Factual summary report on the public consultation on the fitness check of the EU rules on illegal logging

1Fitness check of the EU rules on illegal logging

This is the summary report on the public consultation on the Fitness Check of the EU rules on illegal logging assesses effectiveness, efficiency, relevance, coherence and EU-added value of the European Union Timber Regulation (EUTR, Regulation (EU) No 995/2010) and the Forest Law Enforcement, Governance and Trade Regulation (FLEGT Regulation, Regulation (EC) No 2173/2005). The results of the Fitness Check feed into the parallel impact assessment study, supporting identification and analysis of options for additional EU regulatory and non-regulatory demand-side measures that could increase supply chain transparency and minimise the risk of deforestation and forest degradation associated with products and commodities placed on the EU market.

2Objectives of the public consultation

The public consultation forms one of several strands of consultation activities for the Fitness Check as outlined in the Evaluation Roadmap 1 . The public consultation aimed at capturing the views of all relevant stakeholders, allowing them to provide relevant information and feedback on the functioning and impacts of the EUTR and FLEGT Regulation.

This document provides a breakdown of the responses to the public consultation. A full analysis of the results will be included in the final report of the study in support of the Fitness Check. A more comprehensive description of the results will be included in the consultation synopsis report annexed to the Fitness check.

3Approach to the public consultation

The questionnaire developed for the purposes of this consultation consisted of three parts: Part 1 for citizens with a general interest in illegal logging, Part 2 designed for respondents with in depth technical knowledge of the two Regulations (e.g. public authorities responsible for implementing and/or enforcing the Regulations, industry and sectorial associations representing companies concerned, monitoring organisations, environmental and consumer NGOs, universities and research institutes) and Part 3 addressed to all types of stakeholders.

The questionnaire was made available in all EU official languages and uploaded to the Have Your Say platform of the European Commission 2 . The consultation period started on 3 September 2020 and ended on 26 November 2020, lasting 12 weeks. To maximise the response rate, a link to the questionnaire was shared with the members of the Commission Expert Group on Protecting and Restoring the World’s Forests, including the EUTR and the FLEGT Regulation 3 and on the FLEGT.org website 4 .

4Responses to the public consultation

In total 175 respondents filled in the questionnaire during the consultation period, of which 55% have requested that their responses remain anonymous. The remaining agreed to the publication of all information of their contribution, except for one participant who did not respond. Although there was a total of 175 respondents, it should be noted that the number of responses to each specific question has varied throughout the survey. Due to the non-mandatory nature of most questions, it is typical that fewer than 175 responses have been provided to certain questions.

Out of all respondents, 79% (138 respondents) were from EU countries. The primary country of origin for respondents was Germany (35 respondents, 20% of all respondents), followed by Belgium (28 respondents, 16%), France and the Netherlands (both with 11 respondents, or 6 %). In total, respondents listed 38 different countries of origin, with an even split of 19 EU countries and 19 Non-EU countries being represented. Half of these countries were represented by only one respondent.

Of the 175 respondents, the most common stakeholders to reply were companies/businesses (46, 26%) followed by NGO’s (41, 24%) and public authorities (26,15%). 21 respondents have identified themselves as private citizens (18 EU, 3 non-EU, 12%). The remaining stakeholders have come from businesses associations (19, 11%), environmental organisations (5, 3%), academic/research institutions (5, 3%) and one trade union (1, 1%). 10 participants (10, 6%) also selected the ‘other’ option, which included three consultants (sustainability & forestry), an EUTR monitoring organisation, three certification bodies, two forestry associations and a representative of a project funded by EU for strengthening forest governance. One respondent did not answer the question. The full breakdown of respondents is shown in Figure 3-1.

Figure 3-1 Stakeholder Respondents

152 respondents answered the question as to whether their organisation was active in a timber or timber products related sectors, with 23 respondents failing to provide an answer. The vast majority of total survey participants (132, 75%) stated that their organisation was active in these sectors. A number of options were provided to respondents to specify their areas of interest and activities. The most common area of interest or activity were ‘operator’ as defined by the EUTR (i.e. placing timber and timber products on the EU market for the first time) (38 respondents, representing 9%); ‘import and trade’ (of wood, solid biofuel, etc.) (33 respondents, 8%) and ‘environmental NGO’s (33 respondents, 8%). In addition, 22 other areas of interest were selected by at least one respondent. Of the 22 other areas of interest or activity selected by respondents, no single area was selected by more than 7% of participants. However, a high proportion of respondents (44, 11%) did not provide a response.

Participants were also asked to indicate their level of knowledge of illegal logging and associated trade, the EUTR, and the FLEGT Regulation. Depending on the topic, between 70% and 83% of total survey participants judged themselves as having either excellent or good understanding of the topics covered in the consultation.

As shown in Figure 3-2, displaying the results to the question ‘How do you rate your level of knowledge of illegal logging and associated trade’, just under half (79 respondents) stated that they have excellent knowledge/understanding. A further 67 respondents marked that they had a good knowledge/understanding of illegal logging and associated trade, thus overall 83% of participants reported being well informed on the subject. Only 2 respondents stated that they had little to no knowledge of the topic. 5 respondents did not answer the question.

Figure 3-2 Knowledge of illegal logging and associated trade

169 participants responded to the question ‘How do you rate your level of knowledge of the EUTR?’, with 6 participants providing no response. Detailed results are shown in Figure 3-3. The most frequent response was that participants had excellent knowledge/understanding of the EUTR (78, 45%) followed by good knowledge/understanding (62, 35%). Overall, 80% of respondents have marked that they are well informed about EUTR. Only 10 participants (6%) responded that they had little or no knowledge of the EUTR.

Figure 3-3 Knowledge of EUTR

Finally, 169 participants responded to the question ‘How do you rate your level of knowledge of the FLEGT Regulation?’, with 6 participants not providing a response. As shown in Figure 3-4, the most frequent response was that participants had good knowledge/understanding of the Regulation (71, 41%) followed by excellent knowledge/understanding (50, 29%). Overall, a smaller share of respondents (70%) have considered themselves well informed about on the topic, compared to illegal logging and EUTR. 20 participants (12%) responded that they had little or no knowledge of the FLEGT Regulation.

Figure 3-4 Knowledge of FLEGT Regulation

(1)

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/11630-Illegal-logging-evaluation-of-EU-rules-fitness-check-

(2)

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/11630-Illegal-logging-evaluation-of-EU-rules-fitness-check-/public-consultation

(3)

  https://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetail&groupID=3282

(4)

  http://www.flegt.org/