Results of the Survey of Russian Forest Industry Senior Staff Awareness of the European Union Timber Regulation 995/2010

Results of the Surveyof Russian Forest Industry Senior Staff Awareness of the European Union Timber Regulation 995/2010

This publication has been produced with the assistance of the European Union. The content, findings, interpretations, and conclusions of this publication are the sole responsibility of the FLEG II (ENPI East) Programme Team (www.enpi-fleg.org) and can in no way be taken to reflect the views of the European Union. The views expressed do not necessarily reflect those of the Implementing Organizations.

Results of the Surveyof Russian Forest Industry Senior Staff Awareness of the European

Union Timber Regulation 995/2010

Nikolay Shmatkov, Andrey Shegolev (WWF Russia)Olga Karaeva (Yuri Levada Analytical Center)

Roman Verin (NEPCon)

March 2015

Results of the survey of Russian forest industry senior staff awarenessof the European Union Timber Regulation 995/2010. Shmatkov, N., O. Karaeva, A. Shegolev, R. Verin 2015. WWF, Moscow. 72 p.

Editor: Nikolay Shmatkov (WWF Russia)

Translation: Ekaterina Karpenko, Nikolay Shmatkov (WWF Russia)

Peer review: Elena Kulikova, European Forest Institute

The authors would like to thank Alexander Bruykhanov (WWF Russia), Nikolay Stashkevich (WWF Russia), Andrey Ptichnikov (FSC Regional Office for CIS countries), Alexander Voropaev (GFTN Russia) for their valuable comments provided for the text of this publication.

The survey of Russian forest sector companies’ awareness of the EUTR and their compliance level was performed as part of the European Neighborhood and Partnership Instrument (ENPI) East Countries Forest Law Enforcement and Governance (FLEG) II Program. The Program is funded by the European Union and implemented by the World Bank in partnership with WWF and IUCN.

This publication has been produced with the assistance of the European Union. The content, findings, interpretations, and conclusions of this publication are the sole responsibility of the FLEG II (ENPI East) Program Team (www.enpi-fleg.org) and can in no way be taken to reflect the views of the European Union. The views expressed do not necessarily reflect those of the Implementing Organizations.

Citation of FLEG II (ENPI East) is mandatory in the case of full or partial reproduction of this report.

This report is distributed free of charge.

On the cover: © Victor Jyvotchenko / WWF Russia

The material in this publication is copyrighted. Copying and/or transmitting portions of this work without the permission may be in violation of applicable law.

ContentsEXECUTIVE SUMMARY 4

LIST OF ABBREVIATIONS 9

OBJECTIVES 10

METHODS 11

FINDINGS AND DISCUSSION 161. Overall understanding of the EUTR: awareness, applicability and character of change needed for companies to adjust 162. FSC voluntary forest certification: presence and plans 203. Due diligence system: implementation and role of monitoring organizations 234. Changes in requirements for suppliers under the EUTR 265. Information sources on the EUTR 30

RESULTS AND RECOMMENDATIONS 34

ANNEX 1. List of survey questions 45

ANNEX 2. WWF-Russia’s Guidance for Operators and ompetent Authorities on Applicable Legislationof the Russian Federation for EU Timber Regulation 50

4

Executive summaryRegulation (EU) No. 995/2010 of the European Parliament and of the Council of 20 October, 2010 laying down the obligations of operators who place timber and timber products on the market (further referred upon as the EUTR) came into effect across the EU on 3 March, 2013.

EUTR lays down obligations on operators to introduce a due diligence system to evaluate the risks of timber harvested in breach of applicable legislation of a country of harvest or timber products derived from such timber being placed on the market and to minimize these risks.

The research was organized to access Russian timber suppliers’ awareness level of the EUTR and its requirements and due diligence procedures, understand reflections of Russian companies on consequences of this regulation on their businesses and perceptions on EUTR’s effectiveness to contribute tackling the illegal logging problem in Russia. The methodology for the research was developed by WWF Russia in partnership with the Levada Analytical Center1 and NEPCon2 (a monitoring organization).

100 forest sector companies (logging, timber processing and trade) in 13 subjects of the Russian Federation — from the Russian

1 http://www.levada.ru/eng/2 http://www.nepcon.net

5

North-West to the Russian Far East — participated in the research. Only those companies exporting to the EU countries either directly or through supply chains participated. Only senior staff (directors, certification managers etc.) was approached. The questionnaire was highly detailed and contained 40 questions. The opinion poll took place from October 13 till December 3, 2014.

The research demonstrated that 94 % of companies are aware of the EUTR. However, only 47 % of companies were informed about some details of EUTR requirements and only 45 % of companies, exporting timber to EU do believe that the EUTR has a potential influence on their activities. Obviously there is still a lot of room for basic awareness raising of EUTR: after almost 2 years the EUTR is enforced a half of suppliers working with EU companies have not heard of the EUTR or have not heard much. The least informed companies are located in the Russian Far East where supply chains ending in EU are going through Asian intermediates. The large and intermediate size businesses are more informed about the EUTR (60 % in this segment are aware) compared to small size companies (28 %) businesses. About a quarter of respondents are seeking for some additional information on the EUTR and require publications and trainings.

However, the implementation level of the EUTR and its influence on practical aspects of timber legality in Russia is still — almost 2 years after it came into the full force — very low. Only 1/3 of companies were approached by their EU counterparts with additional requests for information about timber origin and only 40 % of timber export companies which are actually aware of the EUTR requirements developed and introduced due diligence procedures and 18 %

6

are planning to do so in the nearest future. 48 % of respondents believe that EUTR requirements is about more paper work only;42 % of timber exporting companies believe that the EUTR will have no influence on timber legality and will not contribute to the tackling illegal logging. Important to note, that 13 % of companies frankly admit that they are not sure in legality of their timber. Only 1/3 of the respondents in the Russian Far East are sure that the product they sell to the EU market are completely legal. The response rate was high — about 90 % of companies approached by surveyors agreed to participate in the research. However, only half of companies approached for the survey in the Russian Far East agreed to answer legality questions, in Irkutsk Region — 1/3 of companies refused to participate in the survey. This is an indirect indicator (proven by other studies3) that there are more legality problems in Southern Siberia and the Russian Far East, compared to other areas of Russia.

EU companies holding FSC CoC certificates pay more attention to timber legality and introduce additional requirements for their Russian suppliers. 32 % of Russian FSC certified respondents reported on additional requirements set by their EU counterparts, compared to 5 % of not certified companies. 29 % of FSC certified Russian companies which participated in the survey reported that EU operators introduced additional field legality checks, compared to 14 % of not certified respondent which are facing the same requirements now.

Senior management staff of Russian companies is sober on its financial expectations on the EUTR. No expectations for any

3 E. g. http://www.wwf.ru/resources/publ/book/eng/776

7

additional competitiveness for their products on the market of price premiums are expected as a reward for following EUTR requirements. So far the EUTR was not a huge additional financial burden for companies: only 13 % of respondents reported on sufficient increase of their costs to fulfill requirements imposed by their EU partners.

However, respondents are not optimistic on practical results of the EUTR implementation in tackling illegal logging and timber trade problem on the ground. While 48 % of the respondents presume the EUTR would only mean more paperwork to them, 42 % of timber exporters are sure the new law would neither help improve legality nor contribute to the combating of illegal logging. Some respondents made remarks, that “the new Regulation will not help to resolve the problem in case illegal timber is supplied for the domestic market”, there were comments that “irresponsible companies will be pushed to out of the EU market to the Chinese one”. Several respondents said that for them “the new Regulation is just about some more paperwork but nothing will be changed in the real life” and “illegal loggers will continue to flourish, they have been transformed into bigger illegally operating companies affiliated to authorities thus transforming into mafia”.

Yet, there is hope for things to get improved, as approximately one fourth of the respondents claimed they need more information on the EUTR and its requirements and they reported to be ready to take training and update themselves by reading relevant publications. This means there are a lot of businesses that are willing to commit to the EUTR, and the civil society organizations along

8

with other interested stakeholders in place may serve the source of information on the updates to EU regulations.

Generally, the survey shows that even though the businesses appear quite aware of the EUTR, there is a huge gap in their interpretation of the essence of the new regulations seeking combating illegal logging and of how they should be implemented. The results of the survey will be brought to the attention of the Commission, competent authorities, monitoring organizations, operators and NGOs. Hopefully this information will help to bring more action to improve implementation of the EUTR and make it a real force to tackle illegal logging in timber producing countries. We hope that based on the survey outcomes, the Russian forestry businesses will enjoy more information support as a way to help them adjust their operations to the updated EU context and to start implementing the due diligence systems for efficient timber origin legality verification.

9

List of abbreviationsASI — Accreditation Services InternationalCEO — Chief Executive OfficerCoC — chain of custody DDS — due diligence systemEU — European UnionENPI — European Neighborhood and Partnership InstrumentEUTR — European Timber RegulationFSC — Forest Stewardship CouncilGFTN — Global Forest Trade NetworkIUCN — International Union for Conservation of Nature (the World Conservation Union) Ltd. — limitedMln — millionMO — monitoring organizationNGO — non-governmental organizationWWF — World Wide Fund for Nature

10

ObjectivesRegulation (EU) No. 995/2010 of the European Parliament and of the Council of 20 October, 2010 laying down the obligations of operators who place timber and timber products on the market (further referred upon as the EUTR) came into effect across the EU on 3 March, 2013.

EUTR lays down obligations on operators to introduce a due diligence system to evaluate the risks of timber harvested in breach of applicable legislation of a country of harvest or timber products derived from such timber being placed on the market and to minimize these risks.

The research was organized to access Russian timber suppliers’ awareness level of the EUTR and its requirements and due diligence procedures, assess availability of information on EUTR and its requirements and relevant procedures, understand reflections of Russian companies on consequences of this regulation on their businesses and perceptions on EUTR’s effectiveness to contribute tackling the illegal logging problem in Russia. The key objective of the research was to shape informational aids to be provided to EU based operators and monitoring organizations to establish sound due diligence systems and to their suppliers in Russia to help them adjust their operations to the updated EU context and to start implementing the due diligence systems for efficient timber origin legality verification.

The results of the survey could be important for the Commission, competent authorities, monitoring organizations, operators and their suppliers, and NGOs. Hopefully this information will help to bring more action to improve implementation of the EUTR and make it a real force to tackle illegal logging in timber producing countries.

11

MethodsThe research on the level of companies’ awareness of the EUTR was organized as a telephone and on-line interview. Only senior staff of Russian logging, timber processing and trade companies with clients in the EU participated.

The methodology for the research was developed by WWF Russia in partnership with the Levada Analytical Center and NEPCon (a monitoring organization) and tested by NEPCon at 8 companies of the forest sector in Arkhangelsk Region in the summer of 2014. Based on the results of this testing some improvements to the methodology were introduced.

The major survey was organized by the Levada Analytical Center from October 13 till December 3, 2014 in 13 subjects of the Russian Federation, including Arkhangelsk, Leningrad, Pskov, Vladimir, Vologda, Irkutsk Regions, the Republics of Karelia, Komi and Adygea, Krasnodar, Khabarovsk and Primorsk Krays (see the Table 1.1). The scope of the research was predetermined mainly by priority regions of the FLEG II in Russia. 100 enterprises4 with clients in the EU were surveyed (either trading their products directly to the EU partners, or through supply chains). The survey contained 40 questions.

3 In one of the regions 3 enterprises which belong to one large consortium were interviewed. In the analysis and interpretations these enterprises are treated as independent ones.

12

SUBJECT OF THE RUSSIAN FEDERATION

QUANTITY OF RESPON-DENTS

SUBJECT OF THE RUSSIAN FEDERATION

QUANTITY OF RESPON-DENTS

Leningrad Region 22 Pskov Region 6

Republic of Karelia 15 Primorsk Kray 4

Irkutsk Region 12 Vologda Region 4

Arkhangelsk Region 9 Krasnodar Kray 2

Krasnoyarsk Kray 8 Republic of Komi 1

Khabarovsk Kray 8 Vladimir Region 1

Republic of Adygea 6 Total 100

Table 1.1.Number of respondents in the regions of Russia

13

The selection of Russian suppliers of timber products to EU to participate in the research was accomplished by the Levada Analytical Center and was based on the random selection (in each region) from the data base “Logging and Timber Processing industry — 2014”5 and was verified through direct contacts with industries and relevant regional resource management authorities.

The key method for data collection was telephone interviews with CEOs and managers responsible for certification. However, these respondents were hard to reach so the on-line tool was also employed (see figure 1.1 and 1.2).

42 %

15 %

15 %

9 %

2 % 2 %

4 %

11 %

Position

CEOForest Manager (or Timber SupplyManager)Sales Manager(or vice)Export SalesManager (or vice)Certification ManagerCommercial DirectorHead of theCommercial DepartmentVice Head on LegalIssues

Method

Telephone interviewOnMline survey

85 %

15 %

Figure 1.1. Proportion between telephone and on-line interviews used for data collection

Figure 1.2. Positions of respondents within their companies

5 The data base is a part of the larger one: “Industry of Russia and Neighboring Countries” // “ASU-Impuls”, 2014. http://www.asuimp.com

14

The Levada Analytical Center faced serious challenges implementing the research. The greatest challenge was to reach respondents. The problem is explained by three key factors:

1) narrow group of respondents (only enterprises trading with EU — directly or through supply chains — were interviewed);2) low quality of contact information data bases;3) many enterprises refused to answer legality questions right away and were not included into the poll.

These challenges resulted into the longer implementation period and a lot of efforts into obtaining contacts. The average response rate was high — about 90 % of respondents approached by surveyors agreed to participate in the research. The rate was much lower in the Russian Far East (about 50 %) and in the Irkutsk Region (about 70 %).

Almost equal numbers of small size (100 staff and below), and medium (101–1000 staff) and large size (1001 and above)(see figure 1.3), there was a broad variation of financial turnover

Size of a company

Small size Medium sizeLarge size

47 %

20 %

33 %

Figure 1.3. Number of small, mediumand large scale companies surveyed

15

(see figure 1.4). Mostly Russian owned companies were reviewed, though 20 % of companies have international investments, including 14 % with EU investments (see figure 1.5). A wide scale of organizational forms was covered (figure 1.6).

Annual turnover, mln rubles

Under 10 10–100 under 1 0001 000–10 000

Above 10 000No answerDo not know

14 %

36 %

14 %

15 %

6 %

8 %7 %

An organizationalform

StateMownedenterpriseMunicipalenterpriseOpen joint stockventureClosed joint stockventure (Ltd.)Limited liabilitycorporation

2 % 2 %3 %

18 %

55 %

Source of internationalinvestments

No international investmentsWith EU investmentsWith Chinese investments

6 %

80 %

14 %

Figure 1.4. Annual turnover of surveyed companies

Figure 1.6. Organizational formsof surveyed companies

Figure 1.5. Shareof surveyed companieswith international investments and their sources

16

Findings and discussion1. Overall understanding of the EUTR: awareness, applicability and character of change neededfor companies to adjust

Most of respondents (94 %) are aware of the EUTR. Only 6 enterprises out of 100 admitted that they have never heard of the EUTR before. The least informed companies are located in the Russian Far East where supply chains ending in EU are going through Asian intermediates. 47 % of companies are well aware of EUTR requirements, and 46 % have only heard of the EUTR but not know any details. Obviously there is still a lot of room for basic awareness raising of EUTR: after almost 2 years the EUTR is enforced 52 % of suppliers working with EU companies have not heard of the EUTR or have not heard much. The large and intermediate size businesses are more informed about the EUTR (60% in this segment are aware) compared to small size companies (28%) businesses (see table 1.2) though awareness raising is needed in these both segments.

Almost every second respondent (45 %)6 believes that the requirements on timber legality established by the EUTR is totally applicable for it and in a quarter of companies top managers believe the EUTR is only partially applicable. 9 % of EU timber suppliers believe that the EUTR is applicable in an indirect manner

7 Here and further, the share (%) from the companies which are aware of the EUTR is provided (94 enterprises out of 100), if not indicated differently.

17

AW

AR

EN

ES

S L

EV

EL

SH

AR

E F

OR

M

TO

TAL

NU

MB

ER

OF

R

ES

PO

ND

EN

TS

FEDERAL DISTRICT SIZE OF A COMPANY

NO

RT

H

WE

ST

SIB

ER

IA

SO

UT

HE

RN

TH

E

RU

SS

IAN

FA

R E

AS

T

SM

ALL

SIZ

E

ME

DIU

M

SIZ

E

LAR

GE

S

IZE

I have never heard of the EUTR before

6 0 0 8 42 7 8 4

I have heard something but do not know the details

46 55 55 8 33 63 28 36

I have studied the EUTR and well aware of its content and requirements

47 45 45 85 17 28 64 61

Do not know 1 0 0 0 8 2 0 0

Table 1.2.Respondents’ awareness level of the EUTR across federal districts7

and size groups (% of the total number of respondents)

7 The Central Federal District was represented by one company only and was not specified in the analyses.

18

and 12 % of companies believe the EUTR has no relevance to their work. Companies based in the Russian Far East and in the Southern Federal District feel their work less relevant to the EUTR compared to companies in other locations (see table 1.3).

Estimation of EUTR relevance provided by CEOs and other senior managers well corresponds with their estimation of the level of change the EUTR introduced into companies’ work. 65 % of surveyed companies reported that the EUTR did not make any changes and for 17 % of surveyed companies the changes were minimal. However 15 % of companies feel a big change introduced by the EUTR. The changes are felt mostly by medium size businesses. One of possible explanation of this phenomenon could be the usual observation that medium size business are less flexible compared

Table 1.3.Estimation of relevance of the EUTR to activities of companies

(% of the companies aware of the EUTR)

ESTIMATION OF RELEVANCE

TOTAL

FEDERAL DISTRICT

NORTH WEST

SIBERIA SOUTHERNTHE RUSSIAN FAR EAST

Totally relevant 45 56 20 58 0

Partially relevant 23 20 25 33 17

Relevant by indirectly 9 11 5 8 0

Totally irrelevant 12 5 30 0 33

I do not know 12 7 20 0 50

19

to small size businesses and not big enough to manage additional legal requirements in the most effective way (see table 1.4).

The key changes recognized by the forest sector senior staff could be grouped as follows:

• more documents (often described by companies as “paperwork”);• more strict control from the buyers side (compliancy checks, additional requests for compliance);• more costs for new procedures to confirm legality.

40 % of respondents expect changes in the future to come (52 % of medium size businesses). From those expecting the changes

Table 1.4.Estimation of the level of change introduced by the EUTR

into companies’ work (% of companies aware of the EUTR)T

OTA

L


NO

RT

H

WE

ST

SIB

ER

IA

SO

UT

HE

RN

TH

E

RU

SS

IAN

FA

R E

AS

T

SM

ALL

S

IZE

ME

DIU

M

SIZ

E

LAR

GE

S

IZE

Nothing has changed 65 65 70 42 83 79 52 52

Minimal changes 17 24 10 8 0 5 26 30

Sufficient changes 12 7 10 42 0 10 22 7

Principle changes 2 2 0 8 0 2 0 4

I do not know 3 2 5 0 17 5 0 4

20

to come, the most expect them to happen in the coming year (50 %), about the quarter — in a few years (22%).31 % of companies expect some minimal changes, 42 % expect some considerable changes and 17 % — expect some critical changes (see figure 1.7).

2. FSC voluntary forest certification:presence and plans

2/3 of surveyed companies have some FSC certified products in their supply chains to EU (64 %). Almost all large companies (96 %) have at least some certified supply chains, 100%

Minimal changes Critical changesConsiderable changes I do not know

31

42

Total Small size Medium size Large size

3327

20 20 17 17

44

33

11 11

0

67

1711

Figure 1.7. Answers to the question: “Do you believe that will be minimal, considerable or critical changes?” (% of those companies that expect some changes)

21

of products delivered to EU by the each second large company are certified. 32 % of small and medium size enterprises have no certified products in their supply chains (see figure 1.8). The least certified companies are observed in the North West and the Russian Far East but this could me mostly contributed to the fact that in these areas a lot of small businesses took part in the survey (figure 1.9).

3/4 of companies (73 %) are going to renew FSC certificates in future, a half of companies which have no certificates are going to get certified.

It looks like EU companies holding FSC CoC certificates pay more attention to timber legality and introduce additional requirements for their Russian suppliers. 32 % of Russian FSC certified respondents reported on additional requirements set by their EU

Share of certified productsNo certified products (% of companies)

Small size

4733

Medium size

3932

Large size

52

4

Share of certified productsNo certified products (% of companies)

NorthMWest

3729

Siberia

67

15

RussianFar East

59

33

Southern

22

8

Figure 1.8. Share ofFSC-certified products(by volume) in supply chainsof companies of various sizes

Figure 1.9. Share of FSC-certified products (by volume) in supply chains of companies in various districts

22

counterparts, compared to 5 % of not certified companies (see figure 1.10). 29 % of FSC certified Russian companies which participated in the survey reported that EU operators introduced additional field legality checks, compared to 14 % of not certified respondent which are facing the same requirements now (see figure 1.11).

2/3 of companies (67 %) believe that FSC is enough to comply with EUTR requirements. 72 % of FSC certified businesses and 59 % of not certified businesses share this view point.

Additional requirements wereintroducedAdditional requirements werenot introducedI do not know

5 5

91

32

68

No FSC FSC certified No FSC FSC certified

29

71

14

86

Additional field checks wereintroducedAdditional checks werenot introduced

Figure 1.10. “Were there additional requirements for the products quality and labeling introduced since the last year?” (in correlation with FSC certification)

Figure 1.11. “Were additional field checks of timber suppliers introduced at your company?” Correlation of answers withthe presence of FSC certification

23

3. Due diligence system: implementationand role of monitoring organizations

According to respondents’ replies, due diligence systems are introduced at 40 % of surveyed enterprises. 18 % of companies which are lacking these systems are going to introduce them in future. However 1/3 of companies have no such a system and it is not planning to get it introduced.

However, this particular information — on due diligence systems — has to be treated with care. According to NEPCon practical experience, only a few large enterprises in Russia have introduced due diligence systems under full requirementsof the EUTR.

The largest share of companies which have got these systems introduced is with the large and medium size companies (52 %). Only 26 % of small companies have the system in place. Every second company reported to have no system and no plans to introduce it (table 1.5).

57 % of companies with due diligence systems on place have been developed these systems themselves, in 6 % of cases systems were introduced by operators. Monitoring organizations were involved into development of due diligence systems only at 9 % of companies (figure 1.12).

Indeed, 70 % of respondents are aware of the role of monitoring organizations. However, 60% of those which have not involved monitoring organizations in development of their systems are not

24

Table 1.5.Number of companies with a due diligence system (DDS) and having

plans to introduce it (% of those aware of the EUTR)

TO

TAL

FEDERAL DISTRICT SIZE OF THE COMPANY

NO

RT

H W

ES

T

SIB

ER

IA

SO

UT

HE

RN

TH

E R

US

SIA

N

FAR

EA

ST

SM

ALL

SIZ

E

ME

DIU

M S

IZE

LAR

GE

SIZ

E

No DDS and no plans to introduce it

32 36 35 25 0 50 13 22

No DDS but there are plans to introduce it

18 11 15 58 17 12 39 11

DDS is introduced 40 45 35 17 50 26 48 52

I do not know 10 7 15 0 33 12 0 15

By ourselves (by our company)By a customerBy an individual consultantBy a consulting companyBy a monitoring organizationI do not know

57

6

6

9

9

17

Figure 1.12. “Who developed and introduced a due diligence system for your company?” (% from those companies which have the system running or working on it)

25

planning to invite them to participate; only 18 % are considering this opportunity for the future.

Mostly large businesses invite monitoring organizations to develop and establish due diligence systems. 28 % of large enterprises reported on this, compared to just 5 % with small business. However, the research demonstrates a clear demand for small and medium size enterprises to approach monitoring organizations for due diligence systems to be set up (table 1.6).

There is no correlation with FSC certification and due diligence systems development (figure 1.13).

Table 1.6.Cooperation with monitoring organizations

STATUS OF COOPERATION WITH MONITORING ORGANIZATIONS (MOS)

TO

TAL

SIZE OF THE COMPANY

SMALL SIZE

MEDIUM SIZE

LARGE SIZE

We do not work with MOs and do not plan to do so

60 79 55 32

We do not work with MOs but are planning to do so in the future

18 14 36 8

We work with MOs 10 5 0 28

I do not know 11 2 9 28

26

4. Changes in requirements for suppliersunder the EUTR

Most companies reported there were no changes in their clients’ requirements since the EUTR was enforced. However each third company reported about changes. Half of respondents (48 %) reported that changes are only of bureaucratic character, however another half of the respondents believe that changes are not only bureaucratic (41 %) and only a few companies say that changes are totally not about bureaucracy (table 1.7). Generally speaking,22 % of companies complain about more bureaucracy after the EUTR came into force.

56 % of companies did not notice any changes in paperwork that accompany timber trade. 1/3 of companies (31%) that did notice changes in the requirements reported that new documents have been introduced, each ten respondent said about new forms of documents.

No FSCFSC certified

A due diligencesystem is not

introduced andthere are no plans

to introduce it

3630

A due diligencesystem is notntroduced butthere are plansto introduce it

18 19

I do notknow

5 10

A due diligencesystem

is introduced

41 41

Figure 1.13. FSC and due diligence systems (% of companies)

27

Every fourth company (24 %) reports about the new requirements for additional field legality checks.

Most of surveyed companies (78 %) do not perceive the EUTRas a threat. However, 13 % of companies perceive it as a threat (mostly small and medium businesses) (figure 1.14).

Table 1.7.Nature of changes in requirements of clients

(% of those companies that observe changes)

NATURE OF CHANGES TOTALSIZE OF A COMPANY

SMALL SIZE MEDIUM SIZE LARGE SIZE

Only bureaucratic 48 20 62 64

Other changes, in addition to bureaucratic

41 60 38 27

Not bureaucratic changes 10 20 0 9

Figure 1.14. Requirements for additional field checks and perception of the EUTR as a threat by companies of various size

Now there is a needfor additional fieldchecksThe EUTRis a potential threatfor our company'sbusiness

Total

24

13

Small size

1217

Medium size

35

17

Large size

33

4

28

At the same time most of the respondents do not see in the EUTR any opportunities either. Only 24 % of companies see some opportunities in the EUTR, mostly — large businesses(41 % of respondents in this sector).

According to participants of the survey the EUTR does not influence their competitiveness: 73 % of respondents do not think that the EUTR improves their positions at the international market, in the contrary, 5 % of respondents believe they are losing their competitiveness and only 16% believes that the EUTR influenced their competitiveness in a positive way. Small business seems to be more vulnerable — 10 % of small enterprises believe their products are less competitive now and only 12 % of companies in this sector believe their products are more competitive now. In the contrary, more than a quarter (26%) of large business perceives the EUTR to provide them some competitive advantages (table 1.8).

Table 1.8.Answers to the question: “How do you perceive the change of your

products’ competiveness after the EUTR was enforced,was it increased, decreased or no change since then?” (in %)

PERCEPTION OF COMPETITIVENESS

TOTALSIZE OF A COMPANY

SMALL SIZE MEDIUM SIZE LARGE SIZE

Increased 16 12 13 26

Decreased 5 10 0 4

No change 73 76 78 67

I do not know 5 2 9 4

29

Most of the respondents do not observe any serious changesin a number of clients caused by the EUTR enforcement(88 % of respondents see no change). Only 6% of respondents reported about some increase, 4 % in the contrary, decrease.

2/3 of companies (66 %) do not expect numbers of customers going down in the future, 16 % do not expect any increase. Expectations for income dynamics because of EUTR implementation are neutral: 56 % do not expect any changes, 22 % expect modest increase and 6 % — waiting for large increase.

Most of the companies do not experience high costs involved into establishing additional procedures, related to the EUTR. Almost a half of companies reported on no extra costs involved. 38 % experience some additional costs but they are not high and only 13% complain about radical increase of costs. As it was noted above, the most vulnerable is the middle size business (this segment had the highest rate of companies which reported about high costs — 22 %) (figure 1.15).

Figure 1.15. Perception of costs needed for implementation of EUTR requirements

Small size Medium size Large size

57

33

0

10

3539

22

4

4144

77

No changeSmall increaseConsiderable increaseI do not know

30

5. Information sources on the EUTR

90 % of companies report they know where detailed informationon the EUTR can be found. 23 % of companies said that they need additional information on the EUTR. Most of the companies need informational materials (76 %) and consultations (48 %). 25 % of respondents would like to participate in workshops and visits to EU.

6. Assurance in legality of products

Most of the respondents (87%) believe that all timber that is used for production of their products is harvested and transported following all requirements of the Russian legislation. This assurance is almost the same across sized of enterprises. However, it varies across

Figure 1.16. Key sources of information for companies willing to get additional information on the EUTR (% from companies reported the need for more information)

Informational materials

Consultations

Workshops and trainings

Study tours to the EU

Other

I do not know

48

76

29

24

10

5

31

the geographies — only 1/3 of companies in the Russian Far East are sure about legality of their products (table 1.9).

80 % of respondents are sure that no social interests (of employees and local communities) were damaged by timber harvesting, transportation and trade (table 1.10). The least sure were, again, companies based in the Russian Far East (33 % of companies there are sure in timber legality and 50 % are sure that no social interests were damaged by timber harvesting).

It is important to note, that only half of companies approached for the survey in the Russian Far East agreed to answer legality questions, in Irkutsk Region — 1/3 of companies refused to participate

TO

TAL


NO

RT

H-

WE

ST

SIB

ER

IA

SO

UT

HE

RN

TH

E

RU

SS

IAN

FA

R E

AS

T

SM

ALL

SIZ

E

ME

DIU

M

SIZ

E

LAR

GE

SIZ

E

Yes 87 95 90 75 33 88 83 93

No 8 2 10 17 33 10 4 4

I do not know 5 4 0 8 33 2 13 4

Table 1.9.Answers to the question “Are you, as a senior manager of

the company, sure that all timber your company purchases is produced with no breach to the Russian legislation, including forest legislation,

nature conservation legislation and trade legislation?” (in %)

32

in the survey (the average response rate was high — about 90 % of companies approached by surveyors agreed to participate in the research). This is an indirect indicator (proven by other studies8) that there are more legality problems in Southern Siberia and the Russian Far East, compared to other areas of Russia.

47 % of companies believe that EUTR requirements will contribute to tackling illegal logging and 42 % think that EUTR will have no effect on illegal logging (see Table 1.11). Companies provided a lot of comments to the question on EUTR’s effectiveness for tackling illegal logging. Many respondents said that the EUTR is not effective when timber is sold to the domestic market

TO

TAL


NO

RT

H-

WE

ST

SIB

ER

IA

SO

UT

HE

RN

TH

E

RU

SS

IAN

FA

R E

AS

T

SM

ALL

SIZ

E

ME

DIU

M

SIZ

E

LAR

GE

SIZ

E

Yes 80 84 90 67 33 76 74 89

No 11 7 5 17 50 14 17 0

I do not know 10 9 5 17 17 10 9 11

Table 1.10.“Are you, as a senior manager of the company, sure that all timber

your company purchases is produced with no breach to interests of local communities and employees?” (in %)

8 E. g. http://www.wwf.ru/resources/publ/book/eng/776

33

and in a case of small size businesses. There were comments that irresponsible businesses may easily switch their supply to domestic market of China. Among the comments on why the EUTR will not work against illegal logging were the following: “there are more papers now but nothing was changed in field and nothing would change in the future”, “there always have been illegal loggers around, but now they are merged with authorities and became a part of the mafia”.

PERCEPTION OF EUTR’S EFFECTIVENESS FOR TACKLING ILLEGAL LOGGING AND ILLEGAL TIMBER TRADE

TO

TAL

FEDERAL DISTRICT

NO

RT

H-

WE

ST

SIB

ER

IA

SO

UT

HE

RN

TH

E

RU

SS

IAN

FA

R E

AS

TEUTR will definitely result into decreasing of illegal logging

18 15 35 8 17

EUTR will possibly result into decreasing of illegal logging

29 33 15 33 33

EUTR will most possibly not result into decreasing of illegal logging

29 36 20 8 33

EUTR will definitely not result into decreasing of illegal logging

13 9 15 33 0

I do not know 11 7 15 17 17

Table 1.11.Answers to the question “What do you think, will EUTR help tackling

illegal logging and illegal timber trade?” (in %)

34

Resultsand recommendationsThe research proved that senior staff of the Russian forest sector companies is well aware of the EUTR’s approval. WWF with an input from the Lesexpert Consulting Company and under support from WWF-IKEA Partnership on Forests translated into Russia and published all documents of the EUTR, developed a detailed review of Russian applicable legislation9, published a detailed guidance for Russian timber suppliers in the context of the EUTR’s requirements10. WWF held several workshops and trainings (within the FLEG II (ENPI East) Program)11 to raise Russian forest sector’s (including companies, NGOs and other stakeholders) awareness of requirements of EUTR for companies which supply timber to the operators for the EU markets and their supplies which have to be compliant to applicable Russian legislation and have to be able to demonstrate this compliance. The workshops and trainings for forest sector companies were organized with an active participation of the GFTN Russia12, and those targeted at NGOs — with participation of the leading international NGOs, which are involved into monitoring of EUTR’s effectiveness13.

NEPCon, the first authorized monitoring organization (for all EU countries) and a champion in FSC certification in Russia has been

9 www.wwf.ru/euroreglament

10 http://www.wwf.ru/resources/publ/book/89611 http://wwf.ru/resources/news/article/1226612 http://www.wwf.ru/resources/news/article/1166813 http://www.wwf.ru/data/publ_period/forest_mag38/03.pdf

35

spreading information on EUTR requirements actively among its clients in 2013–2014.

Information on various aspects of the EUTR has been many times published in professional media. The results of the research clearly demonstrate that all these efforts had fruit some good results — almost all respondent were aware of the EUTR.

On the other hand the results suggest that even more than 1.5 year after the EUTR came into the full force its influence of practical aspects of timber legality in Russia is rather limited and need for more information on its requirements for the Russian forest sector is very high. 1/4 of respondents claim that they need additional information on EUTR requirements and are ready to participate in trainings and study publications.

Half of the respondents, representing companies supplying timber to operators working at the EU markets do not know much on the EUTR and its requirements and only 45 % of respondents believe that the EUTR are fully relevant to their business activities. That means that almost a half of companies are not planning any practical measures to improve timber legality flow to EU markets.

The results of the research prove opinions of many experts14 that EUTR enforcement for operators has not been very effective yet: many operators are either formal about their requirements for Russian suppliers or have no any additional requirements at all. According to the results of the research only 1/3 of the companies

14 For example, http://www.wwf.ru/data/publ_period/forest_mag38/03.pdf

36

exporting timber to EU markets have been approached by their EU counterparts about additional information on timber origin and legality in the context of the EUTR’s requirements and 1/2 of respondents believe that these queries are formal only. Additional information on timber origin and legality proof are necessary to operators to establish due diligence systems required by the EUTR.

The need for additional efforts to exclude illegal timber for custody chains in Russia is obvious. According to the results of the survey, many respondents openly admitted that they are not completely sure that all timber their companies purchase has been harvested in accordance to Russian applicable legislation and infringement of interests of local communities. Most problems occur in the Russian Far East — only 1/3 of companies which supply timber to EU markets (through Asia) claim that their products are completely legal. It is interesting to note that most of companies have been participating in the review quite eagerly (only 1/10 of companies refused to participate in the research in average), every second company has refused to participate in the research in the Russian Far East, in the Irkutsk Region — every third company. This may be an indirect indicator of high illegality risk in these regions, which has been proved by previous research15. We believe that uncertified timber supply chains from the Southern Siberia and from the Russian Far East are characterized by a high risk of illegality and legality issues have to be considered in a serious way if timber is supplied from these regions.

The results of the survey show that even some FSC certificate holders in the Russian Far East hesitated to guarantee full

15 For example, http://www.wwf.ru/resources/publ/book/eng/776

37

compliance of their products with the Russian applicable legislation. That means a precautious approach has to be taken for timber from this region. FSC certification quality in Russia still has to be improved this is opinion of both WWF and Greenpeace, specifically to improve timber harvesting sustainability. Saying that, NGOs are not aware of any proved cases of timer been harvested or traded in Russia in the breach of the approved legislation; ASI16, FSC and WWF have started to be very active to improve certification quality in Russia, a precautious approach has to be taken for timber from the Russian Far East and Siberia.

We are seriously concerned that 1/2 of respondents, including companies which have introduced due diligence systems report on formal character of quarries of their EU partners on timber legality issues. Only 1/4 of companies report that additional field checks are needed to comply the EUTR. However, the analysis of the Russian applicable legislation17, which was developed by WWF in 2013 demonstrates that in many cases it is difficult to prove the compliance to the applicable legislation on harvesting and nature conservation without field checks. We believe that field checks should be a part of an effective due diligence system.

Consequences of due diligence systems improvement and of more clear and detailed requirements for timber supply legality verification are more evident in the West compared to the East. However, in 2014 there was an increase of demand for services of monitoring

16 In 2014 г. the audit by ASI of one of Siberian logging companies resulted into suspension of Russian accreditation of Bureau Veritas, the international certification body http://www.wwf.ru/resources/news/article/1312217 www.wwf.ru/euroreglament

38

organizations not only in Western Europe countries, but also in Baltic States and countries of the Eastern Europe. In 2014 first field checks of Russian supplies were initiated by operators. 24 % of respondents noted increase in field checks after the EUTR was approved.

The one more trend revealed by the research — large Russian companies are more proactive to change their procurement policies in accordance to EUTR requirements. 28 % of large companies reported that they use services of monitoring organizations and 8 % are planning to do so and 28 % of large businesses did not know the answer and that may indicate the growth of the demand in the future. No medium size companies use services provided by monitoring organizations, however 36 % are considering that for the future.

The research revealed one serious alarming problem related to formal approach taken by many operators on checking timber legality. 1/3 of respondents reported about changes in timber legality procedures initiated by importers. From those above 60 % of both large and medium companies reported about formal approach taken by an importer for checking timber legality. Direct detailed interviews at the pilot stage of the research revealed that requirements vary from an operator to an operator largely: both level of details asked and number of required documents to prove the legality were very different. Most operators are asking just for copies of logging sites rent agreements and of forest declarations; however it should be noted that in most cases it is impossible to prove timber legality based on presence of these two papers only.

The research demonstrates correlation between queries from EU partners to their Russian suppliers in the context of EUTR

39

implementation and FSC certification. 32% of companies which had certified their products reported on additional queries from their EU partners. Only 5 % of not certified companies reported about additional queries. 29 % of certified companies reported about the need for additional field checks because of the EUTR implementation, compared to 14 % of not certified companies.

In the end of 2014 large companies started to consider combining annual FSC audits with auditing their legality systems and issuing a LegalSourceTM certificate which is provided by a monitoring company. That provides an opportunity for a Russian company to provide an operator just with one certificate (LegalSourceTM) instead of many papers.

However overall situation with implementation of EUTR’s requirements by operators working with Russia has to be further improved, specifically in terms of transparency of timber supply chains and results of the research prove this clearly. Ability to change the situation is in hands of operators and depends on procurement policies of importers sourcing timber and timber products from Russia and on their ability either to improve their legality systems or use tested, unified and approved standards developed by monitoring organizations.

The results of the research demonstrate that the level of awareness of the EUTR is high but there are some serious gaps in understanding the essence and details of EUTR’s requirements which are targeted at tackling illegal logging and illegal timber trade. Many stakeholders do not know how these measures could be implemented in practice. Saying that it is necessary to consider

40

that the EUTR is not applicable to the Russian companies directly but only through requirements set by their EU partners which are fully applicable to the requirements of the new European legislation. The EUTR is applicable in Russia through buyers of Russian timber and the longer a custody chain is the weaker is influence of the EUTR could be. In the context of this research this could be illustrated at the example of the companies working in the Russian Far East and the Irkutsk Region which supply timber to the EU market through Asian traders / processors. Russian companies are not legally obliged to introduce due diligence systems or any other schemes to control their custody chain without requests from operators. The research shows that in many cases these requests / requirements are missing or have a formal character, at least in the eyes of Russian companies. Nevertheless in the end of 2014 practical examples of effective work by monitoring organizations in Russia have appeared and this is an important signal for the Russian market18.

Assessments by WWF and other interested stakeholders show that requirements of EU competent authorities for their operators and of operators to their suppliers differ greatly from a country to a country. For example, the British operators are typically very detailed and consistent in their requirements to follow EUTR, when legality tracking could be formal or absent in requirements of operators from other countries. If any follow up research are organized, it would be important to identify EU countries where Russian companies supply timber to. This would help to get a more

15 As an example, NEPCon worked with one of the largest importers of timber from Russia and identified problems with timber legality with its two Siberian suppliers resulted in termination of contracts with them.

41

clear picture of EUTR implementation across the EU and could be possibly result into actions to implement the EUTR in a more consistent and unified way across operators and EU countries.

The results of the research could be of interest to Russian forest management authorities and other Russian stakeholders as well as to the Commission, competent authorities, monitoring organizations and international NGOs. It is planned to provide informational assistance for interested Russian companies to help them to adapt their operations to the EUTR requirements and establish sound timber origin/legality tracking systems. Informational assistance is necessary to small business – awareness level in this segment is twice as low compared to the one of medium and large enterprises. Also, medium size businesses need informational support, too. Enterprises of this segment reported that investments required to follow the EUTR’s requirements are high for them.

The research has also revealed some aspects and trends important for various stakeholders not only in the context of the EUTR. For example, revealed legality gaps may be used to improve the Russian National FSC Standard. Information shared by respondents on their perceptions of timber legality in different regions of Russia is very interesting and appears to be a quite accurate reflection of the reality. An additional research and analysis of this aspect would be of interest as well as of different sources of information on EUTR and its requirements. For the future research it would be helpful to stratify companies not only for their size and regions of location but also for the products they are producing and sell to the EU. This would help to share further awareness raising activities to be more effective.

42

We believe the following recommendations could be useful for the interested stakeholder to follow up the resultsof this research:

1. Continue awareness rasing of Russian logging and timber trade companies on EUTR and its requirements. 1.1. Develop and widely spread awareness raising materials on EUTR and its requirements. Lessons learned by monitoring organizations though their interactions with operators should be used. 1.2. Include information on EUTR into the trainings and other educational activities targeted on consultants helping companies to get prepared for FSC certification. Monitoring organizations should be involved into development of these materials. 1.3. Continue organizing trainings, workshops and awareness rasing events on the EUTR. It would be important to have these events in the agenda of Russian-wide and regional forest fora, exhibitions and other sectoral events. It would be important to get federal and regional authorities involved into these events; invite representatives of European stakeholders with an experience with the EUTR, including competent authorities, professional associations, operators, monitoring organizations and NGOs.1.4. Suggest GFTN Russia to organize a workshop on practical aspects of EUTR implementation for CEOs of Russian timber export companies.1.5. Suggest Russian and international NGOs to be more active in spreading good practices on timber legality

43

monitoring exercised by Russian forest sector companies in the context of the EUTR requirements.

2. Pay special attention to the problem of illegal logging and on quality of FSC certification in Siberia and the Russian Far East.2.1. Suggest FSC to pay additional attention for certification and regular audits in Siberia and the Russian Far East. Suggest NGOs to pay more attention for monitoring of certified companies’ activities in these regions. 2.2. Suggest Russian timber importers and monitoring organizations to pay additional attention on timber legality monitoring in Siberia and the Russian Far East. 2.3. WWF Russia and other interested stakeholders should work more to raise awareness of illegal loggings in Siberia and the Russian Far East in mass media. 2.4. Ensure effective interactions of NGOs with federal and regional authorities and law enforcement agencies to coordinate actions and develop tools to tackle the problem of illegal logging in Siberia and the Russian Far East. 2.5. Suggest monitoring organizations develop less bureaucratic and less costly timber legality standards for small businesses and for larger companies’ suppliers. Large and medium size companies which involve subcontractors should apply these timber legality standards and make them obligatory for all their suppliers.

44

3. Organize the follow up research on the Russian forest sector’s awareness of the EUTR in 2016 to measure progress. Lessons learned by this research should be fully applied to improve the methodology: questions used for the survey should be adjusted as well as methods for selection and stratification of respondents, more time should be allocated for the research, the results should be presented having the grouping by types of products produced in mind.

45

Annex 1.List of survey questions

S1. Does your company supply (directly or through a supply chain) products for export? If yes, does your company supply to the countries of the European Union? Does your company supply to China?

1. How many people are working at you enterprise?

2. What is the average annual turnover of your company?

3. What is the average volume(s) of production of a key product(s) by your company?

4. What is the organizational form of your enterprise?

5. Are there international investments in your company? If yes, are there investments coming from the countries of the European Union? Are there investments coming from China?

6. What is the average share of export in the total production of your company?

7. What is the average share of FSC certified and/or FSC controlled wood in the export by your company?

46

8. Is your company planning to obtain/prolong FSC certification?

9. Are you aware of the European Union Timber Regulation 995/2010 that was enforced march 3, 2013?

10. Is this regulation applicable to your company?

11. Were there any changes at your company related to enforcement of the EUTR? If yes, how considerable have been these changes?11a. If yes, please comment on a character of these changes.

12. Do you expect any changes for your company in the future?12a. If yes, when do you expect these changes to happen?12b. Were these changes minimal, considerable or principle?

13. Has a due diligence system been introduced at your company? Are there plans to get it introduced?

14. Who was (or will be) responsible for introduction of the due diligence system?

15. Are you aware of the role of monitoring organizations? What are they needed for?

16. Does your company cooperate with monitoring organizations or plan to cooperate?

17. Do you think FSC certificate is enough to fulfill requirements of the EUTR?

47

18. Were there any changes in your clients’ requirements for your products?18a. If yes, where these changes just about strengthening documentation or were there any other new procedures introduced?

19. Have the clients’ requirements for sales documentation been changed last year?

20. “Were there additional requirements for the products quality and labeling introduced by clients since the last year?”

21. Was there need for additional checks of timber suppliers to be introduced at your company?21a. Was there need for additional field checks of timber suppliers to be introduced at your company?

22. Do you perceive the EUTR as a threat to your business?

23. Do you see benefits of the EUTR for your business?

24. How do you perceive the change of your products’ competiveness after the EUTR had been enforced, was it increased, decreased or no change since then?

25. Are there extra costs for your business associated with enforcement of the EUTR?

26. Do you expect in future extra costs for your business associated with enforcement of the EUTR?

48

27. Is there increase in paperwork at your company because of enforcement of the EUTR?

28. Has the number of your clients changed because of the EUTR?

29. Do you expect a change in the number of your clients because of the EUTR?

30. Do you expect to receive more income if your company follows the EUTR requirements?

31. Has enforcement of the EUTR changed (or will change in the future) plans for company’s production modernization?31a. How has it changed plans for company’s production modernization?

32. Do you know where to get detailed information on the EUTR?

33. Do you need additional information on the EUTR?33a. How would you like to get it?

34. Are you, as a senior manager of the company, sure that all timber your company purchases is produced with no breach to the Russian legislation, including forest legislation, nature conservation legislation and trade legislation?

35. Are you, as a senior manager of the company, sure that all timber your company purchases is produced with no breach to interests of local communities and employees?

49

36. Are you aware of any examples of enforcement of sanctions for operators not following the EUTR’s requirements?

37. Do you find sanctions for not following the EUTR’s requirements not sufficient, sufficient or excessive?

38. What do you think, will EUTR help tackling illegal logging and illegal timber trade, or will not be able to influence illegal logging and illegal timber trade?38a. Why do you think it will not contribute to tackling illegal logging and illegal timber trade?

39. Please provide any additional comments.

50

Annex 2.WWF-Russia’s Guidancefor Operators and Competent Authoritieson Applicable Legislation of the Russian Federationfor EU Timber Regulation

Regulation (EU) No. 995/2010 of the European Parliament andof the Council of 20 October, 2010 laying down the obligations of operators who place timber and timber products on the market came into effect across the EU on 3 March, 2013. The EU Timber Regulation (EUTR) lays down obligations on ‘operators’(i. e. companies who put timber or timber products on the EU market for the first time) to introduce a due diligence system to evaluate the risks of timber harvested in breach of applicable legislation of a country of harvest or timber products derived from such timber being placed on the market and to minimize these risks. Penalties for breaching the EUTR are responsibility of the EU Member States and can include administrative and criminal sanctions, imprisonment,

This guidance document has been developed by WWF-Russia in a collaborative process with the forest industry, certification agencies and NGOs as a support tool regarding the implementation of due diligence requirements of the EU Timber Regulation from a Russian perspective. It describes the applicable legislation of the Russian Federation — the list of applicable legal acts, means of verification, description of typical violations and brief recommendations for operators.

51

seizure of timber or timber products and suspensionof the authorization to trade.

One of the key concepts of the EUTR is “applicable legislation”. To define “applicable legislation” the EUTR refers to the national legislation of the country in which the timber was harvested. According to the EUTR, applicable legislation means the legislation in the country of harvest that covers the following aspects:

• 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, and• trade and customs, in so far as the forest sector is concerned.

The described approach to define “illegality” has many strengths. At the same time, it creates some challenges for operators to comply with the new law, One of the difficulties is defining the applicable legislation at national level. Stakeholders may find it difficult to define applicable legislation in Russia mainly because of language barriers, constant changes in legislation, diverse and wide-scale legislation on forest, environment, taxes, indigenous peoples, trade and customs, and contradictions between some legislative acts.

With support from the Global Forest and Trade Network (GFTN)

52

and TRAFFIC, and in collaboration with “Lesexpert”, WWF Russia developed criteria and indicators for the Framework for Assessing Legality of Timber Harvesting, Processing and Tradefor the Russian Federation. With support from WWF-IKEA Partnerships for Forests, these criteria and indicators were compared to EUTR requirements for timber legality to provide guidance for operators. This guidance document includes a list of applicable legislation and verification means, descriptions of the most common violations, risk assessments and some general risk mitigation measures. The guidance document was developed to:

• specify the legal requirements for Russian timber exporters and their suppliers in the context of European regulations• develop a practical tool to control timber legality by interested stakeholders in the EU and Russia, and• to allow for effective monitoring of changes in the Russian applicable legislation.

The risk of violation of applicable legislation (e. g. absence or falsification of verification documents, data discrepancies, etc.) in Russia is different for various laws and regulations listed. The risk was ranked based on opinion of experts involved into development of this document. A ‘low’ risk of violation corresponds to a probability of 3–5 % or less, while any higher risk is considered to be ‘uncertain’.

The guidance on applicable legislation was developed by Nikolay Shmatkov (WWF Russia) and Anatoliy Kuritzin and Alexey Kuritzin (“Lesexpert”), with contributions being made by Yulia Dolinina, Ekaterina Khmeleva, Konstantin Kobyakov, Elena Kopylova and Elena Kulikova (WWF Russia), Anke Schulmeister (WWF EPO)

53

and Evgeny Parshukov (Certification Association “Russian Register”). The guidance document draft was discussed at a roundtable meeting held at the VI Conference of the FSC National Working Group in Zvenigorod (Moscow Region) on 9 April, 2013 and revised according to feedback received from participants. The document was peer-reviewed by Alexander Arbachakov (Agency for Research and Protection of Taiga (AIST) in Kemerovo Province), Oleg Konyshatov (“Forest Certification” company) and Denis Popov (Mondi Syktyvkar) and again revised following comments that were provided. The document will again be updated when lessons learnt with regard to its practical application and law enforcement practice are gathered together and new legislation is developed.

This document reflects the knowledge, understanding and analysis of the information available on the EUTR by WWF and the other organizations involvedin the development of the is document. The informationin this document can neither be seen as exhaustive or describing the status quo from a legal perspective nor providing any information pre-empting court cases or other juridical decisions.

!

54

CATEGORY OFAPPLICABLE LEGISLATION

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vise

d ve

rsio

n of

23

Apr

il 20

12)

• S

ub

con

trac

tor’

s A

gre

em

en

t fo

r L

og

gin

g

of th

e F

eder

al F

ores

try

Age

ncy

(rev

ised

ver

sion

of

23

Apr

il 20

12).

Po

ten

tial

ris

k:M

ost v

iola

tions

occ

ur w

hen

timbe

r is

har

vest

ed o

utsi

de

the

offic

ially

del

inea

ted

boun

darie

s of

legi

timat

e fe

lling

are

as, o

r ex

ceed

s ap

prov

ed v

olum

es, a

nd/

or is

of s

peci

es th

at a

re

unau

thor

ized

for

harv

est

(i. e

. diff

eren

t fro

m th

ose

liste

d in

a s

ale

agre

emen

t).

Re

com

me

nd

ed

mit

igat

ion

m

eas

ure

s:S

elec

tive

field

aud

its

are

reco

mm

ende

d as

a

verif

icat

ion

mea

sure

Fo

rest

are

a le

ase

ho

lde

rs,

log

gin

g

com

pan

ies

The

For

est C

ode

of th

e R

ussi

an

Fed

erat

ion

No.

200

-FZ

of

4 D

ecem

ber

2006

(r

evis

ed v

ersi

onof

28

July

201

2).

“Con

tent

of t

he F

ores

t D

evel

opm

ent P

roje

ct

and

Pro

cedu

re fo

r its

Dev

elop

men

t”.

App

rove

d by

the

Ord

er

of th

e F

eder

al F

ores

try

Age

ncy

No.

69

of 2

9 F

ebru

ary

2012

.

“Pro

cedu

re fo

r S

tate

or

Mun

icip

al E

xper

tise

of

the

For

est D

evel

opm

ent

Pro

ject

”. A

ppro

ved

by

the

orde

r of

the

Fed

eral

Ver

ify th

at a

fore

st

man

agem

ent /

lo

ggin

g co

mpa

ny

has

a va

lid F

ore

st

De

velo

pm

en

t P

roje

ct a

ppro

ved

by s

tate

or

mun

icip

al e

xper

tise

Unc

erta

in

56


APPLICABLE ENTITY



COMMENTS


For

estr

y A

genc

y N

o. 5

45 o

f 22

Dec

embe

r 20

11

(2)

Pay

me

nts

fo

r h

arve

st

rig

hts

an

d

tim

be

r

Pu

rch

ase

rso

f fo

rest

st

and

s,

fore

st a

reas

le

ase

ho

lde

rs,

log

gin

g

com

pan

ies

“On

Sta

te R

egis

trat

ion

of L

egal

Ent

ities

and

In

divi

dual

Pro

prie

tors

”.

Fed

eral

Law

No.

129

-FZ

of 8

Aug

ust

2001

(re

vise

d ve

rsio

n of

28

July

201

2)

Ver

ify th

at a

n or

gani

zatio

n or

an

indi

vidu

al

prop

rieto

r ha

s a

stat

e re

gist

ratio

n as

a le

gal e

ntity

, na

mel

y:•

Pro

of

of

Sta

te

Re

gis

trat

ion

as

a L

eg

al E

nti

ty•

Pro

of

of

Sta

te

Re

gis

trat

ion

of

a P

hys

ical

E

nti

ty a

s an

In

div

idu

al

Pro

pri

eto

r

All

entit

ies

with

in a

cha

in

of c

usto

dy (

until

the

expo

rter

) ha

ve to

be

offic

ially

re

gist

ered

.

Po

ten

tial

ris

k:M

ost v

iola

tions

occ

ur w

hen

som

e in

term

edia

ries

do n

ot

have

off

icia

l reg

istr

atio

n.

Re

com

me

nd

ed

mit

igat

ion

m

eas

ure

s:C

ontr

ol o

f a c

ompl

ete

cust

ody

chai

n is

re

com

men

ded

Unc

erta

in

All

app

liab

le

en

titi

es

The

Tax

Cod

e of

the

Rus

sian

Fed

erat

ion

(Fed

eral

Law

No.

46-

FZ

of

31

July

199

8 (r

evis

ed

vers

ion

of 2

8 Ju

ly 2

012)

Ve

rify

th

at a

n

org

aniz

atio

n o

r an

ind

ivid

ual

p

rop

rie

tor

has

P

roof

of S

tate

R

egis

trat

ion

with

a

Tax

Off

ice

A p

roof

of r

egis

trat

ion

is r

equi

red

for

all e

ntiti

es

in a

tim

ber

expo

rt c

usto

dy

chai

n.

Po

ten

tial

ris

k:M

ost v

iola

tions

occ

ur w

ith

inte

rmed

iarie

s th

at a

re n

ot

offic

ially

reg

iste

red

with

a ta

x of

fice.

Unc

erta

in

57R

eco

mm

en

de

d m

itig

atio

n

me

asu

res:

Con

trol

of a

com

plet

e cu

stod

y ch

ain

is

reco

mm

ende

d

All

com

pan

ies

“On

Insu

ranc

e P

aym

ents

to

the

Ret

irem

ent

Fun

d of

the

Rus

sian

F

eder

atio

n, th

e S

ocia

l Ins

uran

ce

Fun

d of

the

Rus

sian

F

eder

atio

n, th

e F

eder

al

Fun

d fo

r O

blig

ator

y M

edic

al In

sura

nce”

. F

eder

al L

awN

o. 2

12-F

Z o

f 24

July

20

09 (

revi

sed

vers

ion

of 2

9 F

ebru

ary

2012

)

Ver

ify th

at a

n or

gani

zatio

n ha

s do

cum

enta

ry

evid

ence

of

paym

ent f

or a

ll re

quire

d in

sura

nce

fees

for

wor

kers

to

the

Ret

irem

ent

Fun

d of

the

Rus

sian

F

eder

atio

n, s

ocia

l se

curit

y fu

nds

and

the

Fed

eral

O

blig

ator

y M

edic

al

Insu

ranc

e F

und.

Pro

ofs

of

Pay

me

nt

for

requ

ired

paym

ents

to

the

Ret

irem

ent

Fun

d of

the

Rus

sian

F

eder

atio

n, s

ocia

l se

curit

y an

d m

edic

al in

sura

nce

fund

s

Pay

men

ts m

ade

shou

ld b

e co

nsis

tent

with

the

Fed

eral

La

w N

o. 2

12-F

Z o

f 24

July

20

09.

Po

ten

tial

ris

k:M

ost v

iola

tions

occ

ur w

hen

som

e in

term

edia

ries

do

not m

ake

the

nece

ssar

y pa

ymen

ts.

Re

com

me

nd

ed

mit

igat

ion

m

eas

ure

s: C

ontr

ol o

f a

com

plet

e cu

stod

y ch

ain

is

reco

mm

ende

d

Unc

erta

in

Fo

rest

are

a le

ase

ho

lde

rs,

log

gin

g

com

pan

ies

The

For

est C

ode

of th

e R

ussi

an

Fed

erat

ion

No.

200

-FZ

of

4 D

ecem

ber

2006

(r

evis

ed v

ersi

onof

28

July

201

2).

Inst

ruct

ion

of

the

Cen

tral

Ban

k of

the

Rus

sian

Fed

erat

ion

Ver

ify th

at a

n en

tity

that

use

s a

fore

st a

rea

for

logg

ing

pays

for

logg

ing

in a

tim

ely

man

ner

and

is

able

to p

rese

nt

a va

lid P

aym

en

t O

rde

r fo

r L

og

gin

g

Pe

rmis

sio

n.

Low

58


APPLICABLE ENTITY



COMMENTS


No.

978

-u o

f 15

June

20

01 “

On

Ord

er

of L

egal

Act

s an

d O

ther

D

ocum

ents

of t

he B

ank

of R

ussi

a”

It is

pos

sibl

e to

ver

ify w

heth

er

or n

ot lo

ggin

g pa

ymen

ts h

ave

been

mad

e on

the

Fed

eral

F

ores

try

Age

ncy

and

the

Min

istr

y of

Indu

stry

and

Tr

ade

web

site

s

(3)

Tim

be

r h

arve

stin

g

Fo

rest

are

a le

ase

ho

lde

rs,

log

gin

g

com

pan

ies

The

For

est C

ode

of th

e R

ussi

an F

eder

atio

nN

o. 2

00-F

Z

of 4

Dec

embe

r 20

06

(rev

ised

ver

sion

of

28

July

201

2).

“Con

tent

of a

For

est

Dev

elop

men

t Pro

ject

an

d In

stru

ctio

ns fo

r its

Dev

elop

men

t”.

App

rove

d by

th

e F

eder

al F

ores

try

Age

ncy

No.

69

of 2

9 F

ebru

ary

2012

.

“Inf

orm

atio

n on

P

rese

nce

of R

are

and

End

ange

red

Spe

cies

of

Tree

s, S

hrub

s, L

iana

s an

d O

ther

“IF

ores

t

Ver

ify th

at a

For

est

Dev

elop

men

t P

roje

ct in

clud

es

the

Ann

ex w

ith

Info

rmat

ion

on

P

rese

nce

of

Rar

e an

d E

nd

ang

ere

d

Sp

eci

es

of

Tre

es,

S

hru

bs,

Lia

nas

an

d O

the

r F

ore

st

Pla

nts

and

that

no

logg

ing

and/

or

fore

st in

fras

truc

ture

de

velo

pmen

t is

taki

ng p

lace

in

area

s de

sign

ated

as

hab

itats

for

rare

an

d en

dang

ered

sp

ecie

s

Po

ten

tial

ris

k:O

ften

info

rmat

ion

on r

are

and

enda

nger

ed s

peci

es

is n

ot in

clud

ed in

For

est

Dev

elop

men

t Pro

ject

s.

Mor

eove

r, w

hen

info

rmat

ion

on r

are

and

enda

nger

ed

spec

ies

is in

clud

ed in

to

a F

ores

t Dev

elop

men

t P

roje

ct, i

t is

impo

rtan

t to

che

ck th

at th

ese

habi

tats

ar

e in

deed

pre

serv

ed a

nd

that

no

logg

ing

or b

uild

ing

of r

oads

is ta

king

pla

ce

ther

e.

Re

com

me

nd

ed

mit

igat

ion

m

eas

ure

s:S

elec

tive

field

aud

its

are

reco

mm

ende

d as

a

verif

icat

ion

mea

sure

Unc

erta

in

59P

lant

s”. A

nnex

6

to a

sam

ple

For

est

Dev

elop

men

t Pro

ject

The

For

est C

ode

of th

e R

ussi

an

Fed

erat

ion

No.

200

-FZ

of

4 D

ecem

ber

2006

(r

evis

ed v

ersi

onof

28

July

201

2).

Tim

ber

Har

vest

ing

Rul

es. A

ppro

ved

by th

e O

rder

No.

337

of

the

Fed

eral

For

estr

y A

genc

y of

1 A

ugus

t 20

11.

The

Ord

erof

the

Fed

eral

For

estr

y A

genc

y N

o. 1

26of

4 A

pril

2012

“O

n A

ppro

val o

f the

C

onte

nt o

f For

estr

y R

egul

atio

ns, G

uide

lines

fo

r T

heir

Dev

elop

men

t, V

alid

Dat

es a

nd

Am

endm

ent P

roce

dure

”

In c

ases

whe

re

a F

ore

stry

R

eg

ula

tio

n

con

tain

s a

list

of

bio

div

ers

ity

con

serv

atio

n

ob

ject

s an

d s

ize

s o

f b

uff

er

zon

es

dete

rmin

ed b

y th

e T

imbe

r H

arve

stin

g R

ules

(pa

ragr

aph

17),

it is

impo

rtan

t to

ver

ify th

at

a lo

ggin

g en

tity

follo

ws

the

requ

irem

ents

an

d th

at ti

mbe

r is

no

t log

ged

in th

ose

area

s de

sign

ated

fo

r bi

odiv

ersi

ty

cons

erva

tion

and

whe

re lo

ggin

g is

forb

idde

n an

d th

at lo

ggin

g ac

tiviti

es ta

ke

plac

e in

thos

e se

ason

s w

hen

timbe

r ha

rves

ting

is p

erm

itted

Po

ten

tial

ris

k:O

ften

a F

ores

try

Reg

ulat

ion

does

not

hav

e a

solid

list

of

bio

dive

rsity

con

serv

atio

n ob

ject

s w

hich

wou

ld b

e ad

equa

te to

intr

oduc

e ne

cess

ary

cons

erva

tion

mea

sure

s.

Re

com

me

nd

ed

mit

igat

ion

m

eas

ure

s:W

hen

spec

ific

fore

st

area

s ar

e de

sign

ated

for

biod

iver

sity

con

serv

atio

n by

a F

ores

try

Reg

ulat

ion

and

spec

ific

fore

st

man

agem

ent r

equi

rem

ents

ar

e de

velo

ped

for

them

(in

clud

ing

com

plet

e or

se

ason

al li

mita

tions

on

logg

ing)

, ver

ifica

tion

shou

ld in

clud

e th

e co

mpa

rison

of f

ellin

g ar

eas

iden

tifie

d in

a F

ores

try

Reg

ulat

ion

and

thos

e lis

ted

in a

For

est D

ecla

ratio

n or

a F

ores

t Sta

nds

Sal

e A

gree

men

t.

Whe

n a

For

estr

y R

egul

atio

n on

ly d

escr

ibes

a m

etho

d fo

r id

entif

ying

bio

dive

rsity

co

nser

vatio

n ar

eas

durin

g th

e al

loca

tion

of fe

lling

ar

eas

it is

rec

omm

ende

d th

at s

elec

tive

field

che

cks

are

unde

rtak

en to

ver

ify th

at

biod

iver

sity

con

serv

atio

n ar

eas

rem

ain

undi

stur

bed

Unc

erta

in

60


APPLICABLE ENTITY



COMMENTS


The

For

est C

ode

of th

e R

ussi

an

Fed

erat

ion

No.

200

-FZ

of

4 D

ecem

ber

2006

(r

evis

ed v

ersi

onof

28

July

201

2).

“Gui

delin

es fo

r D

evel

opm

ent a

nd

Sub

mis

sion

of a

F

ores

t Dec

lara

tion

and

a S

ampl

e F

orm

for

a F

ores

t D

ecla

ratio

n”. A

ppro

ved

by th

e O

rder

of t

he

Fed

eral

For

est A

genc

y N

o. 1

8of

17

Janu

ary

2012

.

The

Ord

er o

f the

F

eder

al F

ores

try

Age

ncy

No.

126

of

4 A

pril

2012

“O

n A

ppro

val

of th

e C

onte

nt o

f F

ores

try

Reg

ulat

ions

, G

uide

lines

for

The

ir D

evel

opm

ent,

Val

id

Dat

es a

nd A

men

dmen

t P

roce

dure

”

Ver

ify th

at a

lo

ggin

g en

tity

whi

ch h

as

a F

ores

t Are

a R

ent A

gree

men

t ha

s a

valid

Fo

rest

D

ecl

arat

ion

ap

prov

ed b

y fo

rest

m

anag

emen

t au

thor

ities

and

ch

eck

if th

e F

ores

t Dec

lara

tion

is c

onsi

sten

t with

ap

prov

ed t

ypes

of

fore

st u

se s

et

by a

For

estr

y R

egul

atio

n

Po

ten

tial

ris

k:O

ften

har

vest

ed s

peci

es a

nd

volu

mes

are

not

con

sist

ent

with

a F

ores

t Dec

lara

tion.

Re

com

me

nd

ed

mit

igat

ion

m

eas

ure

s:S

elec

tive

field

aud

its a

re

reco

mm

ende

d to

ver

ify if

the

plac

e of

har

vest

, ex

trac

ted

volu

mes

and

sp

ecie

s co

mpo

sitio

n ar

e co

nsis

tent

with

thos

e de

clar

ed in

a F

ores

t D

ecla

ratio

n

Unc

erta

in

61T

he F

ores

t Cod

eof

the

Rus

sian

F

eder

atio

n N

o. 2

00-F

Z

of 4

Dec

embe

r 20

06

(rev

ised

ver

sion

of 2

8 Ju

ly 2

012)

.

Tim

ber

Har

vest

ing

Rul

es (

para

grap

h 53

).

App

rove

d by

the

Ord

er

No.

337

of t

he F

eder

al

For

estr

y A

genc

yof

1 A

ugus

t 201

1

Ver

ify th

at a

lo

ggin

g en

tity

has

deve

lope

d an

d fo

llow

s th

e re

quire

men

ts o

f a

Te

chn

olo

gic

al

Lo

gg

ing

Map

fo

r a

Fe

llin

g A

rea

that

is d

evel

oped

in

acc

orda

nce

with

the

Tim

ber

Har

vest

ing

Rul

es, F

ores

try

Reg

ulat

ions

an

d a

For

est

Dev

elop

men

t P

roje

ct (

whe

n th

ere

is a

val

id R

ent

Agr

eem

ent)

Po

ten

tial

ris

k:O

ften

Vio

latio

ns o

ften

occ

ur

whe

n lo

ggin

g do

es n

ot

follo

w a

Tec

hnol

ogic

al M

ap.

For

exa

mpl

e, th

e ac

tual

ha

rves

ted

timbe

r vo

lum

e is

hi

gher

than

per

mitt

ed a

nd/

or lo

ggin

g is

und

erta

ken

outs

ide

of d

esig

nate

d bo

unda

ries

and/

or fo

rest

re

gene

ratio

n m

easu

res

are

not i

mpl

emen

ted.

Re

com

me

nd

ed

mit

igat

ion

m

eas

ure

s:S

elec

tive

field

aud

its

are

reco

mm

ende

d as

a

verif

icat

ion

mea

sure

Unc

erta

in

The

For

est C

ode

of th

e R

ussi

an

Fed

erat

ion

No.

200

-FZ

of

4 D

ecem

ber

2006

(r

evis

ed v

ersi

onof

28

July

201

2).

List

of T

ree

and

Shr

ub

Spe

cies

for

whi

ch

Tim

ber

Har

vest

ing

is n

ot A

llow

ed.

App

rove

d by

the

orde

rof

the

Fed

eral

For

estr

y A

genc

y N

o. 5

13of

5 D

ecem

ber

2011

Ver

ify th

at n

o lo

ggin

g oc

curr

ed

of a

ny s

peci

es

incl

uded

in th

e L

ist

of

Tre

e a

nd

S

hru

b S

pe

cie

s fo

r w

hic

h T

imb

er

Har

vest

ing

is N

ot

Pe

rmit

ted

Po

ten

tial

ris

k:Lo

ggin

g of

spe

cies

incl

uded

in

the

List

of T

ree

and

Shr

ub

Spe

cies

for

whi

ch T

imbe

r H

arve

stin

g is

Not

Allo

wed

of

ten

occu

rs.

Re

com

me

nd

ed

mit

igat

ion

m

eas

ure

s:In

ord

er to

che

ck w

heth

er

or n

ot ti

mbe

r fr

om fo

rbid

den

tree

spe

cies

is s

hipp

ed a

nd

sele

ctiv

e fie

ld a

udits

are

re

com

men

ded

Unc

erta

in

The

Fed

eral

Law

No.

7-F

Z o

f 10

Janu

ary

2002

“O

n E

nviro

nmen

t C

onse

rvat

ion”

.

The

Gov

ernm

ent

Res

olut

ion

No.

158

Ver

ify th

at n

o lo

ggin

g of

tree

s an

d sh

rubs

list

ed in

th

e R

ed D

ata

Boo

k of

the

Rus

sian

F

eder

atio

n an

d/or

R

ed D

ata

Boo

ks

Per

mis

sion

for

Col

lect

ion

of A

nim

al a

nd P

lant

S

peci

es L

iste

d in

the

Red

D

ata

Boo

k of

the

Rus

sian

F

eder

atio

n co

uld

be is

sued

by

the

Fed

eral

Sup

ervi

sory

N

atur

al R

esou

rces

Unc

erta

in

62


APPLICABLE ENTITY



COMMENTS


of 1

9 F

ebru

ary

1996

of

the

Gov

ernm

ent o

f th

e R

ussi

an F

eder

atio

n“O

n th

e R

ed D

ata

Boo

k of

the

Rus

sian

F

eder

atio

n”.

The

Ord

er N

o. 1

23

of 3

0 A

pril

2009

of

the

Min

istr

y of

N

atur

al R

esou

rces

an

d E

nviro

nmen

t “O

n A

ppro

val o

f th

e A

dmin

istr

ativ

e R

egul

atio

n fo

r th

e F

eder

al S

uper

viso

ry

Nat

ural

Res

ourc

es

Man

agem

ent S

ervi

ce

on A

ccom

plis

hmen

t of

the

Sta

te S

ervi

ce

on Is

suin

g P

erm

issi

ons

for

Col

lect

ion

of A

nim

al

and

Pla

nt S

peci

es

List

ed in

the

Red

Dat

a B

ook

of th

e R

ussi

an

Fed

erat

ion”

.

Ord

ers

of r

egio

nal

auth

oriti

es o

n re

gion

al

red

data

boo

ks a

nd

red

lists

and

on

perm

issi

ons

for

(Lis

ts)

of r

elev

ant

subj

ects

of th

e R

ussi

an

Fed

erat

ion

occu

rs.

Als

o, it

is im

port

ant

to c

heck

if lo

ggin

g an

d/or

fore

st

infr

astr

uctu

re

deve

lopm

ent

dest

roys

hab

itats

of

red

list

ed

plan

ts, a

nim

als

and

othe

r sp

ecie

s,

or if

a lo

ggin

g en

tity

poss

esse

s an

d fo

llow

s th

e re

quire

men

ts

of a

Pe

rmis

sio

n

for

Co

llect

ion

of

An

imal

an

d P

lan

t S

pe

cie

s L

iste

din

th

e R

ed

D

ata

Bo

ok

of

the

Ru

ssia

n

Fe

de

rati

on

an

d/

or

the

Re

d D

ata

Bo

ok

of

a S

ub

ject

o

f th

e R

uss

ian

F

ed

era

tio

n

Man

agem

ent S

ervi

ce

of th

e M

inis

try

of N

atur

al

Res

ourc

es a

nd E

nviro

nmen

t.

Po

ten

tial

ris

k:re

d lis

ted

spec

ies

are

ofte

n ha

rves

ted

with

out

perm

issi

on.

Vio

latio

ns o

ften

occ

ur w

hen

logg

ing

dest

roys

the

habi

tats

of

red

list

ed p

lant

s an

d an

imal

s.

Re

com

me

nd

ed

mit

igat

ion

m

eas

ure

s:It

is th

eref

ore

nece

ssar

y to

che

ck th

at n

o fo

rbid

den

timbe

r is

shi

pped

.S

elec

tive

field

aud

its

are

reco

mm

ende

d as

a

verif

icat

ion

mea

sure

63co

llect

ion

of r

ed li

sted

sp

ecie

s

The

For

est C

ode

of th

e R

ussi

an F

eder

atio

n N

o. 2

00-F

Z o

f4

Dec

embe

r 20

06

(rev

ised

ver

sion

of 2

8 Ju

ly 2

012)

.

Rul

es fo

r U

seof

For

ests

for

Bui

ldin

g,

Rec

onst

ruct

ion

and

Mai

nten

ance

of L

inea

r In

fras

truc

ture

Obj

ects

ap

prov

ed b

y th

e O

rder

of

the

Fed

eral

For

estr

y A

genc

y N

o. 2

23of

10

June

201

1.

“Con

tent

of a

For

est

Dev

elop

men

t Pro

ject

an

d a

Pro

cedu

re fo

r its

Dev

elop

men

t”.

App

rove

d by

the

Ord

er

No.

69

of th

e F

eder

al

For

estr

y A

genc

yof

29

Feb

ruar

y 20

12

For

est r

oads

, br

idge

s an

d ot

her

fore

st in

fras

truc

ture

bu

ilt b

y th

e co

mpa

ny h

ave

to

com

ply

with

off

icia

l gu

idel

ines

and

re

quire

men

ts s

et

by th

e •

Ru

les

for

Use

of

Fo

rest

s fo

r B

uild

ing

, R

eco

nst

ruct

ion

an

d M

ain

ten

ance

o

f L

ine

ar

Infr

astr

uct

ure

O

bje

cts

and

be r

efle

cted

in

a•

Fo

rest

D

eve

lop

me

nt

Pro

ject

Po

ten

tial

ris

k:V

iola

tions

oft

en o

ccur

w

hen

road

s ar

e bu

ilt

acro

ss o

r ne

ar to

str

eam

s,

river

s an

d la

kes

and

thei

r co

nstr

uctio

n an

d us

e do

not

follo

w a

ppro

ved

requ

irem

ents

.

Re

com

me

nd

ed

mit

igat

ion

m

eas

ure

s:S

elec

tive

field

aud

its

are

reco

mm

ende

d as

av

erifi

catio

n m

easu

re

Unc

erta

in

The

For

est C

ode

of th

e R

ussi

an

Fed

erat

ion

No.

200

-FZ

of

4 D

ecem

ber

2006

(r

evis

ed v

ersi

onof

28

July

201

2).

Tim

ber

Har

vest

ing

Rul

es. A

ppro

ved

by th

e O

rder

No.

337

of th

e F

eder

al F

ores

try

Age

ncy

of 1

Aug

ust

2011

.

Ver

ify th

at lo

ggin

g re

quire

men

ts a

re

fulfi

lled

usin

g an

A

ct o

n F

elli

ng

S

ite

s S

urv

ey

Re

sult

s.

The

req

uire

men

ts

for

deve

lopi

ng a

n A

ct o

n F

ellin

g S

ites

Sur

vey

Res

ults

are

se

t by

the

Tim

ber

Har

vest

ing

Rul

es

(par

agra

phs

63–6

6)

An

Act

on

Fel

ling

Site

s S

urve

y R

esul

ts is

a r

epor

t by

fore

st

man

agem

ent a

utho

ritie

s on

th

e fu

lfillm

ent b

y a

logg

ing

com

pany

of r

equi

rem

ents

se

t by

a Te

chno

logi

cal M

ap

and

othe

r do

cum

ents

.

Po

ten

tial

ris

k:V

iola

tions

typ

ical

ly o

ccur

w

hen

Tim

ber

Har

vest

ing

Rul

es a

re n

ot o

bser

ved,

ha

rves

ted

timbe

r vo

lum

es

are

exce

eded

and

logg

ing

Unc

erta

in

64


APPLICABLE ENTITY



COMMENTS


The

Ord

er N

o. 1

85of

16

July

200

7of

the

Min

istr

y of

N

atur

al R

esou

rces

“On

App

rova

l of R

ules

fo

r Te

ndin

g af

ter

For

est”

.

The

Ord

er b

yth

e G

over

nmen

tof

the

Rus

sian

F

eder

atio

n N

o. 4

14of

29

June

200

7 “O

n A

ppro

val o

f S

anita

tion

Rul

es fo

r F

ores

ts”.

The

Ord

er b

yth

e G

over

nmen

tof

the

Rus

sian

F

eder

atio

n N

o. 4

17

of 3

0 Ju

ne 2

007

“On

App

rova

l of F

ire

Saf

ety

Rul

es fo

r F

ores

ts”

(rev

ised

ve

rsio

n of

1 N

ovem

ber

2012

)

take

s pl

ace

outs

ide

th

e bo

unda

ries

of a

per

mitt

ed fe

lling

site

.

Opp

ortu

nitie

s to

con

trol

the

fulfi

llmen

t of r

equi

rem

ents

ar

e lim

ited

beca

use

the

Act

is

usu

ally

form

ulat

ed a

fter

tim

ber

has

alre

ady

been

sol

d.

Re

com

me

nd

ed

mit

igat

ion

m

eas

ure

s:S

elec

tive

field

aud

its

are

reco

mm

ende

d as

a

verif

icat

ion

mea

sure

. S

peci

al a

tten

tion

need

s to

be

pai

d to

the

verif

icat

ion

of in

form

atio

n re

port

ed in

th

e A

ct a

nd to

com

plia

nce

with

Tim

ber

Har

vest

ing

Rul

es.

Whe

n tim

ber

is h

arve

sted

th

roug

h in

term

edia

ries

and

as p

art o

f san

itatio

n lo

ggin

g,

it is

nec

essa

ry to

ver

ify

com

plia

nce

with

the

For

estr

y M

anag

emen

t Reg

ulat

ions

an

d S

anita

tion

Rul

es fo

r F

ores

ts. W

ith th

e la

tter

, a

valid

For

est P

atho

logy

Act

is

req

uire

d

65T

he F

ores

t Cod

eof

the

Rus

sian

F

eder

atio

n N

o. 2

00-F

Z

of 4

Dec

embe

r 20

06

(rev

ised

ver

sion

of 2

8 Ju

ly 2

012)

.

The

Ord

erN

o. 4

85 o

f the

Fed

eral

F

ores

try

Age

ncy

of 1

4 D

ecem

ber

2010

“O

n A

ppro

val

of G

uide

lines

for

Use

, Pro

tect

ion,

C

onse

rvat

ion

and

Reg

ener

atio

n of

F

ores

ts L

ocat

ed in

W

ater

Pro

tect

ion

Zon

es

and

For

ests

Ful

fillin

g F

unct

ions

of P

rote

ctio

n on

Nat

ural

and

Oth

er

Obj

ects

and

For

ests

Lo

cate

d on

For

este

d A

reas

with

a S

peci

al

Pro

tect

ion

Reg

ime”

Ver

ify th

at lo

ggin

g is

con

sist

ent

with

the

spec

ial

prot

ectio

n re

gim

e of

pro

tect

ive

fore

sts

esta

blis

hed

by:

• T

he F

ores

t Cod

e (a

rtic

les

102–

107)

• G

uide

lines

for

Use

, Pro

tect

ion,

C

onse

rvat

ion

and

Reg

ener

atio

n of

F

ores

ts L

ocat

ed in

W

ater

Pro

tect

ion

Zon

es a

nd F

ores

ts

Ful

fillin

g F

unct

ions

of

Pro

tect

ion

on N

atur

al a

nd

Oth

er O

bjec

ts a

nd

For

ests

Loc

ated

on

For

este

d A

reas

w

ith a

Spe

cial

P

rote

ctio

n R

egim

e

Whe

n lo

ggin

g is

und

erta

ken

in p

rote

ctiv

e fo

rest

s an

d fo

rest

s w

ith a

spe

cial

pr

otec

tion

regi

me,

th

e re

leva

nt le

gisl

atio

n sh

ould

app

ly a

nd lo

ggin

g lim

ited.

Po

ten

tial

ris

k:S

omet

imes

spe

cial

pr

otec

tion

regi

me

of

prot

ectiv

e fo

rest

s is

not

ob

serv

ed d

urin

g lo

ggin

g op

erat

ions

.

Re

com

me

nd

ed

mit

igat

ion

m

eas

ure

s:S

elec

tive

field

aud

its

are

reco

mm

ende

d as

a

verif

icat

ion

mea

sure

Unc

erta

in

Fed

eral

Law

No.

33-

FZ

of

14

Mar

ch 1

995

“On

Pro

tect

ed A

reas

” (r

evis

ed v

ersi

onof

25

June

201

2).

The

For

est C

ode

of th

e R

ussi

an

Fed

erat

ion

No.

200

-FZ

of

4 D

ecem

ber

2006

(r

evis

ed v

ersi

onof

28

July

201

2).

The

Ord

er o

f the

M

inis

try

of N

atur

al

Res

ourc

es N

o. 1

81

of 1

6 Ju

ly 2

007

Whe

n lo

ggin

g an

d/or

fore

st

infr

astr

uctu

re

deve

lopm

ent i

s un

dert

aken

in P

As,

it

is n

eces

sary

to

ver

ify if

the

requ

irem

ents

set

by

the

legi

slat

ion

on P

As

are

obse

rved

, inc

ludi

ng

man

agem

ent

plan

s fo

r re

leva

nt

indi

vidu

al P

As

Po

ten

tial

ris

k:V

iola

tions

oft

en o

ccur

whe

n th

e pr

otec

tion

regi

mes

of

reg

iona

l PA

s ar

e no

t ob

serv

ed.

Re

com

me

nd

ed

mit

igat

ion

m

eas

ure

s:F

or v

erifi

catio

n pu

rpos

es,

com

paris

on o

f inf

orm

atio

n fr

om F

ores

t Dec

lara

tions

, R

ent A

gree

men

ts a

nd/

or F

ores

t Sta

nds

Sal

es

Agr

eem

ents

with

m

anag

emen

t pla

ns

of s

peci

fic P

As,

For

est

Dev

elop

men

t Pro

ject

s

Unc

erta

in

66


APPLICABLE ENTITY



COMMENTS


“On

appr

oval

of

Gui

delin

es fo

r U

se, P

rote

ctio

n,

Con

serv

atio

n an

d R

egen

erat

ion

of F

ores

ts lo

cate

d on

Pro

tect

ed

Are

as”(

revi

sed

vers

ion

of 1

2 M

arch

200

8).

Reg

iona

l leg

isla

tion

on

prot

ecte

d ar

eas

(PA

s)

and

on s

peci

fic P

As

(man

agem

ent p

lans

)

is r

equi

red,

in a

dditi

on to

se

lect

ive

field

aud

its

(4)

Th

ird

-p

arty

leg

al

rig

hts

Fo

rest

are

a le

ase

ho

lde

rs,

log

gin

g

com

pan

ies

The

For

est C

ode

of th

e R

ussi

an

Fed

erat

ion

No.

200

-FZ

of

4 D

ecem

ber

2006

(r

evis

ed v

ersi

onof

28

July

201

2)

In m

ost c

ases

, thi

rd

part

y le

gal r

ight

s (in

clud

ing

right

s of

In

dige

nous

peo

ples

an

d ot

her

rura

l co

mm

uniti

es to

live

in

thei

r tr

aditi

onal

lif

esty

le, r

ight

s to

ha

rves

t ber

ries,

m

ushr

oom

s,

med

icin

al h

erbs

, et

c. a

nd r

ight

s to

fish

and

hun

t)

are

trad

ition

al

right

s th

at a

re

not r

egul

ated

by

legi

slat

ion

Po

ten

tial

ris

k:T

hird

par

ties

are

not

cons

ulte

d an

d/or

thei

r in

tere

sts

are

not c

onsi

dere

d.

Re

com

me

nd

ed

mit

igat

ion

m

eas

ure

s:F

ace-

to-f

ace

mee

tings

an

d di

rect

mai

ling

of

ques

tionn

aire

s to

third

pa

rtie

s, o

r th

e ab

senc

e of

co

mpl

aint

s re

ceiv

ed c

ould

be

use

d to

ver

ify w

heth

er

or n

ot tr

aditi

onal

rig

hts

are

bein

g re

spec

ted

Unc

erta

in

67of

the

Rus

sian

F

eder

atio

n. T

hird

pa

rtie

s us

ually

do

not

hav

e an

y w

ritte

n pr

oof t

hat

they

pos

sess

thes

e rig

hts,

exc

ept f

or

fore

st a

rea

rent

ag

reem

ents

for

hunt

ing

purp

oses

The

For

est C

ode

of th

e R

ussi

an

Fed

erat

ion

No.

200

-FZ

of

4 D

ecem

ber

2006

(r

evis

ed v

ersi

onof

28

July

201

2).

Fed

eral

Law

No.

82-

FZ

of 3

0 A

pril

1999

“O

n G

uara

ntee

s of

Indi

geno

us P

eopl

es

Rig

hts

in th

e R

ussi

an

Fed

erat

ion”

.

Fed

eral

Law

No.

49-

FZ

of 7

May

20

01 “

On

Terr

itorie

s of

Tra

ditio

nal L

and

Use

fo

r In

dige

nous

Peo

ples

of

the

Rus

sian

Nor

th,

Sib

eria

and

the

Rus

sian

F

ar E

ast o

f the

Rus

sian

F

eder

atio

n”.

Fed

eral

Law

104

-FZ

of 2

0 Ju

ly 2

000

“On

Com

mon

Prin

cipl

es

for

Org

aniz

atio

n of

Indi

geno

us P

eopl

es

Com

mun

ities

of t

he

Rus

sian

Nor

th, S

iber

ia

and

the

Rus

sian

Far

The

re a

re a

few

ca

ses

whe

re

agre

emen

ts

betw

een

logg

ing

com

pani

es a

nd

indi

geno

us p

eopl

es

orga

niza

tions

ar

e de

velo

ped

and

it m

akes

it

easi

er to

ens

ure

that

inte

rest

s of

third

par

ties

are

resp

ecte

d.

Rig

hts

for

trad

ition

al

livel

ihoo

ds

and

trad

ition

al

econ

omic

act

iviti

es

can

also

be

enjo

yed

by n

on-

indi

geno

us p

eopl

es

who

per

man

ently

liv

e in

pla

ces

desi

gnat

ed

for

trad

ition

al

livel

ihoo

ds

and

trad

ition

al

econ

omic

act

iviti

es

of in

dige

nous

pe

ople

s. T

hese

rig

hts

are

secu

red

Po

ten

tial

ris

k:T

hird

par

ties

are

not

cons

ulte

d an

d/or

thei

r in

tere

sts

are

not c

onsi

dere

d.

Re

com

me

nd

ed

mit

igat

ion

m

eas

ure

s:F

ace-

to-f

ace

mee

tings

an

d di

rect

mai

ling

of

ques

tionn

aire

s to

indi

geno

us

peop

les’

org

aniz

atio

ns /

com

mun

ities

or

the

abse

nce

of c

ompl

aint

s co

uld

be u

sed

to v

erify

whe

ther

or

not t

heir

right

s ar

e be

ing

resp

ecte

d

Unc

erta

in

68


APPLICABLE ENTITY



COMMENTS


Eas

t of t

he R

ussi

an

Fed

erat

ion”

.

The

Ord

er b

yth

e G

over

nmen

tof

the

Rus

sian

F

eder

atio

n N

o. 2

55

of 2

4 M

arch

200

0 “O

n C

omm

on L

ist o

f In

dige

nous

Peo

ples

of th

e R

ussi

an

Fed

erat

ion”

(w

ith

revi

sion

s an

d

addi

tions

).

The

Ord

erof

the

Gov

ernm

ent o

f th

e R

ussi

an F

eder

atio

n N

o. 5

36-r

of 1

7 A

pril

2006

“O

n T

he L

ist o

f In

dige

nous

Peo

ples

of

the

Rus

sian

Nor

th,

Sib

eria

and

the

Rus

sian

F

ar E

ast o

f the

Rus

sian

F

eder

atio

n”.

The

Ord

erof

the

Gov

ernm

ent o

f th

e R

ussi

an F

eder

atio

n N

o. 6

31-r

of 8

May

20

09 “

On

App

rova

l

by r

egio

nal

legi

slat

ion

(sub

ject

s of

the

Rus

sian

F

eder

atio

n)

69of

the

List

of P

lace

s fo

r tr

aditi

onal

Liv

elih

ood

and

Trad

ition

al E

cono

mic

A

ctiv

ities

of I

ndig

enou

s P

eopl

es o

f the

Rus

sian

F

eder

atio

n an

d th

e Li

st

of T

radi

tiona

l Eco

nom

ic

Act

iviti

es o

f Ind

igen

ous

Peo

ples

of t

he R

ussi

an

Fed

erat

ion”

.

Rel

evan

t reg

iona

l le

gisl

atio

n

(5)

Tra

de

an

d

cust

om

s

Tim

be

r tr

ansp

ort

atio

n

en

titi

es,

tr

ader

s, t

imb

er

exp

ort

ers

Tran

spor

tatio

nIn

voic

e (F

orm

1-Т

).

App

rove

d by

the

Ord

er

of th

e S

tate

Sta

tistic

al

Com

mitt

ee N

o. 7

8of

28

Nov

embe

r 19

97.

Rul

es fo

r A

utom

obile

Tr

ansp

orta

tion.

A

ppro

ved

by th

e O

rder

of

the

Gov

ernm

ent o

f th

e R

ussi

an F

eder

atio

n N

o. 2

72 o

f 15

Apr

il

2011

(re

vise

d ve

rsio

n of

30

Dec

embe

r 20

11).

Gui

delin

es fo

r Tr

ansp

orta

tion

Doc

umen

ts

Dev

elop

men

t for

R

ail R

oad

Car

go

Tran

spor

tatio

n.

App

rove

d by

the

Ord

er N

o. 3

9 of

the

Min

istr

y of

Rai

l Roa

d Tr

ansp

orta

tion

of18

Jun

e 20

03 (

revi

sed

vers

ion

of 3

Oct

ober

20

11).

Ver

ify th

at e

ach

ship

men

t of t

imbe

r ha

s al

l req

uire

d do

cum

ents

, na

mel

y:•

Car

go

S

pe

cifi

cati

on

• T

ran

spo

rtat

ion

In

voic

e •

Rai

l T

ran

spo

rtat

ion

B

ill

• C

MR

• B

ill o

f L

and

ing

• P

hyt

osa

nit

ary

Ce

rtif

icat

e•

Ag

ree

me

nts

(c

on

trac

ts)

for

ship

me

nt

of

tim

be

r, in

clu

din

g

con

trac

ts w

ith

in

term

ed

iary

b

uye

rs

Po

ten

tial

ris

k:F

alse

info

rmat

ion

on ti

mbe

r vo

lum

es a

nd s

peci

es c

ould

be

dec

lare

d in

tran

spor

tatio

n do

cum

ents

.

Re

com

me

nd

ed

mit

igat

ion

m

eas

ure

s:F

actu

al d

ata

on ti

mbe

r vo

lum

es a

nd s

peci

es h

ave

to b

e ve

rifie

d an

d co

mpa

red

with

thos

e de

clar

ed in

tr

ansp

orta

tion

docu

men

ts.

A c

ompl

ete

supp

ly c

hain

has

to

be

cont

rolle

d.

A c

orre

ct a

nd c

ompl

ete

scie

ntifi

c na

me

of a

sp

ecie

s ha

s to

app

ear

in a

P

hyto

sani

tary

Cer

tific

ate

Unc

erta

in

Unc

erta

in

Low

Low

Low

Unc

erta

in

Unc

erta

in

70


APPLICABLE ENTITY



COMMENTS


Con

vent

ion

onth

e C

ontr

act f

orth

e In

tern

atio

nal

Car

riage

of G

oods

by

Roa

d (C

MR

), G

enev

a,

19 M

ay 1

956.

The

form

of a

Bill

of

Lan

ding

is a

ppro

ved

by th

e M

erch

ant M

arin

e C

ode

of th

e R

ussi

an

Fed

erat

ion

(Fed

eral

La

w N

o. 8

1-F

Zof

30

Apr

il 19

99

(rev

ised

ver

sion

of 2

8 Ju

ly 2

012)

.

Inte

rnat

iona

l Pla

nt

Pro

tect

ion

Con

vent

ion

(FA

O, r

evis

ed te

xt

in 1

997)

Tim

be

r ex

po

rte

rsT

he O

rder

of th

e G

over

nmen

t of

the

Rus

sian

F

eder

atio

n N

o. 7

79

of 3

0 Ju

ly 2

012

“On

Tarif

f Quo

tas

for

Cer

tain

Sof

twoo

d T

imbe

r P

rodu

cts

Exp

orte

d fr

om

the

Rus

sian

Fed

erat

ion

Ver

ify th

at a

n ex

port

ent

ity

trad

ing

soft

woo

d ro

und

timbe

r on

di

scou

nt ta

riffs

ha

s a

On

e-t

ime

Lic

en

se f

or

Tra

de

in C

ert

ain

S

oft

wo

od

Tim

be

r P

rod

uct

s o

n

The

Lic

ense

pro

ves

the

lega

l rig

ht o

f the

Rus

sian

ex

port

ing

com

pany

to e

njoy

di

scou

nt e

xpor

t tar

iffs

on

soft

woo

d tim

ber

Low

71an

d O

ther

Mem

ber

Sta

tes

of th

e C

usto

ms

Uni

on”

(rev

ised

ver

sion

of

27

Sep

tem

ber

2012

)

Dis

cou

nt

Exp

ort

T

arif

fs is

sued

by

the

Min

istr

y of

In

dust

ry a

ndTr

ade

The

Con

vent

ion

on

Inte

rnat

iona

l Tra

de in

E

ndan

gere

d S

peci

es o

f W

ild F

auna

and

Flo

ra

(CIT

ES

). A

ppen

dix

III

Whe

n C

ITE

S

liste

d sp

ecie

s ar

e ex

port

ed v

erify

that

an

exp

ortin

gen

tity

has

a C

ITE

S E

xpo

rt

Pe

rmis

sio

n is

sued

by

the

Fed

eral

S

uper

viso

ry

Nat

ural

Res

ourc

es

Man

agem

ent

Ser

vice

of t

he

Min

istr

y of

Nat

ural

R

esou

rces

and

E

nviro

nmen

t

Onl

y tw

o tr

ee a

nd s

hrub

sp

ecie

s gr

owin

g in

the

Rus

sian

Fed

erat

ion

are

liste

d in

the

CIT

ES

Ann

ex II

I, na

mel

y, K

orea

n pi

ne (

Pin

us

kora

iens

is)

and

Japa

nese

ye

w (

Taxu

s cu

spid

ata)

.

CIT

ES

Exp

ort P

erm

issi

on is

an

obl

igat

ory

docu

men

t for

in

tern

atio

nal t

rade

in K

orea

n pi

ne a

nd J

apan

ese

yew

.

Po

ten

tial

ris

k:V

iola

tions

occ

ur w

hen

info

rmat

ion

on s

peci

es

com

posi

tion

is fa

lsifi

ed.

Re

com

me

nd

ed

mit

igat

ion

m

eas

ure

s:F

actu

al d

ata

on ti

mbe

r vo

lum

es a

nd s

peci

es h

ave

to b

e ve

rifie

d an

d co

mpa

red

with

thos

e de

clar

ed in

tr

ansp

orta

tion

docu

men

ts.

A c

ompl

ete

supp

ly c

hain

has

to

be

cont

rolle

d

Unc

erta

in

The

Dec

isio

nof

the

Cus

tom

s U

nion

C

omm

issi

on N

o. 2

57

of 2

0 M

ay 2

010

“On

Inst

ruct

ions

for

Cus

tom

s D

ecla

ratio

ns

Dev

elop

men

t and

C

usto

ms

Dec

lara

tion

Ver

ify th

at a

tim

ber

expo

rt e

ntity

has

a

valid

Cu

sto

ms

De

clar

atio

n.

Cus

tom

s D

ecla

ratio

ns

cont

ain

info

rmat

ion

on g

oods

an

d th

eir

cust

oms

cost

s,th

e m

eans

of t

rans

port

atio

n,

the

send

er a

nd th

e re

cipi

ent.

Dec

lara

tions

hav

e to

be

in c

ompl

ianc

e w

ith th

e

Low

72


APPLICABLE ENTITY



COMMENTS


For

ms”

(re

vise

d ve

rsio

n of

26

Apr

il 20

12)

requ

irem

ents

set

by

the

Inst

ruct

ion

on th

e O

rder

of

Dev

elop

men

t Dec

lara

tions

fo

r G

oods

app

rove

d by

th

e D

ecis

ion

No.

39

of

the

Eur

asia

n E

cono

mic

C

omm

issi

on o

f 26

Apr

il20

12

Inst

ruct

ion

of th

e C

entr

al B

ank

of th

e R

ussi

an

Fed

erat

ion

No.

978

-uof

15

June

200

1“O

n O

rder

of L

egal

Act

s an

d O

ther

Doc

umen

ts

of th

e B

ank

of R

ussi

a”

Ver

ify th

at a

tim

ber

expo

rt e

ntity

pa

id e

xpor

t fee

s.

The

ent

ity h

as to

pr

ovid

e a

valid

P

aym

en

t O

rde

r fo

r ex

port

fee

Low

Technical Editor: Philip Johnson Layout: Ekaterina Kozlova

Circulation: 500 copies Printed by the Polygraph Media Group

Worldwide Fund for Nature (WWF)109240 Moscow, Russia, Nikoloyamskaya st.19 building 3

About FLEG II (ENPI East) Program The Forest Law Enforcement and Governance (FLEG) II European Neighbourhood and Partnership Instrument (ENPI) East Countries Program supports participating countries’ forest governance. At the regional level, the Program aims to implement the 2005 St. Petersburg FLEG Ministerial Declaration and support countries to commit to a time-bound action plan; at the national level the Program will review or revise forest sector policies and legal and administrative structures; and improve knowledge of and support for sustainable forest management and good forest governance in the participating countries, and at the sub-national (local) level the Program will test and demonstrate best practices for sustainable forest management and the feasibility of improved forest governance practices at the field-level on a pilot basis. Participating countries include Armenia, Azerbaijan, Belarus, Georgia, Moldova, Russia, and Ukraine. The Program is funded by the European Union.http://www.enpi-fleg.org

Project PartnerEUROPEAN COMMISSION The European Union is the world’s largest donor of official development assistance. The European Commission’s Directorate General for European Neighbourhood Policy and Enlargement Negotiations (DG NEAR) manages the bulk of the Union’s financial and technical assistance to the neighbourhood and enlargement countries. By implementing assistance actions in Europe’s eastern and southern neighbourhood, DG NEAR supports reform and democratic consolidation, and strengthens the prosperity, stability and security around Europe. DG NEAR helps to promote EU values, policies and interests in this region, and to contribute to developing the special relationship of the EU with its neighbouring countries.http://ec.europa.eu/index_en.htm

WORLD BANKThe World Bank Group is one of the world’s largest sources of knowledge and funding for its 188 member-countries. The organizations that make up the World Bank Group are owned by the governments of member nations, which have the ultimate decision-making power within the organizations on all matters, including policy, financial or membership issues. The World Bank Group comprises five closely associated institutions: the International Bank for Reconstruction and Development (IBRD) and the International Development Association (IDA), which together form the World Bank; the International Finance Corporation (IFC); the Multilateral Investment Guarantee Agency (MIGA); and the International Centre for Settlement of Investment Disputes (ICSID). Each institution plays a distinct role in the World Bank Group’s mission to end extreme poverty by decreasing the percentage of people living on less than $1.25 a day to no more than 3 percent, and promote shared prosperity by fostering the income growth of the bottom 40 percent for every country. For additional information please visit:http://www.worldbank.org, http://www.ifc.org, http://www.miga.org

IUCNIUCN, International Union for Conservation of Nature, helps the world find pragmatic solutions to our most pressing environment and development challenges. IUCN’s work focuses on valuing and conserving nature, ensuring effective and equitable governance of its use, and deploying nature-based solutions to global challenges in climate, food and development. IUCN supports scientific research, manages field projects all over the world, and brings governments, NGOs, the UN and companies together to develop policy, laws and best practice. IUCN is the world’s oldest and largest global environmental organisation, with more than 1,200 government and NGO members and almost 11,000 volunteer experts in some 160 countries. IUCN’s work is supported by over 1,000 staff in 45 offices and hundreds of partners in public, NGO and private sectors around the world.www.iucn.org

WWFWWF is one of the world’s largest and most respected independent conservation organizations, with almost 5 million supporters and a global network active in over 100 countries. WWF’s mission is to stop the degradation of the planet’s natural environment and to build a future in which humans live in harmony with nature, by conserving the world’s biological diversity, ensuring that the use of renewable natural resources is sustainable, and promoting the reduction of pollution and wasteful consumption.www.panda.org

Environment

Results of the Survey of Russian Forest Industry Senior Staff Awareness of the European Union Timber Regulation 995/2010