Soil Association                            DEF0026

Written evidence submitted by the Soil Association

The Soil Association is a membership charity, formed in 1946 by a group of farmers, scientists, doctors, and nutritionists who were determined to pioneer a world where we can live in health and in harmony with nature. Our mission is to restore nature, health, and a safe climate from the ground up. We do this by supporting a farming and land use transition to agroecology and regenerative forestry, as well as a transition to healthy and sustainable diets for all, with a radically reduced fashion and forest footprint. Today, the Soil Association works to develop, innovate and scale-up solutions for sustainable food, farming, and forestry - by collaborating with organic and non-organic farmers, foresters, retailers, processors, and food procurers from schools to hospitals to restaurant chains. 

Through our trading subsidiary, Soil Association Certification, we work with over 6,000 businesses including organic farmers and growers, caterers, food processors and manufacturers. We also work in more than 65 countries to certify over 25 million hectares of sustainably managed forest globally to FSC and PEFC global standards, as well as certifying over 4000 chain of custody enterprises.

The subject of this Environmental Audit Committee inquiry into sustainable timber and deforestation is very close to our mission and expertise, so hopefully our thoughts and perspectives will add-value to the inquiry.

We have focused our response around the key questions posed by the Committee, although we do not provide a response for every question.


Growing the UK timber industry

See below


There is a huge challenge to link future potential UK timber production to the demand side. Currently UK demand is for conventionally grown plantation timber. However the likelihood of increasing UK supply of this product is limited, as timber produced in this way is highly contested and unlikely to achieve significant traction in the crowded, predominantly farmed landscapes of the UK. UK government should therefore be concentrating primarily on supporting farm-scale forestry and helping to make timber production viable within integrated, predominantly small-scale systems.

To date, implementation of ambitions for tree planting have consistently failed to recognise this starting point of a predominantly farmed landscape in the UK. There has been very little focus on encouraging farmers to act as the change implementer, by incorporating new tree planting, as agroforestry and woodland systems, into their farm enterprise activity. For too long, aspirations for woodland creation and increasing tree cover in the landscape has been discussed in an abstract and third-party manner, without cognisance of this reality. In many ways the key challenges are no longer technical or even financial; rather they are cultural and social. We should aim to devise all actions with the ambition of giving farmers, more agency to ‘own’ the strategy to plant and manage trees, rather than it being imposed on farmers, and delivered by others. This means an effective campaign to ensure that ‘tree growing’ gives farmers pride and value as ‘producers’. In the same way, that the value from growing food and helping to deliver ‘food security’ gives farmers pride and value currently. So, we advocate for a ‘carry on farming but with trees’ strategy, to complement the establishment of new, large-scale forests by other actors, through a land use change and a cessation in farming model.

To support this transition, we believe that there should be a focus on rewarding farmers for the public benefits that their trees and farm woodlands currently provide, to act as a powerful incentive to deliver more in future. Although almost 30% of the UK’s current woodland cover is part of a farm enterprise (farm woodland), for many farmers this resource is viewed as unproductive and contributing little to farm revenues. Although some of these woodlands will be in poor ecological condition, many will still be providing significant public benefits. If we reward farmers now for what they already deliver, then over time these woodlands will be viewed as ‘productive’ and contributing to the revenue of the farm enterprise. It is our contention, that this will then encourage increased ‘farmer led tree planting and management’ and a long-term attitude change to trees on their farms and the benefits of more integrated and diverse land use. 


Burning forest biomass for large-scale electricity generation worsens climate change in real terms and in real time, and the harm it causes can persist for decades or even centuries.[1] For the purpose of international accounting under the Paris Agreement, these emissions are supposed to be counted in countries’ land use sectors at the point of harvest. Imported biomass is therefore counted as zero emissions in the UK energy sector. This has created perverse incentives, whereby renewable energy and zero carbon subsidies are awarded to large-scale biomass plants, despite the real carbon emissions associated with burning wood. Soaring demand for imported wood pellets, led by the UK,[2] also puts unsustainable pressure on globally important ecosystems.[3]

Proponents of bioenergy argue carbon neutrality can be achieved after wood is combusted when an equal amount of carbon is sequestered by regrowing trees. However, this premise of carbon neutrality is false.[4]

It can take decades for new trees to sequester equivalent carbon to that released, and this generates a ‘carbon debt’ in the atmosphere that will not be repaid on timescales relevant to achieving net zero.[5],[6]

Other significant woody biomass lifecycle emissions (that are not always properly accounted for) include:

  1. Emissions from processing and transporting wood pellets;
  2. Carbon released from the soil during biomass harvest in forests;[7]
  3. Forgone sequestration as a result of cutting down older trees and replacing them with saplings after harvest, where the forest’s overall carbon storage and sequestration capacity declines for decades compared to a scenario where the trees are left standing.[8],[9]

Large-scale reliance on burning forest biomass therefore sets back climate efforts. Evidence indicates that protecting forests is more valuable for climate change mitigation than harvesting trees for bioenergy.[10], [11]

As the government considers further billions of pounds in subsidy for bioenergy with carbon capture and storage (BECCS), UK greenhouse gas emissions accounting and GGR policy must reflect the real and total effects of BECCS on the atmosphere as well as other environmental impacts. A UK-focussed approach based on ruling out specific feedstocks from sustainability criteria would close this loophole and end the subsidising of those types of wood that have the greatest carbon and biodiversity impact.

There are only very limited ‘sustainable’ sources of woody biomass available, and financial incentives have generated a vast discrepancy between availability and usage. A report by 3Keel for the RSPB identified that the only moderate and low risk sources of biomass for the UK are wastes and residues and that these could provide 4% of primary energy supply.[12] The European Commission’s Joint Research Centre analysed a range of woody biomass feedstocks to identify risks posed to biodiversity and ecosystem as well as carbon emissions. Out of 24 sourcing practices, the only scenario identified as enabling short term carbon risk and low risk for biodiversity is burning fine woody debris (twigs and low diameter branches) if some are also left in the forest to maintain soil health and biodiversity.[13] This is only a small fraction of the biomass currently used by the UK.

The UK currently uses large amounts of thinnings for bioenergy. We recognise that UK Woodland Assurance Scheme accredited thinning practices in the UK are beneficial for silvicultural reasons and may have biodiversity benefits, however, our understanding is that we cannot separate these from the carbon and nature risk of incentivising excessive harvesting for wood burning. Incentives for truly sustainable forest management, either of plantations or semi-natural woodland that would benefit from conservation management, should be developed separately from the energy market. Woody arisings from such management may be suitable for small-scale bioenergy use, however the market should not be distorted by subsidy to encourage this end use over other options which may be more beneficial for climate and nature, like leaving debris on the forest floor.

Evidence suggests that the creation of a market for wood pellets can stimulate excessive thinnings or clearcuts, removal of beneficial debris, or cause indirect impacts by displacing other markets like pulp or paper elsewhere.[14] As our current woody biomass supply chain is almost totally reliant on imports, challenges of international governance can also prove to be insurmountable, therefore it is imperative that future targets for biomass use are scaled down in order to facilitate this reduction in feedstock availability.


The Soil Association recently published a ‘Regenerative Forestry’ report in which we set out a blueprint for an approach to UK forestry that would ensure that forestry delivers for climate, nature and people. In doing so, we aim to help redefine forestry more broadly, to include all tree, woodland and forest systems grown for a purpose, at all scales. From individual trees providing shelter and shade to livestock in a silvopasture system, to extensive forest areas owned by private, state and voluntary actors managed primarily for timber production or nature conservation.

Regenerative Forestry Report (

For the Soil Association, truly regenerative forestry operates at both a land use scale and as an adaptive practice, rooted in ecology that delivers for climate, nature and people. It seeks to improve landscapes, so they become diverse ecosystems adaptive to change. It does this by storing high levels of carbon to help rebalance our destabilised climate; by promoting resilient and adaptive forests to restore our depleted biodiversity; and by generating timber and other products to support climate mitigation and meaningful livelihoods.

Regenerative forestry adopts a whole system approach. It recognises the importance of forest ecosystems and the many goods and services they provide for climate, nature and people. In practice, this means ensuring that benefits and trade-offs are assessed across the whole system (in and beyond the forest), to make optimal and balanced decisions. Timber is an important part of the system and long-term uses provide a significant potential carbon store beyond the forest. The importance and value of timber and carbon storage will increase as the world moves towards net zero, providing more opportunities for economic, climate, biodiversity and societal gains.


Regenerative forestry can be an integral part of the wider landscape restoration, achieving an increased level of forest cover; restoring lost habitats and species and supporting livelihoods. It requires the planting of more diverse forests to increase forest cover and more trees integrated into farming systems and the wider farmed landscape.  Like regenerative and organic farming, regenerative forestry generates products for our use, and does so whilst improving the conditions within which it operates, and in a way conducive to human wellbeing. New forests must be established with careful thought for their location and composition. Fragile soils and valuable habitats must be avoided. These forests must link to other biodiverse habitats, including a site-sensitive mix of species, allowing natural processes as much as possible. Introducing more trees to farmland is vital both to increase forest cover and to improve its productivity, biodiversity and resilience to extremes of future weather, with trees playing a role in protecting farmland from rain, wind and sun. This will only be achieved if forests are clearly seen to integrate with, and contribute to, the local community and environment.


Regenerative forestry ensures the resilience and adaptive capability of the forest itself. Management objectives, whether achieved through active management or non-intervention, planting or regeneration, must ensure the forest’s own future.  This requires a realistic risk assessment of predicted climate change and a strategy to ensure the UK’s forests can deliver climate mitigation benefits, whilst adapting as ecosystems to a changing climate. Diversity is fundamental to ecological resilience of the forest, as is the diversity of landscapes.

Regenerative forestry promotes a set of improved forest management practices that deliver optimal outcomes for climate, nature and people. These practices ensure that our forests are diverse by species and age structure, principally managed by low impact systems (such as continuous cover forestry). There must be minimal soil disturbance during planting and harvesting, avoiding planting on organic soils, and protecting soils with a canopy of trees as much as possible. These practices help to protect forests from damage and threat, whilst maintaining diverse forest conditions for nature and people, and still able to produce high quality timber.


Only through these improved regenerative forestry practices can we ensure that forests achieve their full role in the response to climate change. These practices both mitigate emissions by storing carbon and by helping forests adapt to climate change. Regenerative forestry practices consider carbon storage at every stage of a forest’s growth – in forest soils, living trees and harvested wood products. Regenerative forestry practices also restore depleted biodiversity – restoring and establishing ecosystems with a greater diversity of species, genetics, structure and age.

The report summarised our thinking by suggesting the following principles.




Regenerative forestry principles


The Soil Association proposes that forestry as a land use can be regenerative and that individual forests can be managed regeneratively. But only when the following principles are applied: 


  1. Regenerative forestry is a whole system approach, delivering  benefits for climate, nature and people, both within the forest and from forest ecosystem services outside the forest.


  1. Regenerative forestry is an integrated approach to deliver the ambitions for more trees, by ensuring new forests are diverse and resilient, and integrated into our wider farmed landscape through mainstream adoption in farming systems.


  1. Regenerative forestry is resilient and adaptive and takes care of the forest itself, so that benefits for climate, nature and people can be provided for the long-term.


  1. Regenerative forestry is a set of improved forest management practices that deliver optimal outcomes across the whole forest and avoids spatial intensification in some zones. The whole forest must deliver for climate, nature and people, whether actively managed or non-intervention, planted or regenerated.


  1. Regenerative forestry supports high levels of engagement by people and delivers strong livelihoods. Regenerative forestry is rewarded for the market products and wider ecosystem services, it delivers for climate, nature and people.

No specific comments

The effectiveness of UK efforts to reduce global deforestation


We support the position set out in the WWF’s Riskier Business report:

“The UK’s overseas land footprint, a key element of the UK’s total environmental footprint overseas, has increased by 15% on average compared to our 2011-15 analysis. Between 2016 and 2018, an area equivalent to 88% of the total UK land area was required to supply the UK’s demand for just seven agricultural and forest commodities – beef & leather, cocoa, palm oil, pulp & paper, rubber, soy, and timber. This rise is in response to an increasing demand for agricultural and forestry products, including those led by shifts in UK policy (notably, the greater demand for fuel wood as a source of renewable energy)”. Source:



The 2021 Environment Act aims to address illegal deforestation in UK supply chains, but the scope of the requirements and guidance for business is still being developed. Arguments have been made, including by UK retailers, that addressing only illegal deforestation will not solve the impact of UK supply chains on global deforestation and that measures should also address legal deforestation. The Environment Bill should be strengthened to cover all types of deforestation and clearance of natural areas of high importance for climate and biodiversity. It is hoped that forthcoming measures in the EU to address deforestation and land use-risk commodities will address some of these challenges.

See above

The entire suite of measures recommended by the Global Resource Initiative should be adopted, because a sole focus on ‘importer country’ regulations without a broader suite of policy measures, investments, inducements and disincentives is unlikely to achieve the stated policy goal of making forest risk commodities more sustainable and legal.


Government standards should require palm oil, soya and other forest-risk commodities to be from ‘certified’ sources, though we flag that the UK Soy Manifesto is exploring non-certification avenues towards deforestation and land-conversion free soy. Certification of commodities is not always a guarantee of environmental and social responsibility. The following measures might be effective in reducing the use of unsustainable commodities including palm oil and soy:

              Reducing the procurement of ultra-processed foods.

              Reducing the use of soy-based feed with standards that support more plant-based protein and ‘better’ meat. Organic meat and dairy, with organic soy, is a more responsible choice.

              Improving regulation of forest-risk commodities and removing unsustainable legal deforestation from UK supply chains.

Similar measures, with government support, should be employed by the private sector.

Specifically for timber as a commodity, the UK Government’s Timber Procurement Policy sets out the documentary evidence required for government procurers and suppliers to show that timber is legal and sustainable.  However, since the closure the Central Point of Expertise on Timber (CPET) in 2016, it is unclear how well this policy is understood or implemented.  By strengthening the policy and ensuring it is fully implemented, the UK Government could drive demand for legal and sustainable timber through the public sector. 

The UK Timber Regulations (UKTR) aim to ensure that the UK imports timber harvested in compliance with the laws of the country of origin. The Regulations focus on legality rather than sustainability.  By extending the scope to look at sustainability, the UK Government could drive demand for legal and sustainable timber more broadly.

To be fully effective, certification schemes need to have robust deforestation criteria and indicators covering both environmental and social requirements.


Working with international partners to tackle deforestation

No specific comments

No specific comments

September 2022

[1] Michael Norton et al., “Serious Mismatches Continue Between Science and Policy in Forest Bioenergy,” Global Change Biology Bioenergy 11, no. 11 (November 2019): 1256-1263,


[3] “UK Biomass Imports Threaten Global Biodiversity,” Cut Carbon Not Forests, March 2021,

[4] Scientist letter regarding use of forests for bioenergy. Online.

[5] European Academies’ Science Advisory Council, “Commentary by the European Academies’ Science Advisory Council (EASAC) on Forest Bioenergy and Carbon Neutrality,” June 15, 2018, online.

[6] Brack, D. (2017). Woody biomass for power and heat: Impacts on the global climate. Environment, Energy and Resources Department, The Royal Institute of International Affairs, Chatham House, London.

[7] D. L. Achat et al., (2015) “Forest Soil Carbon Is Threatened by Intensive Biomass Harvesting,” Scientific Reports 5, art. 15991 (online); S. P. Hamburg et al., (2019) “Losses of Mineral Soil Carbon Largely Offset Biomass Accumulation 15 Years After Whole-Tree Harvest in a Northern Hardwood Forest,” Biogeochemistry 144, no. 1. Online.

[8] N. L. Stephenson et al., (2014) “Rate of Tree Carbon Accumulation Increases Continuously With Tree Size,” Nature. Online.

[9] Mitchell, S.R., Harmon, M.E. and O'Connell, K.E.B. (2012), Carbon debt and carbon sequestration parity in forest bioenergy production. Glob. Change Biol. Bioenergy, 4: 818-827.

[10] Ter-Mikaelian, M. T., Colombo, S. J. & Chen, J. The Burning Question: Does Forest Bioenergy Reduce Carbon Emissions? A Review of Common Misconceptions about Forest Carbon Accounting. J. For. 113, 57–68 (2015).

[11] Moomaw, W. R., Masino, S. A., & Faison, E. K. (2019). Intact forests in the United States: Proforestation mitigates climate change and serves the greatest good. Frontiers in Forests and Global Change, 2, 27.

[12] 3Keel, Biomass for Energy: A framework for assessing the sustainability of domestic feedstocks, May 2022,

[13] European Commission, Joint Research Centre, Camia, A., Giuntoli, J., Jonsson, R., et al., The use of woody biomass for energy production in the EU, Publications Office, 2021,

[14] ‘Managers at Plum Creek. […] agreed that the market provided by Drax was accelerating this intensified forestry regime’ Fern (2016) Up in Flames: How biomass burning wrecks Europe’s Forests. Online.