Update on risk assessment associated with illegal harvesting of wood, in contradiction of national and international legislation, as well as to identify the best measures to mitigate them, considering the evolution of the legislative framework and the current realities in the Romanian forestry sector.
This update will support operators and stakeholders in order to better implement the (EU) Timber Regulation No 995/2010 (EUTR).r și factorilor interesați, în vederea unei mai bune implementări a Regulamentului (UE) privind Lemnul nr. 995/2010 (EUTR).
The analysis uses the framework proposed by FSC® (Forest Stewardship Council) for the National Risk Assessment (FSC-PRO-60-002 V3-0). According to this best practice model and based on the Centralised National Risk Assessment (FSC-CNRA-RO V1-0 RO), published in September 2017, an updated analysis of specific indicators regarding the risks of illegal wood harvesting was carried out.
The analysis was conducted within a participatory process consisting of 3 working groups attended by representatives of forest administrators, competent authority, operators and academia, followed by submission of the resulting document to public consultations between 16/07/2020-31/07/2020.
The risk assessment associated with illegal harvesting of wood is an obligation imposed on operators1 by (EU) Timber Regulation No. 995/2010 (EUTR) in the process of purchasing wood materials. The assessment of the origin of timber and the fulfilment of legal obligations in the wood harvesting process must be carried out at the level of the wood purchase unit for each product placed on the market. The process of assessing the risks associated with illegal harvesting of wood will be based on the following concepts:
Assessment of legality (general approach) systematic and/or large-scale infringements of applicable law.
Illegally harvested timber means harvested in contravention of the applicable legislation in the country of harvest;
Applicable legislation means the legislation in force in the country of harvest covering the following matters (EUTR, Article 2 (h)):
rights to harvest timber within legally gazetted boundaries;
payments for harvest rights and timber including duties related to timber harvesting,
timber harvesting, including environmental and forest legislation including forest management and biodiversity conservation, where directly related to timber harvesting,
third parties’ legal rights concerning use and tenure that are affected by timber harvesting;
trade and customs, in so far as the forest sector is concerned.
Sources of information relevant for establishing the level of compliance (level of governance):
Official governmental reports
Non-governmental reports (relevant, verifiable by third parties)
Independent scientific studies and articles
Evidence resulting from the involvement of stakeholders
National Geographical Scale (RO)
Functional scale Spatial delimitation based on non-geographical characteristics (e.g. functional category, property type, type of administration, scale, intensity and risk of forest operations)
helps to correctly identify risks and mitigation measures, thus avoiding unnecessary administrative burdens (e.g. for national forest fund areas only, which are privately owned – by individuals)
Threshold (1) Low risk The legislation identified is respected. Violations of laws/regulations are effectively monitored through prevention measures taken by competent authorities and/or entities.
Threshold (2) Specified risk The identified legislation is not consistently respected by all entities and/or is often ignored, and/or not implemented by competent authorities.
Risk management involves procedures to identify and mitigate specific risks. The assessment is made in relation to the risk that timber will be harvested, transported or marketed illegally or mixed with material of illegal origin.
SMART mitigation measure Specific, Measurable, Achievable, Realistic, Time-Bound.
RISK DESCRIPTION & MITIGATION MEASURES