A team of experts from the NGO Forest Initiatives and Society conducted a study of risks in the Ukrainian forest sector that may affect the assessment of the legality of the origin of wood and products made from it, and prepared a draft national risk assessment of controlled wood.
The experts described their methodologies and developments in detail on the website of their NGO.
Scientists and experts analyzed the existing risks, taking into account the requirements of the updated FSC (Forest Stewardship Council) risk assessment system and European Union legislation.
How the assessment was conducted
During their work, experts analyzed the presence and significance of risks in the forest sector of Ukraine and ways to reduce them using 64 indicators grouped into 12 categories.
This procedure involves analyzing a wide range of forestry aspects, including:
- land use;
- taxes;
- corruption;
- environmental protection;
- rights of workers and local communities;
- trade and transportation of wood, etc.
Each of the 64 indicators was evaluated by experts according to 4 types of sources of origin of wood in Ukraine:
- Territories under the control of the government of Ukraine (with the exception of radioactively contaminated forests and territories contaminated with explosive objects).
- Forests exposed to radioactive contamination as a result of the Chernobyl disaster.
- Territories in the combat zone or contaminated by explosive objects (in particular, a 20-kilometer strip from the contact line, the borders with the Russian Federation and Belarus, as well as areas that have been reported to have been mined).
- Temporarily occupied territories where it is impossible to guarantee compliance with the laws of Ukraine and international law.
What was discovered
Specialists noted positive changes in certain indicators, in particular regarding:
- supply chain traceability;
- prevention of corruption;
- forest management;
- labor protection, etc.
However, they identified 32 indicators with significant risks in government-controlled areas and all applicable 64 indicators with significant risks in occupied territories, as well as specific risks for radioactively contaminated and mined forests.
You can familiarize yourself with a detailed description of these risks in the prepared draft document " Draft national risk assessment of controlled wood for Ukraine (V 2 Draft 2-0) It is currently under public discussion, which will end on January 30, 2025.
Potential risks have been identified
Among the potential significant risks, the experts of LIiS, in particular, singled out the following:
- Illegal extraction of forests with a change in the form of ownership and purpose – a risk is possible for types of sources of origin of wood 1, 2, 3.
- Illegal transfer of forestry land plots from state (or communal) forestry enterprises to other legal entities or individuals – this risk is possible for types of sources of origin 1, 2, 3.
- Illegal logging is possible for source type 1.
- Harvesting wood in areas with a high level of radiation contamination without radiation control is possible for source type 2.
- Harvesting wood in areas contaminated with explosive objects until confirmation of the absence of a threat is possible for source type 3.
- Non-implementation of measures planned by forest management or implementation of unauthorized measures without appropriate justification is possible for source types 1, 2.
- Underestimation of value added tax, corporate taxes and income tax due to illegal sale of wood or underestimation of its category, grade or volume is possible for source types 1, 2.
- A high level of perception of corruption in the forest sector due to insufficient enforcement of anti-corruption legislation is possible for source types 1, 2, 3.
- Corruption and bribery in the forestry sector is possible for source types 1, 2, 3.
- Falsification of data and documents, in particular during the designation of sanitary and other types of felling for the purpose of commercial logging, is possible for source types 1, 2, 3.
- Illegal construction of forestry land and insufficient assessment of ecological consequences during the construction of a forest transport network and the construction of industrial facilities in forest territories is possible for source types 1, 2.
- Development and maintenance of infrastructure in forests is carried out without taking into account the need to reduce the negative impact on ecological values - possible for source types 1, 2, 3.
- Failure to fully comply with the legislation regarding the preservation of biodiversity and the protection of endemic, rare, endangered or endangered species and their habitats, in particular, there are problems in the allocation and legal processing of documents regarding the protective status of virgin forests, quasi-virgin forests and natural forests – possible for types sources 1, 2.
- Non-compliance with the requirements of the law on the preservation of biodiversity and the protection of endangered species and their habitats, in particular due to ongoing hostilities and contamination of the territory with explosive objects, is possible for source type 3.
- Violation of water resources protection rules: trawling through watercourses, unorganized river crossings, illegal mining of minerals (peat, amber), etc. – possible for source types 1, 2.
- Soil degradation in mountainous areas as a result of dredging along the slopes, continuous felling on low-strength soils, use of heavy tracked machinery during dredging, intensive logging in individual watersheds, etc. is possible for source type 1.
- Transportation of wood by road transport without proper accompanying documents, as well as the risk of selling wood outside the stock exchange is possible for source types 1, 2.
- Probability of conversion of natural forests to agricultural land (deforestation), which requires careful monitoring in accordance with the precautionary principle and EUDR requirements – possible for source types 1, 2, 3.
- Probability of transfer of forest fund lands to other types of land use, except for agriculture, due to weak law enforcement is possible for source types 1, 2, 3.
A detailed description of the identified risks can be found in the "Risk Assessment" section of the Project at the link above.
Earlier, EcoPolitic reported that the deputies started again for draft law No. 4197-d "On the wood market", which has been gathering dust for 3 years.
