now FSC-CWRA-005-PRT

FOREST
STEWARDSHIP
COUNCIL
FSC-SECR-0180

Scope:
Version:
Approval date:
Development:
National Approval:
International Approval
Facilitator:
Email address:

continental Portugal
Final
01 March 2011
GPI
Associação para uma Gestão Florestal Responsável /
FSC Portugal


FSC International Center: Policy and Standards Unit
Vera Santos
v.santos@pt.fsc.org

FSC Controlled Wood risk assessment
SPECIFIC REQUIREMENTS
INTERPRETATION OF ANNEX 2B OF THE STANDARD FOR COMPANY EVALUATION OF
FSC CONTROLLED WOOD FOR PORTUGAL
(FSC-STD-40-005-V-2.1)

Summary of risk for continental Portugal

1
2
3
4
5

Illegally harvested wood
Wood harvested in violation of traditional and civil rights

Wood harvested in forests where high conservation values are threatened by
management activities
Wood harvested in forests being converted to plantations or non-forest use
Wood from forests in which genetically modified trees are planted

Associação para uma Gestão Florestal
Responsável (AGFR)
Rua Mestre Lima de Freitas, n.º 1
1549-012 Lisboa/ Portugal
Phone: +351 217 100 014
Fax: +351 217 100 037

Low Risk
Low Risk
Low Risk
Low Risk
Low Risk

Vera Santos
Mobile: +351 927 977 876

E-Mail: v.santos@pt.fsc.org
www.pt.fsc.org

©2008 Forest Stewardship Council A.C. All rights reserved.

Foreword
The FSC Controlled Wood standards were designed to help manufacturers and traders to avoid
buying wood from the most controversial sources.
For FSC, there are different ways for a company to demonstrate this:
1. Purchase wood from forest management organizations certified according to FSC-STD30-010 FSC Controlled Wood standard for forest management enterprises,
2. Purchase FSC Controlled Wood from suppliers holding a valid FSC Chain of Custody
certificate which includes FSC Controlled Wood in its scope; and/or
3. Internally verify its wood sources according to the requirements of FSC-STD-40-005
Company evaluation of FSC Controlled Wood. This is an option for organizations that
can trace their wood supply back to its origins and will generally, therefore, be more
easily applicable to primary processors of wood or wood fibre.
For case 3 above, the organizations are obliged to implement a risk assessment of its suppliers.
FSC-STD-40-005 attributes the obligation of conducting the risk assessment to the certificate
holder (or the certification candidate). It is the responsibility of the Certification Body to evaluate
and verify the technical adequacy and consistency of the company’s risk assessment.

FSC accredited National Initiatives, as well as National and Regional Offices, can provide guidance
to help companies identify credible sources of information to arrive at a sound risk assessment
decision (see General requirements of Annex 2 of FSC-STD-40-005).
Procedure FSC-STD-60-002 specifies the requirements which must be complied with by National
Initiatives which want to carry out a FSC Controlled Wood Risk Assessment. The Risk Assessment
produced will be evaluated by FSC and once approved, becomes mandatory for the district and
category in question.
The advantage of this approach is that it allows all companies sourcing from a district to use the
same FSC Controlled Wood Risk Assessment, without spending time and resources in repeating
the process and verifying their consistency.
The present document was written according to the guidance available in procedure FSC-PRO-60002 and includes the results of the technical sessions of both the Chain-of-Custody and Controlled
Wood Technical Commission and Controlled Wood National Interpretation Working Group, initiated
in 2007 and carried out throughout 2008 and 2009, first focused on the translation of the relevant
standards (FSC-STD-30-0010; FSC-STD-40-004 and FSC-STD-40-005), and later on the risk
analysis and assessment for the five Controlled Wood categories in Continental Portugal.

– 2 of 12 –

©2008 Forest Stewardship Council A.C. All rights reserved.


FSC CONTROLLED WOOD RISK ASSESSMENT
This evaluation applies to the five FSC controlled wood categories, with the geographic scope of continental Portugal and the district of
origin specified for each category.

1. Illegally harvested wood
District: continental Portugal
Requirements

Sources of information

Key information

Conclusion

Category 1. The district of origin may be considered low risk in relation to illegal harvesting when all the following indicators related to forest governance
are present:
1.1 Evidence of enforcement of
logging related laws in the district.

www.gnr.pt

www.afn.min-agricultura.pt
www.act.pt

The Nature and Environment
Protection Service Serviço de
Protecção da Natureza e do
Ambiente (SEPNA) is a
specialization of the Republican
National Guards Guarda Nacional
Republicana, created in January
2001 to defend Portugal’s
environmental and natural heritage.
It was institutionally formed in
February 2006 through Decree-Law
n.º 22/2006. Since then, the number
of environmental /nature inspections
carried out in cooperation with
related legal responsibilities has
grown, and included cooperation in
game, fishing and forestry

protection, strengthening SEPNA’s
capacity for surveillance and
inspection of national territory.
In the enquiries carried out, no
significant evidence of infractions
– 3 of 12 –

According to this indicator, Portugal
can be considered a low risk
district.

©2008 Forest Stewardship Council A.C. All rights reserved.

Requirements

Sources of information

Key information

Conclusion


was found.
1.2 There is evidence in the district
demonstrating the legality of
harvests and wood purchases that
includes robust and effective
systems for granting licenses and
harvest permits.

1.3 There is little or no evidence or
reporting of illegal harvesting in the
district of origin.

www.afn.min-agricultura.pt
www.icnb.pt
www.asae.pt

www.gnr.pt
http://ec.europa.eu/environment/fore
sts/


In Portugal there is a robust legal
system which includes the activities
of forest harvesting and wood
purchase, with responsibilities
shared among three regulatory
entities.

According to this indicator, Portugal
can be considered a low risk
district.

After consulting various national and
international sources, no significant
reports or evidence were found of
illegal forest harvesting.

According to this indicator, Portugal
can be considered a low risk
district.


According to Transparency
International, Portugal’s Corruption
Perception Index (CPI) was 5.8 in
2009. This index has declined over
the last few years, showing that
corruption is perceived to be
increasing lately. However, this is an
extremely generalist indicator of
corruption and does not reflect the
situation of the forestry sector, which
is considered to have a low level of
corruption.

According to this indicator, Portugal
can be considered a low risk
district.

www.illegal-logging.info
1.4 There is a low perception of

corruption related to the granting or
issuing of harvesting permits and
other areas of law enforcement
related to harvesting and wood
trade.

www.transparency.org

– 4 of 12 –

©2008 Forest Stewardship Council A.C. All rights reserved.

2. Wood harvested in violation of traditional and civil rights
District: continental Portugal
Requirements

Sources of information

Key information

Conclusion

Category 2. The district of origin may be considered low risk in relation to the violation of traditional, civil and collective rights when all the following
indicators are present:
2.1 There is no UN Security
Council ban on timber exports from
the country concerned.

www.un.org

2.2 The country or district is not
designated a source of conflict
timber (e.g. USAID Type 1 conflict
timber).
2.3 There is no evidence of child
labour or violation of ILO
fundamental Principles and Rights
at work taking place in forest areas
in the district concerned.

The information on export bans by
the UN Security Council can be
consulted on the United Nations and
Global Witness internet sites.
None of the sites mention a UN
Security Council ban on timber
exports from Portugal.

According to this indicator, Portugal
can be considered a low risk
district.

www.usaid.gov - Conflict Timber:
Dimension of the Problem in Asia
and Africa. Volume I. Synthesis
report. June 2003

The sources suggested by FSC IC
and other online searches do not
designate Portugal as a source of
conflict timber.

According to this indicator, Portugal
can be considered a low risk
district.

www.ilo.org

Portugal is signatory of the following
ILO conventions: 29, 87, 97, 98,
100, 105, 11, 131, 135, 138, 141,
144, 155 and 182, including those
related to child labour.
Child labour in Portugal is presently
a known reality. Once its existence
was acknowledged, Portugal sought
to establish its current dimension
and main characteristics, promoting
a rigorous identification of the
number of children and young
workers using ILO (through

According to this indicator, Portugal
can be considered a low risk
district.

www.globalwitness.org

www.peti.gov.pt
www.cnasti.pt
www.act.pt

– 5 of 12 –

©2008 Forest Stewardship Council A.C. All rights reserved.

Requirements

Sources of information

Key information

Conclusion

IPEC/SIMPOC) parameters,
indicators and methodologies.
The National Work Authority’s (ACT)
latest report (2007) refers that it
continues to cooperate with other
governmental and nongovernmental organizations, with
particular relevance to the Plan for
Elimination of Child Labour (PETI),
social partners and the National
Confederation for Action on Child
Labour (CNASTI), regarding
identification of child labour cases
and actions implemented.
The evolution registered in this area
is decidedly positive. While in 1997
in each thousand child-labour-risk
inspections, 114,23 under-age
workers were found, in 2007 this
indicator is practically inexpressive
(0,13).
Thus, in Portugal, if one considers
child labour to persist in the forest
sector, it is nonetheless residual.
2.4 There are recognized and
equitable processes in place to
resolve conflicts of substantial
magnitude pertaining to traditional
rights including use rights, cultural
interests or traditional cultural
identity in the district concerned.
2.5 There is no evidence of
violation of the ILO Convention 169
on Indigenous and Tribal Peoples
taking place in the forest areas in
the district concerned.

www.mj.gov.pt

In Portugal, the legal system and
measures to resolve conflicts
pertaining to traditional rights are
effective and comply with FSC
requirements.

According to this indicator, Portugal
can be considered a low risk
district.

In Portugal there are no Indigenous
or Tribal Peoples, such as defined
by the United Nations.

This indicator can be considered as
not applicable to Portugal.

– 6 of 12 –

©2008 Forest Stewardship Council A.C. All rights reserved.

3. Wood harvested in forests in which high conservation values are threatened by management activities
District: continental Portugal
Requirements

Sources of information

Key information

Conclusion

Category 3. The district of origin may be considered low risk in relation to threat to high conservation
values if:
a) indicator 3.1 is met; or
b) indicator 3.2 eliminates (or greatly mitigates) the threat posed to the district of origin by non-compliance with 3.1.
3.1 Forest management activities
in the relevant level (eco-region,
sub-eco-region, local) do not
threaten eco-regionally significant
high conservation values.

www.panda.org/about_our_earth/ecoregions/
mediterranean_forests_scrub.cfm

3.2 A strong system of protection
(effective protected areas and

www.afn.min-agricultura.pt

www.icnb.pt

FSC refers as key sources on
eco-regions work carried out by
WWF, Conservation
International, GreenPeace and
IUCN, among others.
In Portugal, the dominant ecoregion by far is Mediterranean
Forests, Woodlands and Scrub;
a detailed description of the
HCV associated to this ecoregion can be found on the
WWF indicated in the previous
column.
The main threats mentioned by
WWF are continuing conversion
of these forest areas to
agriculture, grazing or urban
use. Other threats are frequent
fires, harvesting of the
remaining areas of natural
forests, the excessive use of
exotic species and overgrazing.
However, the national nature
conservation system is based

– 7 of 12 –

According to this indicator,
Portugal can be considered a
low risk district.

©2008 Forest Stewardship Council A.C. All rights reserved.

Requirements
legislation) is in place that
ensures survival of the HCVs in
the ecoregion.

Sources of information

Key information
on legal protection regimes
(such as the National network
of protected areas, Natura 2000
network, etc.), which limits the
activities allowed in these
areas. There is also an
inspection authority, SEPNA,
whose results, and their
effectiveness, have increased
over the years.
International perception (World
Bank) of the robustness of the
eco-region’s HCV protection
system also corroborates
national perception.
Thus, indicator 3.2 eliminates,
or greatly mitigates, the
potential threat identified in the
previous indicator.

www.icnb.pt
www.gnr.pt
www.govindicators.org

– 8 of 12 –

Conclusion

©2008 Forest Stewardship Council A.C. All rights reserved.

4. Wood harvested from areas being converted from forests and other wooded ecosystems to plantations or non-forest
uses
District: continental Portugal
Requirements

Sources of information

Key information

Conclusion

Category 4: The district of origin may be considered low risk in relation to conversion of forest to plantations or non-forest uses when the following
indicator is present:
4.1 There is no net loss AND no
significant rate of loss (> 0.5% per
year) 8 of natural forests and other
naturally wooded ecosystems such
as savannahs taking place in the
eco-region in question.

According to the FAO’s State of
the World’s Forests last report,
there has been an increase of
forest area in Europe and this
expansion of forest resources to
abandoned farmland is likely to
continue.
Existing legislation prohibits
conversion of natural forest to
plantations (1901 and 1903
regime florestal decrees, decreelaws n. º 166/2008, of 22-08 on
the National Ecological Reserve,
254/2009, of 24-09 on the Forest
code and 169/2001, of 25-05 on
cork and holm oak).
Furthermore, land use changes
after forest fires are conditioned by
law (decree-laws n. º 254/2009, of
24-09, on the Forest code and
169/2001, of 25-05, on cork and
holm oak); changes must be
submitted to the National Forest
Authority (AFN).

http://www.fao.org
www.afn.min-agricultura.pt/
www.icnb.pt

– 9 of 12 –

According to this indicator,
Portugal can be considered a low
risk district.

©2008 Forest Stewardship Council A.C. All rights reserved.

Requirements

Sources of information

Key information
Natural forests are classified as
habitats, and are thus
safeguarded by another legal
framework which is even more
limiting.
The results of the last National
Forest Inventory (2005/6) show an
increase of forest area; namely a
cork oak increase of 3,4% and an
umbrella pine increase of 8,1%. In
contrast, maritime pine and
eucalyptus areas decreased 27%
and 3,8%, respectively.

– 10 of 12 –

Conclusion

©2008 Forest Stewardship Council A.C. All rights reserved.

5. Wood from forest management units in which genetically modified trees are planted
Distrito: Portugal continental
Requirements

Sources of information

Key information

Conclusion

Category 5: The district of origin may be considered low risk in relation to wood from genetically modified trees when one of the following indicators is
complied with:
a) There is no commercial use of
genetically modified trees of the
species concerned taking place in
the country or district concerned.

http://europa.eu.int/comm/environme
nt/biotechnology/index_en.htm
www.maotdr.gov.pt/
www.apambiente.pt/politicasambient
e/biotec/ogm/

The deliberate release into the
environment of Genetically Modified
Organisms (GMOs) is regulated by
th
Directive 2001/18/CE, of 17 April
(transposed to national law by
decree-law n. º 72/2003, of 10-04).
As part of its responsibilities, the
Portuguese Environment Agency
(APA) maintains records on the
location of cultivated GMOs, so as to
supervise their effects on the
environment and provide the public
with information on their deliberate
release into the environment
As to field trials with GMOs for
experimental aims, decree-law n. º

– 11 of 12 –

According to this indicator, Portugal
can be considered a low risk
district.

©2008 Forest Stewardship Council A.C. All rights reserved.

Requirements
b) Licenses are required for
commercial use of genetically
modified trees and there are no
licenses for commercial use.

Sources of information

Key information
72/2003 establishes a specific
permission process, whereby the
designated authority analyses the
information submitted, namely
environmental risk assessment,
public consultation and the opinion
of the national Health and
Agriculture authorities.
In Portugal, there is only one record
of the use of genetically modified
trees – a trial by a private company,
Celbi, which terminated in 2001.
In Portugal, licenses are required for
commercial use of genetically
modified trees, as specified by
decree-law n. º 72/2003, of 10-04.

c) It is forbidden to use genetically
modified trees commercially in the
country concerned.

– 12 of 12 –

Conclusion