Timber Development UK / Timber Trade Federation              DEF0017

Written evidence submitted by Timber Development UK / Timber Trade Federation

About Timber Development UK:

Timber Development UK (TDUK) has been formed in 2022 from the merger of two of the largest and longest established organisations in the supply chain, the Timber Trade Federation (TTF) and Timber Research and Development Association (TRADA).

With over 1200 members, spanning from sawmill to specifier, TDUK is the largest, most comprehensive timber supply chain body in the UK.

We represent UK sawmillers, panel producers, importers, distributors, merchants, joinery & timber frame manufacturers, architects, engineers and contractors. Our members account for roughly 85% of the timber placed on the market in the UK, both imported & homegrown.

Since 2012 (as TTF) we have operated a mandatory third-party auditing policy – the Responsible Purchasing Policy (RPP) on all members. This ensures they are operating a due diligence/ risk management system in line with the EU Timber Regulation and now the UK Timber Regulation to prevent any illegally logged material from entering the market.


Executive Summary

-          trees absorb carbon dioxide as they grow;

-          once harvested the carbon remains stored within the structure of wood for the duration of its physical life;

-          if used in construction this carbon can be locked away for over 100 years, giving time for replacement trees to grow and more emissions to be absorbed and stored;

-          in this way, rural forest areas act as a carbon “sink”, while urban areas act as a carbon “store”.


Growing the UK Timber Industry

Does the UK Government have an adequate understanding of the future demand for timber, including what tree species should be grown?


  1. In short, No. Timber demand is forecast to grow enormously over the coming years. The World Bank, for example, forecasts a quadrupling of global demand for timber products by 2050 compared to 2020 levels.


  1. The UK is a net importer of timber. While there is nothing wrong with imports, and they contribute positively towards sustainable forest growth elsewhere, this forecast increase in demand will leave the UK subject to the whims of global pricing and logistics.


  1. If the Government understood these forecasts, it would make more effort to plant productive woodland. It is falling far short of its targets.


  1. Regarding tree species, we have to look at which species will be used most in the markets available to them to provide a pull-through – that is likely to be a continuation of the current commercial species mix, with minor variations for climate adaptation. Here, I would defer to my colleagues from CONFOR (Confederation of Forest Industries) for further detail.


Does the UK government, working with the devolved administrations, have an effective, joined-up plan with appropriate incentives to increase the production and use of sustainable, domestically grown timber in the UK to reduce its reliance on imports?


  1. Again, No. If they did, we would be seeing the results. There remain several barriers to timber production which is disincentivising UK-grown timber. These include:


  1. - Uncertainty: There is uncertainty as to what land trees can be planted on. New planting often requires consultation with many different local and national interest groups (e.g., English Heritage, Natural England etc.), many of which will throw up issues that need to be overcome as part of the planning process. This is very time-consuming and often deters progress.


  1. - Tree species: Anecdotally we’ve been told that productive softwoods cannot form more than 20% of new planting in England and recent figures suggest that planting in 2021-22 suggest this is closer to 12%, with a presumption in favour of broadleaf planting instead. These species are less useful for commercial construction products (the biggest driver for use) and take longer to grow. This balance needs reversing to encourage planting into more productive uses.


  1. - Bureaucracy and paperwork: There are currently a multitude of forms that need to be completed and signed off by the Forestry Commission before a tree planting scheme can go ahead. Streamlining this process – with a presumption in favour of productive forest planting – would be an improvement. These barriers are preventing targets from being reached. For example, England planted just 13,840[1] hectares of woodland in 2022 despite an “overall target of planting 30,000 hectares per year” in the England Trees Action Plan[2].


Are there sustainable sources of biomass for UK energy generation either from imported or domestically grown wood for pellet or woodchip? And how can future demand be met from sustainable sources?


  1. Regarding sustainability, it is better to look at a hierarchy of use and to prioritise long-life uses for wood fibre first, e.g., construction, before looking at “end of life” uses such as energy production. This keeps the carbon stored longer and encourages efficient use throughout the supply chain.


  1. Additionally, demand for biomass-energy competes directly with the production of panel and particleboard products (demand for which is increasing at the same rate as for other timber products) which use much of the same feedstock. Sustainable timber is a finite resource and using fresh chips and pellets for biofuel diverts resources away from sustainable construction.


  1. The growth of biomass energy is something which needs to be monitored and alternative sources of feedstock sought. The Government should be considering this within the context of an energy policy which seeks to reduce demand while providing secure supply from renewable sources.


How well is the UK Government managing its plans for the domestic timber industry in tandem with meeting its woodland creation targets and related climate change, biodiversity and other environmental goals?


  1. Not very well. We should not see the creation of productive woodland as being opposed to the achievement of biodiversity and other environmental goals. These go hand in hand. Greater expansion of woodland – productive or otherwise – will help achieve biodiversity and other targets. But the Government needs a sense of urgency and purpose to achieve this as outlined above.




How effectively is the UK strengthening the resilience of its tree stock to ensure it is resilient to the future impacts of climate change, as well as to pests and diseases?


  1. The industry and Government have certainly started to look at this, and current UKFS rules around planting which do not allow monocultures will help with this.


  1. However, pressure to plant ‘native’ trees will need to be removed to ensure we plant stock that can cope with increased temperature and meet market needs. This really will mean more softwood species to use in construction.


The Effectiveness of UK Efforts to Reduce Global Deforestation

In what ways and to what extent are UK value chains contributing to global deforestation?


  1. Deforestation is still a major problem across the world, particularly in the tropical belt, but the timber industry is part of the solution, not the problem.


  1. First, most of the timber used in the UK comes from European sources. It is a well-regulated industry across the EU and EU forests are growing as a result. The same is true in other countries such as North America. The timber industry provides a great example of demand and supply side regulation working together.


  1. Most of the countries where deforestation is rife are those which lack the strong governance rules we have in the UK, EU and USA. Despite this, the positive demand-side regulations we have put in place in the UK, EU and elsewhere (UK Timber Procurement Policy, the TDUK Responsible Purchasing Policy, the EU and UK Timber Regulations, the US Lacey Act and others) have had an impact on the forest management and timber production practices of many countries.


  1. Over recent years, as a result of our work with the world-renowned Forests Governance Markets and Climate (FGMC) initiative at the Dept for International Development (now FCDO) we have seen many positive shifts in producer countries as a direct result of the interlocking demand-side regulations put in place by the EU, UK and other major consumer countries.


  1. These include a decrease in illegal logging in major producer countries and a shift towards best practices at major processing centres[3].


  1. However, a majority of these changes have been seen in semi-industrialised and more developed nations. The improvements have been less noticeable in the poorer producer countries.


  1. To counter this problem, and working with FGMC partners, TDUK has been calling for an initiative to create an overarching, international legal trade framework for forest governance and supply chain management. This should be based on the development of national standards within producer nations which meet internationally agreed criteria for trade.


  1. Using such a system, exporters meeting the criteria of their national standards would be given a certificate acting as a “passport to trade” and accepted by importing nations.


  1. The origin of this concept was based on the development of the SVLK system in Indonesia and the VPA agreements under the FLEGT Action Plan. Since introducing its national SVLK system, Indonesia has seen roughly a 65% drop in illegal logging, an increase in third-party certification for forest management, and improvements in income and export value throughout the supply chain.


  1. Similar developments toward national standards are now taking place in a variety of other countries.


  1. Improving forest governance is a prerequisite for tackling deforestation and we believe that globally recognised and inclusive legal frameworks are essential for the sustainable management of global forests – and would also underpin the UK’s other climate policy ambitions. The UK can play an important role, providing leadership as an international broker to drive actions in this arena.


  1. TDUK presented this concept in a paper called “Global Forests Need Global Governance” at COP 26[4]. The paper and concept were well received. Since then, we have built a global coalition of producer and consumer country trade associations to explore developing this into a more coherent functioning initiative.


  1. I would urge the members of the EAC to read this paper and pledge long-term, cross-party support to the FGMC unit to help finance and develop it. I believe this is where the UK – as one of the largest global net importers of timber – can play a leading role in providing soft diplomacy or international brokerage skills towards achieving global environmental, economic and development outcomes.


How effectively is the Government monitoring the UK’s contribution to global deforestation and its progress in tackling the issue? And, what progress has been made by Government to develop an indicator on overseas environmental impacts of UK consumption of key commodities?


  1. We are not aware of any monitoring tool tracking the impact of UK-specific consumption on global deforestation, especially illegal deforestation. According to the UK Government’s consultation paper on Implementing due diligence on forest risk commodities (Dec 2021 to March 2022), very few attempts were made to estimate the extent of illegal deforestation globally. This is understood to be due to their clandestine nature. However, one key resource for global illegality estimates was a 2014 report conducted by Forest Trends which was supported by UK Aid[5].


How effective are the measures to improve due diligence and ban imported products of illegal deforestation in the Environment Act 2021? Do these measures target the right sectors? Given that they do not extend to all products of deforestation are they adequate?


  1. The measures proposed in the Environment Act 2021 have not been implemented so their impact cannot be measured.


  1. In terms of the scope, TDUK is of the view that all forest commodities should be included in the legislation to create the most significant impact on deforestation. We do understand the challenges faced by the Government in ensuring a smooth transition for UK businesses. The initial period of implementation will require Government and private sector investment along with extensive training and awareness raising.


  1. However, this should not be used as an excuse. Business and regulators will soon learn to adjust.


What role can sustainable certification and Government Buying Standards (GBS) have in tackling deforestation?


  1. The GBS, together with the UK Timber Regulation and third-party certification schemes have all contributed to the reduction in timber from areas ripe for deforestation[6].


  1. However, without proper regulation in place – in the form of national governance standards and legal frameworks in producer countries - the benefit of certification will be limited. As stated in the previous answers, many countries lack the basic legal frameworks upon which certification schemes can develop their management systems further. This is especially the case in tropical producing countries where third-party audited management systems have struggled due to the lack of national forest and land governance, the lack of formal business cultures within the SME networks that dominate the forest economy, and the sheer cost of implementing a third-party system.


  1. For example, in Ghana and Côte d’Ivoire, cocoa production is a main driver of deforestation, yet nearly a quarter of all cocoa produced is certified. Clearly, this has not stopped deforestation in the country.


How can the UK government support the private sector to reduce its contribution to furthering deforestation?


  1. Based on experience with timber products, the actual hard work of due diligence – from the initial data gathering and review to the actual transformation - requires the collaboration of all companies among the supply chains that may vary in size and with different levels of understanding of UK rules.


  1. The UK Government could therefore do two things:


  1. - Ensure there is a clearly defined set of criteria as well as verifiers to ensure the interpretation of the requirements among businesses, enforcement bodies and NGOs are on the same level. This will require the Government to have a greater understanding of the actual practice of stakeholders at each stage of the supply chain for each of the forest commodities involved, as well as country-specific guidance on due diligence.


  1. - Declare itself as an international forest champion and play a leading role in helping coordinate these efforts globally between governments and within supply chains. Currently, there is no global leader for governance in the forest commodities sector. Yet, without governance, none of the other initiatives will succeed (LEAF, REDD + etc). The UK has an exemplary record via its work with the FGMC and other initiatives in the forestry and development sector. It can now build on this to help broker greater action with countries and regions as diverse as the USA, China, the EU, the Congo Basin and West Africa, and elsewhere. It is a global role which would tie the links between resource management, trade, economic development and environmental stewardship. The UK should seize the opportunity to become a world leader.


National regulation and governance


  1. The main driver for deforestation in tropical countries is agricultural expansion. Sometimes, the trees felled in land clearance for agriculture are sold to provide cash flow for agricultural development and the timber industry is implicated in the crime. Many of these products are screened out by regulations such as those described above, but there are still outlets for the goods, often in the countries where deforestation takes place or in neighbouring countries, or large processing hubs such as China.


  1. However, there is a clear difference between the business models involved. To put this in crude simple terms: The business model for most agricultural products is characterised by an absence or clearing of trees, while the business model for timber products is characterised by the presence, management, and growth of trees.


September 2022

[1] https://cdn.forestresearch.gov.uk/2022/06/PWS-statsnotice-16jun22.pdf


[3] https://iati.fcdo.gov.uk/iati_documents/49904537.pdf

[4] https://ttf.co.uk/global-forests-need-global-governance-tropical-timber-accord-launches-at-cop26/

[5] https://www.forest-trends.org/wp-content/uploads/imported/for168-consumer-goods-and-deforestation-letter-14-0916-hr-no-crops_web-pdf.pdf

[6] https://www.pnas.org/doi/10.1073/pnas.1704728114