Central Point of Expertise on Timber
UK Government Timber Procurement Policy
Comments and responses on Category A criteria
June 2006
1
Table of Contents
1. Forest Standards¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­¡­ 3 1.1. Content of standards for legal compliance ........................................................................................................................................ 3 1.2. Content of standards for sustainable variant ................................................................................................................................... 13 1.3. Standard-setting process ................................................................................................................................................................ 40 2. 3. 4. Certification.......................................................................................................................................................................................... 75 Accreditation ........................................................................................................................................................................................ 86 Chain of custody................................................................................................................................................................................... 90
The following is a compilation of all comments received as part of the public call for comments on the Category A criteria and guidance document. The comment period ran from 13th February until March 18th, 2006. A summary of comments and the CPET response was discussed with the CPET Reference Board, and many comments were taken in to account in the final version of the Category A criteria and guidance document. All comments are un-attributed.
2
1. Forest Standards
1.1. Content of standards for legal compliance
Criteria 1.1.1 The standard requires that the forest owner/manager holds legal use rights to the forest Guidance on implementation If schemes are only applicable to countries where legal use rights are clear then an explicit requirement for legal compliance is sufficient for a score of 1 even if legal use rights are not explicitly addressed. However, if the scheme can be applied in countries where legal use rights are not clear, there must be an explicit requirement. Comments on 1.1.1 Legal use rights are noted in 1.1.1 and it seems that this requirement is best suited in that section. To request "tenure and use rights" also in 1.1.2 seems to imply that you are looking for something different there, and yet presumably a contractor will be working on the land of the forest owner/manager (already covered in 1.1.1) and therefore it is unclear how this is different. Also it should be made clear that provided there are legal rights to use the land, this is sufficient. Use rights seems to imply perhaps something different from legal rights, and I would think it would be hard for the UK government to get into the arena of arbitrating whether use rights are indeed upheld. Legality is hard enough to secure assurances around, never mind use rights, which could be interpreted as social rights, not legal rights. The criterion appears unambiguous: in order to meet the criterion the standard must contain an explicit statement that the forest owner/manager must holds legal use rights to the forest. The only possible ambiguity is over who may be considered to be the forest owner/manager; presumably the certification applicant (or applicants in the case of group certification 2 Forest owner/ manager means certification applicant. Guidance on interpretation provides explanation on scoring: If schemes are 1 Criterion 1.1.2 has been amended to state "other parties' tenure and use rights." Commentator CPET responses

ÏÂÒ»Ò³