Briefing Document / Feb. 27, 2014

Submission to the Chinese State Forest Administration regarding the forthcoming Timber Trade and Investment Guideline


The last two decades have seen China’s rapid emergence as a global leader within the international timber trade – as an importer, manufacturer, consumer and exporter of a wide range of wood products, as well as an investor in forest industries around the world.

Over the same period, Global Witness’ detailed field research has repeatedly demonstrated the weaknesses in law enforcement in many of the tropical forested countries in Africa, Asia and Latin America that supply major wood product importers such as the EU and USA, as well as China.  We have documented the adverse economic, social and environmental impacts that illegal logging and timber trade have on the populations of these countries and also the commercial and reputational risks to international companies of having their supply chains contaminated with illegal wood.[1]

We note also, that illegal logging is a multi-billion dollar business[2] that fuels corruption and organised crime around the world.  According to 2013 estimates by the UN, Asia-Pacific is the source of 70% of all internationally traded illegal timber. The UN estimates that this trade in illegal timber is the second largest source of revenue for criminal syndicates in the region.[3]

On the basis of our findings and those of the UN and other agencies, we have come to the conclusion that, even though such legal violations may occur far from the country that imports and uses the timber, it is vital that major importers and consumers take measures to ensure that they are not inadvertently exacerbating a very serious global problem through their purchases and their investments. 

Global Witness therefore warmly welcomes the efforts of the State Forest Administration (SFA) and Chinese Academy of Forests (CAF) to establish a new Timber Trade and Investment Guideline for Chinese companies operating or sourcing from overseas. 

We have taken the opportunity to set out a series of recommendations on points that the SFA and CAF may wish to include in the new Guideline. These are principally informed by the following sources:

Global Witness’ own research findings and analysis of the timber trade over the past two decades in countries including Cambodia, Cameroon, Democratic Republic of Congo, Ecuador, Ghana, Honduras, Laos, Liberia, Malaysia, Myanmar and Peru

  • The State Forest Administration and Ministry of Commerce Guide on Sustainable Overseas Forests Management and Utilisation by Chinese Enterprises (2009)
  • The State Forest Administration and Ministry of Commerce Guide on Sustainable Overseas Silviculture by Chinese Enterprises (2007)
  • The EU Timber Regulation and US Lacey Act
  • Other international schemes to control natural resource supply chains internationally, such as UN Security Council Due Diligence Guidelines for the Responsible Supply Chain of Minerals and the Kimberley Process Certification Scheme for rough diamonds[4]

In consulting existing Chinese government guidelines, regulations on the timber trade from the other two main importing and consuming markets globally (EU and US) and comparable international standards of supply chain control for other raw materials, we have sought to formulate suggestions that are grounded in existing best practice.  These suggestions are broken down into three parts:

  • Overarching aims
  • Due diligence by companies
  • Monitoring compliance

Read the full submission here.

[1] Global Witness website For examples of recent Global  Witness publications on forests and illegal logging, see the following: Liberia’s Forest Sector – a new window of opportunity, 2013,; An Industry Unchecked – Japan’s extensive business with companies involved in illegal and destructive logging in the last rainforests of Malaysia, 2013, (in Chinese) or (in English); The cut-price sale of DRC’s forests, 2013, (in Chinese) or (in English); Logging in the Shadows – how vested interests abuse shadow permits to evade forest sector reforms, 2013,; Rocky Road – how legal failings and vested interests behind Peru’s Purus highway threaten the Amazon and its people, 2013,

[2] Nellemann, C, INTERPOL Environmental Crime Programme (eds) Green Carbon, Black Trade: Illegal Logging, Tax Fraud and Laundering in the World’s Tropical Forests: A Rapid Response Assessment, INTERPOL and UN Environment Programme, 2012, p.6, INTERPOL estimates the economic value of illegal logging globally as being between US$30-100 billion.

[3] UN Office on Drugs and Crime, Transnational Organized Crime in East Asia and the Pacific: A Threat Assessment, April 2013, p.96,

[4] UN Security Council, ‘Security Council Committee established pursuant to resolution 1533 (2004) concerning the Democratic Republic of the Congo’; UN Security Council, Due diligence guidelines for the responsible supply chain of minerals from red flag locations to mitigate the risk of providing direct or indirect support for conflict in the eastern part of the Democratic Republic of the Congo’, For English version, see