be sold? 
    According to PEFC Chain of custody requirements, before labelling a product, companies shall conduct due diligence to make sure that any material included in the labelled product does not come from controversial sources. PEFC labelled products to which due diligence was implemented and resulted in negligible risk before the 2nd March 2022, can still be sold.
11. Does the clarification apply to both PEFC Chain of Custody ST 2002:2020 and PEFC Chain of Custody ST 2002:2013?
    Yes. The clarification applies to companies certified to apply to either PEFC Chain of Custody ST 2002:2020 and PEFC Chain of Custody ST 2002:2013.
12. If Russian companies source timber from Russia for internal market purposes, does the conflict timber clarification apply?
    Yes, the conflict timber clarification applies. Material originating from forests in Russia and Belarus is considered conflict timber and cannot be placed on the market under a PEFC claim nor can it enter the PEFC chain of custody, regardless of whether it is to be exported or used within Russia or Belarus.
13. Is timber originating from the Ukraine considered 'conflict timber'?
    Based on the Resolution on Aggression against Ukraine by the United Nations General Assembly, timber originating from territories controlled by the elected Ukrainian government is not included in the clarification by PEFC. Timber from the territories controlled by the elected Ukrainian government for which a PEFC DDS was applied and the DDS resulted in negligible risk can be used and be placed on the market.
    Timber originating from occupied Ukrainian territory is considered ‘conflict timber.
14. How shall PEFC certified companies implement the clarification? 
    The clarification from the PEFC Board, as well as the UN General Assembly Resolution A/ES-11/L.1 (2 March 2022) "Aggression against Ukraine" during the 11th Emergency Special Session are to be considered substantiated concerns.
    Companies implementing PEFC ST 2002:2020 are required to identify supplies originating from Russia and Belarus as having “significant risk” to ensure that they can determine when the DDS was applied. If the DDS for material originating from Russia and Belarus was applied after 2 March 2022, concerns cannot be resolved and it needs to be managed in accordance with PEFC ST 2002:2020 Appendix 1 clause 4 and 5.
    Companies implementing PEFC ST 2002:2013 for which the DDS was applied after 2 March 2022, clause 5.3.7 applies.
15. What evidence can be accepted from the suppliers on when the DDS was conducted? 
    Signed declaration from the PEFC certified supplier where the supplier declares having conducted the DDS prior to the 2^nd of March 2022, together with documentation demonstrating the DDS conduction from the supplier’s chain of custody management system that provides sufficient evidence for the customer to classify the supply as having negligible risk

General questions

1. What is PEFC’s response to the aggression against Ukraine?
   All timber originating from Russia and Belarus is ‘conflict timber’ and therefore cannot be used in PEFC-certified products. This also applies to all timber originating from occupied Ukrainian territory. PEFC continues to monitor the situation and will consider additional measures as necessary.
2. What is the rationale behind PEFC’s clarification concerning timber from Russia and Belarus?
   The clarification that timber from Russia and Belarus is to be categorised as ‘conflict timber’ is based on the UN General Assembly Resolution A/ES-11/L.1 (2 March 2022) "Aggression against Ukraine" during the 11th Emergency Special Session, to safeguard the integrity of PEFC chain of custody certification.
   It follows requests by stakeholders for PEFC to provide clarification for the marketplace and was undertaken in close consultation with PEFC members.
3. How does PEFC define conflict timber?
   PEFC defines conflict timber in its regulatory framework in PEFC ST 2002 as ‘“Timber that has been traded at some point in the chain of custody by armed groups, be they rebel factions or regular soldiers, or by a civilian administration involved in armed conflict or its representatives, either to perpetuate conflict or take advantage of conflict situations for personal gain. (...) Conflict timber is not necessarily illegal.” The exploitation of timber may itself be a direct cause of conflict.
4. How will PEFC consider future resolutions by the UN General Assembly?
   PEFC will provide consistent clarification for future resolutions adopted by United Nations General Assembly emergency sessions.
5. How is PEFC supporting its affected colleagues in Ukraine?
   PEFC is in ongoing contact with our colleagues at PEFC Ukraine and we are glad to report that they are safe for now. We have offered and are prepared to provide them with any support and assistance needed in this unprecedented situation.
6. What is the difference between the approaches that PEFC/FSC has taken with regards to Russia, Belarus, Ukraine?
   In practice it means the same i.e. no FSC/PEFC material from Russia and Belarus is available on the global market, similarly to material coming from invaded/occupied areas of Ukraine. To achieve that result, PEFC has clarified that material originating from Russia, Belarus and occupied areas of Ukraine is considered ‘conflict timber’ and therefore cannot be used in the PEFC chain of custody, neither as PEFC certified nor as PEFC controlled sources, while FSC has suspended certificates in Russia and in the invaded areas of Ukraine and terminated the certificates in Belarus.

Questions about PEFC-certified areas and companies in Russia and Belarus

1. How large is the PEFC-certified forest area in Russia and Belarus?
   As of 31 December 2021, 31,976,108 hectares of forest in Russia and 9,022,400 hectares of forest in Belarus were PEFC certified. This corresponds to 12.5% of the total global PEFC-certified area of 328,464,110 hectares.
2. How many companies are PEFC certified in Russia and Belarus?
   As of 31 December 2021, 104 companies in Russia and 110 companies in Belarus were PEFC chain of custody certified. This corresponds to 1.7% of all 12,671 PEFC chain of custody certified companies globally