The debate announced last week took place on May 11 under the patronage of the Academy of Agricultural and Forestry Sciences, the University of Brașov and INCDS – Marin Drăcea, with the support of professional organizations in the sector.
The theme of the conference – the evaluation, measurement, and assurance of the traceability of timber in Romania, from the valuation act (APV) to primary processing – is extremely important in the context of the adoption of the Deforestation free regulation at the level of the European Union and in the perspective of the new Forestry Code of Romania, currently being drafted.
The event enjoyed a top participation from the Academia, as well as professional associations in the sector (AAP, ASFOR, AIL – Prolemn), the National Forestry Administration – Romsilva, the Forest Guards, representatives of the private sector and from civil society.
The presentations focused on technical aspects, particularly important for the regulation of logging and processing activities, as well as for strengthening the traceability and control systems of timber. The speakers showed:
- Substantial margins of error of the APV calculation. This assessment can remain as the basis for selling timber on stump, without constituting a scriptural, formal, mathematical management, as SUMAL considers it.
- The technological losses and consumptions from logging activities are variable and substantial. Therefore, we have harvesting results that vary between wide limits and do not allow mathematical equalities with the APV.
- The lack of enforceability of the regulations that provide for the issuance of permits with actual dimensions, with legal tolerances that do not even consider the standards in force for logs and timber.
- The problems created by the regulations that provide for the automatic takeover in warehouse management of notices. In this way, an extra-accounting management is created in SUMAL, different from the accounting management based on entry-reception notes and determination of differences, as required by the financial-accounting legislation.
European regulation vs Romanian implementation
In his presentation, Cătălin Tobescu, president of AIL – Prolemn, insisted on the difference in approach between European regulations and their “Romanian” implementation.
Within the EU Regulation 995/2010 (EUTR), the European vision regarding legal provenance and traceability means focusing on the first placing on the market: timber must come from within legally authorized limits and be paid for. The fundamental principles are:
- No forest degradation – also included in the new Deforestation free
- Own due diligence of the economic operators: information gathering, risk assessment, risk mitigation.
- Non-involvement in the commercial side.
The “Romanian” implementation means tracking timber materials beyond the first placing on the market – APV regulation, notice, reception, differences, overlengths, GPS tracking, photos, certified evaluators, indices and coefficients of technical cubage, densities, warehouse management.
It is obvious that there is an over-regulation of the sector, the formal violation of which is extremely easy and leads to the declaration of the wood as ‘without provenance.’ It results in confiscations, an explosion of contraventions and innumerable offences. Hence, placing Romania at high risk of illegal logging, infringement, which has led to further over-regulation as a reaction from the political environment. But also, to bureaucracy, corruption, the inefficiency of control institutions followed by citizen control. Politicization and a permanent public scandal
Among the conclusions of the meeting:
- Currently, despite a long development process from 2008 to date (with SUMAL 1.0, the Forest Radar in 2014, the Forest Inspector in 2016, SUMAL 2.0 in 2021), the SUMAL system does not capitalize on the huge amount of information collected through a system of alerts / risk assessment, which affects the effectiveness of activities to combat illegal logging.
- Over-regulation, by tracking timber materials not only in terms of origin, but also in terms of commercial management far beyond their first placing on the market (in commerce, primary processing, and the furniture industry), has induced administrative costs and bottlenecks in this value chain and locked the resources of control in bureaucratic tasks.
- The development of the SUMAL system must build upon the principles of European regulations, as the basis of a due system due diligence when first placing timber on the market. A system of economic operators’ own risk assessment and targeting of controls on risk areas and activities, without interference in the commercial side of activities in the forestry and timber processing sector.