In denial: FSC’s response to the ARTE documentary

Two weeks ago, ARTE broadcast a documentary that was extremely critical of FSC. FSC responded with a statement on its website, and an 8-page “Fact check”. FSC’s response illustrates that the organisation is in denial about the problems within the FSC system.

The ARTE journalists, Manfred Ladwig and Thomas Reutter, travelled to the Republic of Congo, Cambodia, Vietnam, Peru, Brazil, Sweden, and Russia. They spoke to local communities whose livelihoods have been impacted by FSC certified logging and plantation operations.

They also interviewed Kim Carstensen, FSC’s director general. The documentary includes his responses to each of the cases the journalists looked into.

But FSC’s statement does not take the findings of the documentary seriously. FSC starts by stating that, “The Forest Stewardship Council (FSC) disputes the allegations made about our work in Arte documentary.”

FSC continues:

While we acknowledge that our work will always need improvement in some areas and have publicly owned up to such areas in the past, we oppose the presentation of a relationship between our organization and various controversial activities. Many of these allegations did not take into account contrasted research and reflect a distortion of isolated or unrelated incidents with no regard for context.

This shows a callous disregard for the impact that FSC certified logging operations are having on the livelihoods of local communities and indigenous peoples. For example, ARTE’s documentary clearly shows these impacts in the forests of the Republic of Congo. FSC just refers to its process of free, prior and informed consent, as if that makes any problems disappear.

FSC’s “Fact check” document lists nine “allegations” made in the documentary and responds to each one in turn. In the following the “allegations” are bold, followed by FSC-Watch’s critique of FSC’s response:

1. In the Congo Basin, FSC-certified concessions are either responsible for, or not taking action to reduce the suffering of Indigenous Peoples living around the forests.

FSC says it will “investigate these accusations thoroughly”, but then states that “we have grounds to question the validity of these claims”. But a serious investigation has to start from the premise that the findings of documentary at least could be valid.

Of course, the investigation may find that the findings are not valid, but questioning the validity of the findings before even starting an investigation shows a shocking level of bias.

Ladwig and Reutter visited two concessions in the Republic of Congo: Congolaise Industrielle des Bois (CIB), and Industrie Forestière de Ouesso (IFO).

FSC’s response doesn’t mention either of these companies, or the country they are operating in.

FSC refers to six papers and reports in its attempt to dismiss the ARTE documentary’s findings in the Republic of Congo.

The first reference is titled, “The contribution of NTFP-gathering to rural people’s livelihoods around two timber concessions in Gabon”. ARTE’s journalists did not visit Gabon. The paper mentions FSC only once.

The second reference is titled, “Social impacts of the Forest Stewardship Council certification in the Congo basin”. It was published in 2017 in the International Forestry Review.

The researchers compared nine FSC certified logging concessions and nine non-certified concessions, in Cameroon, Gabon and the Republic of Congo.

The researchers found that workers in FSC certified concessions had better working and living conditions. They also found improvements in “the effectiveness and legitimacy of the institutions and benefit-sharing mechanisms set up to regulate relationships between logging companies and neighbouring communities” in FSC certified concessions.

However, FSC certified operations tended to enforce the law more strictly, which had an impact on local populations’ customary uses of the forests. The paper states that,

Challenges remain, however, especially in relation to customary uses. Paradoxically, findings indicate that social peace may more easily be maintained — and negative impacts on customary uses may be limited — in noncertified FMU [forest management unit], managed or not, than in certified ones, because of the ‘nonintervention’ of logging companies in those areas.

Which supports Ladwig and Reutter’s findings in the ARTE documentary.

The third reference is a 2016 Food and Agriculture Organisation working paper: “The contemporary forest concessions in West and Central Africa: chronicle of a foretold decline?”. The report has the following to say about the hospital built by CIB: “The Pokola health centre (locally known as the ‘hospital’) is reputed as being the most efficient of all of northern Congo.”

The ARTE documentary includes Carstensen’s comment that, “FSC certification is probably the best tool for actually engaging with them [indigenous peoples] for giving them access to health, giving them access to education, giving them other possibilities socially.”

But as Ladwig and Reutter note, only a few of the indigenous Pygmies living in the vast forest area can use the hospital. And the hospital was built before CIB’s concession was certified under the FSC system.

The fourth reference is a book edited by Meindert Brouwer, titled, “Central African Forests Forever”. FSC states that, “The child mortality rate around the other concession mentioned is three times lower than the national average.” Although FSC doesn’t say so, this is a reference to IFO’s concession.

Here’s what Brouwer actually wrote, “Mortality rate for children that are brought to the hospital in the town of Ngombé is 3 times lower than the national average for child mortality.” Which isn’t quite what FSC claims he wrote.


Brouwer’s expertise is PR. He worked for ten years as a communications manager for WWF.

The fifth reference is to SGS Qualifor’s certification report for Congolaise Industrielle des Bois. The report states that “Semi-nomadic populations living around the workers’ camp are also consulted and treated free of charge.”

This is another reference to CIB’s hospital. And as Ladwig and Reutter note in the documentary, most of the Pygmies live in forest and not near the workers’ camp.

The sixth reference is to a 2014 CIFOR occasional paper titled, “Social impacts of the Forest Stewardship Council certification: An assessment in the Congo basin”. It is the same research as that published in 2017 in the International Forestry Review (FSC’s second reference, above).

2. FSC-certification has not stopped deforestation or negative impacts on intact forest landscapes.

In response, FSC states that, “FSC has never pretended to be a stand-alone solution to combat deforestation.”

A quick check on FSC USA’s website reveals that FSC’s mission and vision is “Protecting forests for future generations”. FSC USA states that:

The Forest Stewardship Council mission is to promote environmentally sound, socially beneficial and economically prosperous management of the world’s forests.

That sounds a lot like FSC pretending to be a stand-alone solution to deforestation.

And here’s how FSC USA explains why FSC was set up:

The Forest Stewardship Council was created in 1993 to halt deforestation and safeguard forest ecosystems using the power of the marketplace.

FSC refers to seven papers and reports in its attempt to dismiss the ARTE documentary’s findings on deforestation and the impacts of logging in primary forests.

The first reference is a 2016 paper titled, “Do Forest Management Plans in Congo Lead to Greater Deforestation?”.

FSC summarises the paper as follows:

FSC certification requires forest management plans (FMP). The authors find that during 2000-2010 in North Congo, deforestation rates were higher in the seven main Forest Management Units (FMU) without FMPs (all of which were harvested during this time) than in the six harvested FMUs with FMPs.

The paper was published in Land Use Policy in 2017. The paper is a response to a previous article. Here’s the abstract:

This viewpoint paper presents a reaction to the article by Brandt et al. (2016). It highlights the complexities inherent to the attribution of deforestation impacts to policy interventions when using remote-sensing data. This critique argues that in the context of the Congo a suite of factors (i.e., population density in particular) other than those considered by Brandt et al. (e.g., type of forest, distance from roads and markets) play essential roles in determining the fates of forests. It also contends that care is needed when making decisions regarding which units will be included in the comparison group so that contextual factors and on-the-ground information are properly considered (e.g., when logging operations are inactive or when a concession is used for ‘conservation’ purposes). Finally, it proposes that a focus on an analysis of deforestation rates for a given level of timber production might be a metric that more accurately represents one aspect of the consequences of forest management, which should also consider the appraisal of trade-offs associated with a larger set of social, financial and ecological objectives.

And here’s the abstract of Brandt et al. (2016):

Over 400 million hectares of tropical forests are managed for timber production, comprising more than half of the remaining global permanent tropical forest estate. A growing proportion of tropical production forests are managed under Sustainable Forest Management (SFM) principles. The objective of SFM is to achieve multiple benefits, including forest protection, biodiversity conservation and income enhancement. However, the outcomes resulting from the implementation of SFM in tropical forest ecosystems have seldom been examined rigorously. In this paper, we present a methodological approach to assess broad-scale impacts of SFM policy in tropical forest ecosystems. As a case study, we investigated deforestation and timber production in logging concessions in the Republic of Congo after the implementation of its SFM-based forestry law in 2000. Compliance with the forestry law was incomplete, allowing a unique opportunity to compare deforestation and legal timber production outcomes in concessions that implemented SFM-based policy compared to those that did not. Quasi-experimental matching analysis indicated that deforestation in matched parcels in compliant concessions was up to 2-times higher than matched parcels in non-compliant concessions, equivalent to 67 km2 of forest loss for the period 2005–2010. Annual deforestation data demonstrated that deforestation was stable or increased in all six concessions following the respective date of compliance in each concession. Legal timber production increased (by 5%, from 0.18 to 0.19 CBM/ha/yr) and became more stable, in compliant compared to non-compliant concessions. Our results suggest that the presence of SFM in a concession does not immediately lead to less deforestation. Rather, SFM policy may be associated with higher deforestation, because SFM is also associated with higher legal timber production, foreign capital, and international timber demand. Our findings measure short-term associations between SFM and deforestation in the Congo, and underscore the need for empirical evaluation of long-term impacts of SFM in tropical forest ecosystems worldwide.

Neither study, then, attempts to determine specifically whether FSC certification in the Congo Basin results in more or less deforestation.

The second reference is a paper titled, “A Critical Comparison of Conventional, Certified, and Community Management of Tropical Forests for Timber in Terms of Environmental, Economic, and Social Variables”. In was published in 2016 in Conservation Letters.

In 2017, FSC-Watch carried out a detailed analysis of the literature review behind this paper, and found it to be seriously flawed.

The third reference is a paper titled, “Social and Environmental Impacts of Forest Management Certification in Indonesia”, published in PLOS One in 2015.

This paper compares three FSC certified logging operations with other non-certified logging operations in Kalimantan, Indonesia. The authors write that,

Using data from 2000–2008 in Kalimantan, we find that FSC certification significantly reduced deforestation by 5 percentage points and air pollution by 31% compared to the matched control villages in non-certified logging concessions. This suggests that the program may address previous concerns about the ineffectiveness of traditional logging concessions in reducing deforestation and their potential to decrease community welfare by limiting access to forest resources. However, while FSC certification improves some environmental and socio-economic outcomes, the program may introduce disturbances in forest ecosystems (e.g., by opening the canopy).

They add that, “It is remains unclear if the FSC certification of logging concessions promotes biodiversity per se.”

The fourth reference is a paper titled, “Impacts of nonstate, market-driven governance on Chilean forests”, published in Proceedings of the National academy of sciences of the United States of America.

(FSC got the web address wrong in its response.)

This study compared FSC certified operations in Chile with CERTFLOR, an industry driven certification system, and an NGO logging moratorium. The authors aimed to measure the impact of these three on the rate of conversion of forests to industrial tree plantations.

The paper concluded that,

Using quasiexperimental methods, we demonstrated that Chile’s NSMD (nonstate market-driven) governance regimes were successful in reducing natural forest conversion to plantations by 2–23%. Of the three governance regimes evaluated, the multistakeholder FSC certification standard achieved better environmental performance than either the industry-led CERTFOR standard, or NGO-incited JSP [Joint Solutions Project] moratorium.

The fifth reference is a 2009 report titled, “Effects of Forest Certification on Biodiversity”.

The authors note that there is a “near absence of studies directly addressing the effects of certified forest management on biodiversity”. They write that,

In most certified forests, even though forest managers collect biodiversity information, systematic collection of information needed to assess the effects of management on biodiversity does not take place. Data from non-certified forests, which are needed to assess the added value of certification, are even harder to find. The scientific community has not yet risen to the challenge of providing evidence of the effects of certified forest management on a comprehensive scale.

Because of the lack of studies, and therefore the lack of evidence, the authors use studies that look at “good forest management practices”, including reduced impact logging, establishment of riparian buffer zones, protected areas within forest management units, and identifying High Conservation Value Forests. But these are not studies of FSC certified operations. The reduced impact logging carried out in the operations under study may well not be the same as reduced impact logging carried out in FSC certified operations.

The authors state that, “In the face of these difficulties and uncertainties, the conclusions drawn from the literature study can only be tentative.”

FSC ignores this, and claims that the report found that, “FSC certification has a positive impact on biodiversity.” That is simply not true.

The sixth reference is a paper titled, “Multiple Patterns of Forest Disturbance and Logging Shape Forest Landscapes in Paragominas, Brazil”, published in Forests in 2016.

FSC claims that the report finds that, “In Brazil, FSC certification reduces forest disturbance.” That’s an exaggeration.

In fact, the finding applies to forest disturbance in one logging concession covering an area of 140,658 hectares, run by Cikel Brasil Verde Madeiras. The study looks at logging in the municipality of Paragominas – from illegal logging to FSC certified logging.

The authors found that,

Our disturbance indicators provide observable evidence for the difference between legal and illegal patterns, with some illegal areas having suffered more than three explorations in fifteen years. They also clearly underlined the efficiency of Reduced Impact Logging (RIL) techniques applied under Forest Stewardship Council (FSC) guidelines to reduce the logging impacts in terms of canopy openings.

The seventh reference is a 2017 article on Mongabay titled, “Camera traps reveal surprises in Peru”.

FSC claims that the article shows that, “In Peru, FSC certification has been proved to be beneficial for biodiversity.” Once again, that’s an exaggeration.

The Mongabay article is based on preliminary results from a study carried out by WWF Peru. José Luis Mena, scientific director of WWF Peru, told Mongabay that “the majority of forest concessions in Tahuamanu have forestry certification, and the objective that we have with this project is to compare the state of biodiversity conservation in two types of concessions: certified and not certified.”

WWF set up camera traps in 24 certified concessions, 24 non-certified concessions and 24 control areas – which are inside concessions but have not yet been logged.

Mena explained that the research team’s hypothesis is that FSC certified concessions should have a “greater number of species or have a community that would indicate to us a higher level of conservation than the others, those that do not have FSC [certification].”

Mongabay reported that the results of the research will be known in 2018.

In fact, the results of the research were recently published in Biological Conservation, in a paper titled, “Do responsibly managed logging concessions adequately protect jaguars and other large and medium-sized mammals? Two case studies from Guatemala and Peru”.

The report concludes that,

We believe that well-managed, certified logging concessions have far less negative effects on forest ecosystems than alternative land uses such as cattle ranching, palm plantations and mono-cultures that result in deforestation and drastic reductions in biological diversity. Logging concessions would therefore be ideal in buffer zones and multiple use zones of protected areas, allowing for economic activities while still protecting intact ecosystems. The key to success is strict control and enforcement of management practices by governments along with third-party organizations such as the FSC or the Program for the Endorsement of Forest Certification.

So, according to the researchers, either FSC or PEFC certification will do the job.

3. In Vietnam and Cambodia, timber from illegal logging organizations is being sold to FSC-certified companies and makes its way to the European market. Human rights abuses are occurring.

“We found the graphic images of human rights abuses very upsetting and we condemn any form of violence,” FSC writes in its response. It’s good to know that FSC condemns violence.

FSC has asked Accreditation Services International to carry out an investigation “into the allegations of fraud with Cambodian illegal timber in the supply chains of several specific FSC-certified entities in Vietnam”.

Such an investigation is long overdue. Since the early 1990s, the Environmental Investigation Agency has been documenting the illegal trade of timber from Laos and Cambodia to Vietnam. EIA’s 2008 report “Borderlines: Vietnam’s Booming Furniture Industry and Timber Smuggling in the Mekong Region” found that FSC’s chain of custody certification provides no guarantee that the timber was legal.

4. The documentary claims that most of the wood from a specific
certified company in Peru originates from illegal logging and alleges that some of it is exported under an FSC label.

In response, FSC writes that, “Contrary to the claim made by the filmmakers, FSC does not tolerate illegal logging in our system.”

FSC promises to “investigate allegations of illegal logging in Peru entering the FSC system”.

Once again, an FSC investigation is long overdue. The Environmental Investigation Agency and Global Witness have been researching illegal logging in Peru for many years. EIA’s most recent report, “Moment of Truth” finds that FSC is “no guarantee of legality”.

5. The FSC Mix label is deceptive and the wood may come from unsustainable sources.

FSC writes that, “We acknowledge that controlled wood is a controversial subject and we have been working hard at improving the standard for controlled wood.”

FSC explains that “The term controlled wood describes wood products that are not made up of any sources considered unacceptable.” FSC’s response states that it is “committed to improving our communication around these topics”. But improved communication will solve nothing.

The problem is structural. As Simon Counsell of Rainforest Foundation UK (and co-founder of FSC-Watch), points out in the documentary,

“FSC 100%, in which the labelled product contains only FSC certified timber, is actually just a very small part of the picture. And the others are from what are called, euphemistically, controlled wood. And controlled wood is that which hasn’t actually been controlled.

“So instead of auditors on behalf of FSC going into the forest to inspect the logging operations, it’s basically done from a desk somewhere else, in Bonn, or in London.”

6. An FSC-certified company in Brazil has forcefully displaced a local community.

In its response, FSC refers to its standards on free, prior and informed consent, and its rule that conversion of forest to plantations is not allowed under the FSC system, if the forest destruction took place after 1994. (Predictably, FSC says nothing about Motion 7, passed at its General Assembly in Vancouver in 2017, that would allow certification of plantations on forest trashed since 1994.)

FSC gives the impression that its auditing process picks up any problems that local communities face, and deals with them.

Nothing could be further from the truth. Rainforest Alliance’s most recent audit states that land conflicts have been resolved.

ARTE’s journalists Ladwig and Reutter reported that villagers in the south of Bahia feel that they are being “wiped out by eucalyptus” – planted by the pulp company, Veracel.

The reality is that Veracel has taken over a vast area of land, exacerbating land conflicts. Villagers have lost farming land to the company’s monoculture tree plantations, and say that the company has taken their livelihoods.

7. The practice of certifying plantations is not in line with sustainable forestry.

FSC acknowledges that “It is correct that plantations are a controversial and complex issue.” But FSC yet again sides with the plantation industry. “Plantations are often necessary to meet consumer demand for forest products,” FSC writes.

In the documentary, Klemens Laschefski, professor of political ecology at the Federal University of Minas Gerais, describes how he feels about this “consumer demand”:

“It’s simply unbelievable that people here fight for their land so that they can eat, and its occupied by a company that produces toilet paper for us in Europe. I can’t get my head around that, as much as I try. That really upsets me. That makes me really sad.”

This, by the way, is what Veracel’s “sustainable forestry” – certified under the FSC system as well managed – looks like:


8. Certification bodies and certificate holders have close ties leading to conflicts of interests and corrupt practices.

This is the conflict of interest at the heart of the FSC system. FSC’s certifying bodies are paid by the companies that want to get certified. The certifying bodies do not want to get a reputation for being too “difficult”, otherwise they will not be hired in future.

In its response, FSC refers to Accreditation Services International that is supposed to oversee the work of the certifying bodies. But the conflict of interest remains. And FSC has utterly failed to address it.

9. FSC certifies clear cutting in the boreal, which is damaging to the forest.

In its response FSC admits to allowing clearcuts: “It is true that FSC has certified forest operations practicing clear cutting within specific and controlled parameters.”

FSC also admits that this is “controversial issue with many complexities”. But FSC, as usual, sides with the timber industry and claims that clear cutting is “a widely accepted practice by foresters and environmentalists alike”.

FSC refers to a 2013 report produced by FSC Sweden, titled, “The contribution of FSC® certification to biodiversity in Swedish forests”.

Also in 2013, the Swedish Society for Nature Conservation published a report with the title, “Credibility at Stake – How FSC Sweden Fails to Safeguard Forest Biodiversity”. Obviously, FSC makes no mention of SSNC’s report.

FSC claims that 2.5 million hectares of high conservation value forest are conserved in Russia, thanks to agreements between the companies and WWF Russia.

But that does not address the clearcuts of forest in Archangelsk featured in ARTE’s documentary. After FSC-Watch wrote a post about the documentary’s reporting on FSC in Russia, Alexey Yaroshenko of Greenpeace Russia commented with a link to a post on a Greenpeace Russia forum, titled, “Who Destroys the Last Taiga Wilderness in Arkhangelsk Oblast”.

The post includes satellite images, that clearly show how FSC certified logging operations are clearcutting high value conservation forest. Here is one example:

This is the tenth post in a series based on ARTE’s documentary about FSC: “The exploitation of primary forests: Can an ecolabel stop the forest industry?”
The documentary is available here (and in German here).


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