Second draft NRA V3 0 D2 0 ENG
FSC National Risk Assessment
For the Russian Federation
DEVELOPED ACCORDING TO PROCEDURE FSC-PRO-60-002 V 3-0
Draft quality translation
Version
V 3-0 Draft 2-0 for public consultations
from 19.07.2017-31.08.2017
Code CWNRA-RU-V3-0
National approval
Coordination Council, AssoМiКtion “NRG”
Date
FSC International Center: Policy and
International approval Standards Unit
Date:
International contact
Period of validity
Name:
Email address:
Date of approval:
Valid until: (date of approval + 5 years)
Body responsible for NRA maintenance FSC Russia, XXX
Summary of risk for the Russian Federation
Controlled Wood categories
Risk level (including
functional scale when
relevant)
1
Illegally harvested wood
Specified risk
2
Wood harvested in violation of traditional and human
rights
Specified risk
3
Wood from forests where high conservation values are
threatened by management activities
Specified risk
4
Wood from forests being converted to plantations or nonforest use
Low risk
5
Wood from forests in which genetically modified trees are
planted
Low risk
Contents
1.
Background information
2.
List of experts involved in the risk assessment and their contact details
3.
National Risk Assessment maintenance
4.
Complaints and disputes regarding the approved National Risk Assessment
5.
List of key stakeholders for consultation
6.
Risk assessment (for each area under assessment)
6.1
Category 1: Illegally harvested wood
6.2
Category 2: Wood harvested in violation of traditional and human rights
6.3
Category 3: Wood from forests where high conservation values are threatened by management activities
6.4
Category 4: Wood from forests being converted to plantations or non-forest use
6.5
Category 5: Wood from forests in which genetically modified trees are planted
Annex 1.1
List of information sources for categories 1, 4 and 5
Annex 1.2
List of information sources for category 2
Annex 1.3
List of information sources for category 3
Annex 2.1
Identification of applicable legislation for categories 1, 4 and 5
Annex 2.2
Identification of applicable legislation for category 2
Annex 2.3
Identification of applicable legislation for category 3
Annex 3.1
List of indigenous peoples and subjects of the Russian Federation where indigenous peoples
complying with criteria of ILO C No.169 are present
1
Background information
FSC National Risk Assessment (NRA) for the Russian Federation is developed by FSC Russia (represented by
AssoМiКtion “NКtionКl Working Group for VoluntКrв Forest CertifiМКtion”) for the neeН of FSC МertifieН orgКniгКtions
sourcing wood from uncertified suppliers for further use with FSC Controlled Wood claim.
The NRA Working Group followed the requirements of FSC-PRO-60-002 V3-0 The Development and Approval of FSC
National Risk Assessments, FSC-PRO-60-002a V1-0 FSC National Risk Assessment Framework, FSC-STD-40-005
V3-0 Requirements for Sourcing FSC Controlled Wood and referred to decisions of the VII General Assembly of FSC
Russia (11-14 April 2016), findings of the Centralized National Risk Assessment (CNRA) for the 1, 2 and 5 category,
consultations with experts and comments received during the first public consultations.
Correspondence of NRA with CNRA:
For CW Category 1
- Results of NRA and CNRA risk assessments are the same for 16 indicators (1.2, 1.4-1.12, 1.14,
1.15, 1.17, 1.19-1.21).
- Thorough analysis of the Russian legislation showed that there is no applicable legislation for the
forest sector in relation to 1 indicator (1.13). This is different from the CNRA findings, which refer to
specified risk.
- Results of NRA and CNRA risk assessments are different for indicator 1.16 because CNRA referred
to the legislКtion аhiМh аКs not вet in forМe. Thus, the inНiМКtor аКs Кssesses Кs “not КppliМКЛle”. At
the moment of NRA development the legislation was already in place. This allowed to conduct a risk
assessment. 3 indicators (1.1, 1.3 and 1.18) are also assessed differently because the NRA working
group considers that these risk designations correspond better to the description and requirements of
indicator assessments and reflect national realities better.
For CW Category 2
- Results of the risk assessments are the same in NRA and CNRA for all indicators (2.1, 2.2, and 2.3).
Even more in NRA, risk related to migrant workers discrimination is assessed as specified and set for
the whole country, while in CNRA it stretches only to 9 subjects of the Russian Federation. In
addition, a new indicator, 2.4, is proposed by the working group on NRA.
For CW Category 3
- CNRA not developed, the category accessed by FSC Russia.
For CW Category 4
- CNRA not developed, yet draft assessment was done by CNRA experts, which was noted by FSC
Russia. The category accessed by FSC Russia.
For CW Category 5
- For its only indicator, 5.1, results of the risk assessment in NRA and CNRA are the same.
NRA development is done according to a timeline confirmed by the Coordination Council of FSC Russia:
2015
2016
2017
2018
May
establishment of the NRA Working Group, collection of information
September development of the first NRA draft
February
evaluation of the first NRA draft by PSU of FSC International Center (FSC IC), feedback analysis,
NRA update
December first public consultation
March
feedback analysis, development of the second NRA draft
July
second public consultation
September feedback analysis, development of the final NRA draft
December evaluation of the final NRA draft by PSU of FSC IC, feedback analysis, final NRA draft update
End of March approval of the NRA
The NRA was developed by the NRA Working Group (NRA-WG), which is represented by the Technical Committee of
FSC Russia. All members of the NRA-WG possess thorough knowledge about FSC, FSC normative documents,
forestry and related national conditions. NRA-WG is established on a chamber-balanced basis with minimum 3
members from each chamber: environmental, social and economic. All NRA-WG members accept the results of risk
evaluation for all controlled wood 5 categories, which are presented within public consultations.
Table 1. Members of the NRA Working Group
Name
Qualification
Contact details
Experience in forest research,
academic research and normative
documents development.
[email protected]
Expert in the field of sustainable
forestry, HCV mapping, and
biodiversity conservation. Broad
experience in FSC standards
development. Member of the
Association “National Working
Group for Voluntary Forest
Certification”, 2005-2010 Chairman of the Coordination
Council of the Association.
[email protected]
Experience in all practical aspects
of certification development.
[email protected]
Experience in forest research,
academic research and normative
documents development.
[email protected]
Practical experience in forest
management certification at the
МompКnв’s level.
[email protected]
m
Practical experience in forest
management certification at the
МompКnв’s level, group mКnКger
Artyom.Zagryadskov@storaenso.
com
Practical experience in forest
management certification at the
МompКnв’s level
[email protected]
Environmental chamber
Aleksey Aleynikov (from April
2016)
- Individual member of FSC
Russia
Mikhail Karpachevskiy (till April
2016)
- Non-commercial partnership
“Transparent World”,
- Individual member of FSC
Russia
Konstantin Kobyakov
- WWF Russia, member of FSC
Russia
- Individual member of FSC
Russia
Anna Nemchinova
- Individual member of FSC
Russia
Economic chamber
Alexey Shorokhov
- LLC Metsa Forest Podporozye
Artyom Zagryadskov
- LLC Stora Enso Forest West
Mikhail Kopeykin (from
December 2016)
- Group of CompКnies “TitКn”
Aleksander Druzhinin (from April
till December 2016)
- Tikhvin Complex Logging
enterprise, International Paper
Practical experience in forest
management certification at the
company’s level
Olga Rogozina (till April 2016)
- Stora Enso Forest West
Practical experience in forest
management certification at the
[email protected]
[email protected]
company’s level, including group
certification.
Elena Pyankova
- ILIM Group
Person in charge of the
МompКnв’s FSC МertifieН forests.
Practical experience in forest
management certification at the
МompКnв’s level.
[email protected]
Social chamber
Antonina Kulyasova (from April
2016)
- Individual member of FSC
Russia
Nadezhda Strakhova (till April
2016)
- Individual member of FSC
Russia
Albert Loginov
- Individual member of FSC
Russia
- Chair of Indigenous Peoples
Local Community (Udora
people)
Nadezhda Efimova (from
December 2016)
- individual member of FSC
Russia
Valeria Moreva (from April till
December 2016)
- individual member of FSC
Russia
Marina Severenchuk (Koroleva)
(till April 2016)
[email protected]
Practical experience in social
aspects of the forest management
certification, including dealing with
traditional peoples, consultant on
FSC social issues
Practical experience in social
aspects of forest management
certification at the company’s
level.
Communication with local
communities and local activists,
including Indigenous Peoples.
[email protected]
[email protected]
[email protected]
Practical experience in social
aspects of the forest management
certification, including local
communities, small holders,
consultant on FSC social issues
[email protected]
Practical experience in social
aspects of the forest management
certification within the Center for
Independent Social Research,
consultant on FSC social issues
Practical experience in social
aspects of forest management
certification, including Indigenous
Peoples and local communities,
at the company’s level.
[email protected]
m
- Individual member of FSC
Russia
2
List of experts involved in the risk assessment and their contact details
Technical experts were involved in writing the first draft of the NRA and providing initial feedback on critical issues.
Table 2. Experts involved in NRA development
Categories 1, 4 and 5
Experts involved in NRA drafting
Kuritsyn Anatoliy
Director, LesExpert LLC
[email protected]
+7 916 150 0532 / +7 499 717
5525
Kuritsyn Aleksey
Deputy Director, LesExpert LLC
[email protected]
+7 909 999 9970
Skype: kuritsin
Experts consulted
Lapokha Yuriy
Entrepreneur, expert on timber
[email protected], [email protected]
+7 914 070 7765 /
+7 951 015 0810
Lukashevich Sergey
Head of the Legal Department,
focal point for FSC certification,
AVA Company LLC
[email protected]
+7 3812 394 949 (
. 119) /
+7 913 150 43 10
Kreyndlin Mikhail
Head of Greenpeace Russia,
programme on specially protected
natural areas
[email protected]
Murashko Olga
Expert, Centre for Support of
Indigenous Peoples of the North,
Anthropology Museum
[email protected]
Gerasimov Vasiliy
Forest management consultant
[email protected]
+7 909 120 2752
Skype: vas.gerasimov
Sungurov Rudolf
Head of the forest management
laboratory, Northern Research
Institute for Forest Management
[email protected]
+7 8182 61 7948
Sulyandziga Rodion
Member of the FSC Permanent
Indigenous Peoples Committee,
Representative of the udeghe
minority Indigenous Peoples
[email protected]
+7 985 751 3636
Zhuravlev Denis
President of the Timber and
RelКteН InНustries Workers’ Union
of Russia
[email protected]
+7 499 124 48 01
Popova Elena
Forest ecology consultant
[email protected]
+7 904 208 7597
Skype: e.a.popova
Sungurov Rudolf
Head of the forest management
laboratory, Northern Research
Institute for Forest Management
[email protected]
+7 8182 61 7948
Head of Greenpeace Russia
forest programme
[email protected]
Category 2
Experts involved in NRA drafting
Expert consulted
Category 3
Experts involved in NRA drafting
Expert consulted
Yaroshenko Aleksey
3
National Risk Assessment maintenance
FSC Russia will ensure that information in NRA remains relevant and up-to-date. FSC Russia will be responsible to
initiКte NRA’s revision КnН upНКte if neeНeН.
1
Questionable issues and decision on revision is taken by its NRA-WG with a final approval by the Coordination
Council of FSC Russia.
4
Complaints and disputes regarding the approved National Risk Assessment
Any person or organization can fill in a complaint regarding the approved NRA.
1. Complaints regarding the approved NRA shall be prepared in written form and submitted to the FSC Russia
by e-mКil or post. A МomplКint shКll inМluНe the informer’s nКme, МontКМt НetКils, the МomplКint НesМription КnН
the proposed actions to be taken.
2. FSC Russia shall confirm the receipt of the complaint in written form within two (2) weeks from its receipt.
3. The NRA-WG shall examine the complaint within 30 calendar days. The duration for complaint examination
can be prolonged up to 60 calendar days, when additional information shall be requested or collected.
4. The decision on the complaint is taken by the NRA-WG on consensus basis between representatives of the
three chambers: environmental, social and economic.
5. The complaint informer will receive the final decision of the NRA-WG within 31 days from the time when the
complaint receipt was confirmed. If the NRA-WG requested additional time for complaint examination, it shall
inform the complaint informer about it within the first 30 days and provide its final decision within 61 days from
the time when the complaint receipt was confirmed.
6. If the complaint informer is not satisfied with the decision of the NRA-WG, he/she can submit the complaint to
the Coordination Council of FSC Russia. The Coordination Council shall confirm the receipt of the complaint
within two (2) weeks and shall provide the informer with the official answer in written form within 30 days from
the date of the confirmation.
7. If the МomplКint informer is not sКtisfieН аith the CoorНinКtion CounМil’s НeМision he/she МКn use the
provisions and follow the process described in FSC-PRO-01-008 V2-0 Processing Complaints in the FSC
Certification Scheme.
8. All complaints regarding the approved NRA are registered in the NRA Complaint Register of FSC Russia.
Information in the Register inМluНes МomplКint informer’s nКme, НКte of МomplКint reМeipt КnН Мlosure,
complaint description, description of complaint examination and final actions taken by the NRA-WG or the
Coordination Council in case of appeals.
5
List of key stakeholders for consultation
The list shows key stakeholders who were approached during public consultations and provided their comments
(Note: below is the list of key stakeholders to be contacted within the first public consultations).
Environmental interests
WWF Russia, Greenpeace Russia, Russian Bird
Conservation Union, mailing list of all stakeholders
registered in FSC Russia, mailing list of all
environmental chamber members of Association
NRG
Social interests
Unions/organizations of indigenous peoples (komi,
etc.), Russian forestry labour union, FSC consultants
on social issues2, mailing list of all stakeholders
registered in FSC Russia, mailing list of all social
chamber members of Association NRG
Economic interests
IKEA TORG, ILIM Group, Mondi SLPK, Stora Enso
Forest West, International Paper, Russian Forest
Group, FSC consultants mailing list of FSC certificate
holders in Russia, mailing list of all economic
chamber members of Association NRG
General
Federal Forestry Agency, FSC-accredited certification
bodies working in Russia
1
Within FSC Russia NRA-WG is represented by Technical Committee, which carries out all the duties for national
standard development, national interpretations and other technical issues related to standard setting.
2
The list of registered with FSC Russia consultants is available on https://ru.fsc.org/ru-ru/cert/consult
6
Risk assessment
Area under assessment: Russian Federation
National risk assessment (NRA) is made for the whole territory of the Russian Federation. It is based on information
from open sources, such as scientific and NGO reports, media publications, analysis of regulatory framework and
consultations with experts.
For each indicator the risk designation is based on gathered information and its correlation to thresholds, violation or
conformation of conditions, which justify the level of risk. If the gathered information complies with low risk threshold,
КnН there is no other informКtion thКt, аhen КssemЛling Кll eviНenМe, leКНs to К ‘speМifieН risk’ НesignКtion,
low risk is designated. If gathered information shows any possibility for threshold violation, then designation of
specified risk is justified.
Control measures are developed for indicators with specified risk. Implementation of control measures shall ensure
mitigation of risk of using unacceptable wood by certified organizations. If implementation of control measures does
not help to lower the risk, wood cannot be purchased as controlled wood and used within the FSC system.
Some control measures are mandatory for implementation, some are recommended. Implementation of control
measures will be evaluated by FSC accredited certification bodies during audits.
How to read the risk assessment table?
The table for CW Categories 1, 2, 4 and 5:
Indicator
Source of
information
Indication of
risk, evidence
used
1
2
3
Functional scale
Risk designation
and specification (if not ‘low risk’)
Provide numbers of thresholds that
are met and justify the outcome for
each threshold
Control Measures
M – mandatory
R – recommended
4
5
6
Description of columns:
1. Number and name of the indicator.
2. Reference numbers of information sources are listed in the column. At the end of the NRA, the information sources
are grouped in 3 Annexes: information sources for CW Categories 1, 4 and 5 are listed in Annex 1.1; information
sources for CW Category 2 are listed in Annex 1.2; and information sources for CW Category 3 are listed in Annex
1.3. The column will be useful for the readers who would like to understand what information justifies the
designated level of risk.
3. The column provides evidence for the designated level of risk.
4. The column shows the non-geographical characteristics that were used for dividing the territory into areas of low
and specified risk. The column is important for all NRA users because the risk assessment for a potential supplier
will depend on the information in this column.
If Not applicable is written in the column, it means that the geographical division was used. Usually this refers to
specified risk for the entire Russian territory. For some indicators, it refers to specified risk for some of the
constituent entities of the Russian Federation (knoаn Кs “feНerКl suЛjeМts of the RussiКn FeНerКtion”).
5. The column lists thresholds with which obtained information was compared. The thresholds are identified in the
FSC procedure FSC-PRO-60-002a. This column is interesting for the readers who would like to better understand
the technic applied for the risk assessment.
6. This column is of crucial importance for NRA users because it includes mandatory or recommended actions that
shall or may be taken by the organization for risk mitigation. In case of low risk, control measures are not needed.
Table for CW Category 3:
HCV
category
and
indicator
Data used for HCV
identification
1
2
Identified
threats
Indication of
risk, evidence
used
3
4
Functional
scale
Risk designation
and specification (if not ‘low risk’)
Provide numbers of thresholds
that are met and justify the
outcome for each threshold
Control Measures
M – mandatory
R – recommended
5
6
7
The table for CW CКtegorв 3 Нiffers from the tКЛle for CКtegories 1, 2, 4 КnН 5 onlв in Мolumn № 3 аhiМh speМifies
threats to high conservation values (HCVs). This information is interesting for the readers who would like to know how
forest management activities threaten each HCV type.
6.1
Controlled Wood Category 1: Illegally harvested wood
3
The volume of harvested wood FSC 100% in 2014 in Russia is estimated to be about 40 mln m as for the beginning
of 2015. The volume of controlled wood which comes from uncertified suppliers and is largely used by medium and
large FSC certified wood processing companies is about 80 mln m3. The overall volume of harvested wood in Russia
3
3
is about 200 mln m . These numbers show the importance of FSC controlled wood for FSC in Russia .
Traditions of centralized forest management, which were set during the state-planned economy (i.e. until the 1990s),
still prevail in Russia:
Property rights belong to the state or municipalities*;
All contracts for wood harvesting are done between state or municipal authorities responsible for forest
management and private forest managers;
The state controls the orgКniгКtions’ МompliКnМe with forest legislation and other regulations.
From 2007 to 2013 there was no system for state recording of volumes of harvested and processed wood. It lead to
increase of illegally harvested wood. As a result foreign woodworking companies requested their Russian partners to
confirm wood legality through FSC certification scheme.
In 2014 К neа feНerКl lКа №415-FZ dated 27.12.2013 came into force which regulates recording of harvested and
processed wood volumes. The law states that property rights for transported wood have to be confirmed by a specific
accompanying document and documents confirming roundwood harvesting and business transaction.
4
In order to comply with Regulation (EU) No 995/2010 Russia has adopted a series of normative documents in 20132015. The documents were targeted at combating illegal wood harvesting. As a result from 1 January 2014 a federal
law № 415-FZ of 28 DeМemЛer “On КmenНing RussiКn Forest CoНe and Russian Code of Administrative Offences”
entered into force (Annex 2.1 (18)). The law introduced changes in fighting against sale of illegally harvested wood
(chapters of the Russian Forest Code 2.1 “WooН accounting КnН lКЛelling”, 2.2 “WooН trКnsportКtion” КnН 2.3 “Unified
State Automated Information System for Accounting of Wood and Deals with It” (EGAIS)) and a new article 8.28.1
“ViolКtion of forest legislКtion on КММounting of Unified State Automated Information System for Accounting of Wood
and Deals with It аooН КnН НeКls аith it” to the RussiКn CoНe of AНministrКtive OffenМes.
A relatively large number of new governmental decrees were adopted in order to support changes in federal laws: №
55 of 28 JКnuКrв 2015 “On Approving Кn OperКting ProМeНure for the Unified State Automated Information System
for Accounting of Wood and Deals with It”; № 11 of 6 January 2015 “On Approving Rules for Submission of
Declaration on Deals with Wood”; № 1525 of 26 DeМemЛer 2014 “On Approving Rules for AММounting of WooН”, №
571 of 21 June 2014 “On AММompКnвing DoМument for WooН TrКnsportКtion”; № 1301 of 3 DeМemЛer 2014 “On
Approving Rules for Information Submission to the Unified State Automated Information System for Accounting
of Wood and Deals with It”; № 1161 of 4 November 2014 “On Approving a Provision on labeling wood of valuable
forest species (oak, beech, ash) (Annex 2.1 (27, 61, 54-56, 58).
The issue of criminal and legal protection of forests from illegal wood harvesting is covered in article 260 of the
Russian Criminal Code (Annex 2.1 (17)). Logging of trees, bushes and lianas in forest areas or areas that are not
seen as forest areas, as stated in the article 260 of the Russian Criminal Code, shall be interpreted as their sawing off,
logging or cutting off by different means of tree trunks, stems of bushes and lianas from their roots.
Illegal logging in the mentioned above areas is logging with violation of legislative requirements for example logging
without necessary documents (including lease agreements, decisions on assigning a forest unit, forest development
project, which was approved by state or municipal expertise, forest stands sale agreements, state or municipal
contract for carrying our work on forest safeguarding, protection and regeneration), in quantity exceeding the
approved volume, logging other than approved species or age composition, our outside of the approved cutting area
(Annex 2.1 (9)).
Federal law of 21 July 2014 № 277-FZ “On amending normative framework of the Russian Federation” (Anneб 2.1
(39)) introduced changes to the Russian Criminal Code, article 191.1, which states criminal responsibility for
purchasing, keeping, transportation, processing for the purpose of sale, and sale of knowingly illegally harvested
wood.
Expert estimates made by the Center for Standardization and Certification of RounН TimЛer КnН LumЛer “LesEбpert”
Regulation (EU) No 995/2010 of the European Parliament and of the Council of 20 October 2010 laying down the obligations of
operators who place timber and timber products on the market Text with EEA relevance
3
4
10
Risk designation
Control
and specification (if not ‘low risk’)
Measures
Provide numbers of thresholds5 that are met and
M – mandatory
justify the outcome for each threshold
R - recommended
In the majority of cases wood is harvested on forestlands, defense and security lands and in the smaller volumes in protected nature areas. Logging and dealing with such wood is fully described in Russian
legislation. Executive authorities of the subjects of the Russian Federation manage forest units located on these lands.
It can be stated that also there are forests on agricultural lands, some of which are meant for protection from negative nature, anthropogenic or technogenic disasters. In addition to it there are overgrown
agricultural lands. This has happened due to their longstanding nonexploitation. Experts estimate these lands to be from 50 to 100 mln ha. These lands are not subject to conversion to forestlands and are
regulКteН Лв the lКа “On КgriМulturКl lКnН trКnsКМtions” (Anneб 1.1 (10), Anneб 2.1 (5)). For these lКnНs there Кre no forest planning and management. The process of harvesting and procedures of selling and
purchase of wood from these territories are not yet reflected in the state legislation.
Therefore wood harvested on overgrown agricultural lands temporarily is not considered as FSC controlled wood and is not assessed in the current document. In case of changes in relevant legislation the
decision about assessing wood harvested on overgrown agricultural lands as controlled wood will be reconsidered and relevant changes to NRA will be made.
Indicator
Source of
information
(Annex 1.1)
1.1 Land
tenure and
management
rights
Annex 1.1 (1, 2, 7,
8, 9, 30, 31);
Annex 2.1 (1, 2, 5,
6)
Indication of risk, evidence used
Low risk
State forestlands account for 96,8% of all forestlands in
Russia. It is either state or municipal owned. Relevant
tenure and management rights are regulated by the
Forest and Land Codes and other normative framework
developed in accordance with them (Annex 2.1 (1, 7)).
Defense and security lands are in possession of the
Ministry of Defense. State management of forestry
related issues is handled by the federal state
autonomous enterprise “Department of Forest
Management” of the Ministrв of Defense through 39
forest districts (lesnichestvo) listed in its Chapter (Annex
2.1 (5)). Square surface of forests located on these
territories is 0,4% of all Russian forestlands.
Functional scale
Not applicable
(low risk for entire country)
Low risk
Not required
Loа risk thresholН (thresholН № 1
Identified laws are upheld. Cases
where law/regulations are violated
are efficiently followed up via
preventive actions taken by the
authorities and/or by the relevant
entities from FSC-PRO-60-002a) is
met
Land tenure and management rights
belong to the state. There are no
evidences of other holders of
forestland tenure rights.
There are no evidences of other holders of forestland
tenure rights.
Taking into account that wood harvesting companies are
not the owners of forestlands, but the users holding
concession licenses (see indicator 1.2) the risk is
assessed as low.
1.2
Concession
licenses
Annex 1.1 (1, 2, 3,
4, 6, 10, 11,12,13,
30,31), Annex 2.1
(1, 8 ,9,10)
Specified risk
Not applicable
Specified risk
Lease agreements and agreements for gratuitous use
are evaluated in this indicator.
(specified risk for entire country)
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
FSC-PRO-60-002a) is met
All forests in Russia are state-owned and there are no
private forests. Forests can be licensed as concessions
to enterprises for a period from 1 to 49 years, based on
the results of auctions conducted by the authorities.
The following risks are identified:
The risk of violation of legislation,
unfair competition and corruption of
state authorities during bidding for
All rights are regulated by Russian legislation.
Forests can also be licensed as concessions based on
decisions of the Government of the Russian Federation
11
M – verification of availability of
either concession license
concluded according to legislation
or agreement for gratuitous use,
as well as verification of presence
of such a concession agreement in
EGAIS.
R – monitoring of mass media,
court orders and publications in
order to exclude cases of violation
of legislation by a supplier, facts of
corruptions by authorities during
bidding for forest units and/or
issuing concession licenses.
without any auctions. Concessions are concluded with a
purpose to implement "priority investment project in the
sphere of forest exploitation" by a concession holder.
The government oversees competitive bidding among
such projects.
forest units and issuing concession
licenses.
Unfair competition exists in concluding a concession
agreement, as well as corruption. According to a worldknown ranking on Corruption Perception Index Russia is
on the 131 place out of 176.
1.3
Management
and
harvesting
planning
Annex 1.1 (7, 2224, 91)
Annex 2.1 (1, 1113, 66)
Low risk
Not applicable
Management and harvesting planning in Russia is done
according to the following normative documents: Forest
Plan (on the level of a subject of the Russian
Federation), forestry regulations (on the level of forest
districts), and Forest Development Project (on the level
of a forest unit in lease). Control over forest
management is established and carried out in such a
way that if the mentioned above documents are not in
place or are not approved through a valid procedure, it is
almost impossible to receive subsequent documents
authorizing concrete forest management activities.
(low risk for entire country)
Low risk
Loа risk thresholН (thresholН № 1
Identified laws are upheld. Cases
where law/regulations are violated
are efficiently followed up via
preventive actions taken by the
authorities and/or by the relevant
entities from FSC-PRO-60-002a) is
met
Forest Plans for subjects of the
Russian Federation and forestry
regulations for forest districts are
approved on the governmental level
according to the legislation of the
Russian Federation. Forest
Development Project for the forest
unit in lease also must be developed
according to the national legislation.
No cases of any long-term and/or
large-scale management activities
carried out in the absence of
legitimately approved documents for
forest management are known to
experts of the NRA-WG.
Known cases when documents for management
planning and issued according to them harvesting
permits were canceled, only prove that control over
existing and valid procedure for obtaining the documents
is effective.
There are no known cases of any long-term and/or
large-scale management activities carried out in the
absence of legitimately approved documents for forest
management.
Therefore the risk can be assessed as low.
12
Not required
1.4
Harvesting
permits
Annex 1.1 (5, 2224, 26, 27, 34, 35,
36, 37, 60-63, 95,
96), Annex 2.1 (1,
9, 14-17, 20)
Specified risk
The problem of illegally harvested wood shows the
necessity to verify the existence of harvesting enabling
documents.
Not applicable
Specified risk
(specified risk for entire country)
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
FSC-PRO-60-002a) is met
Documents entitling wood harvesting in Russia are:
Forest declarations,
Forest stands sale agreements.
The problem of illegal harvesting ( in the absence of
such enabling documents) is recognized by
governmental forestry authorities. Publicly available
evidences exist.
There are cases of harvesting without such documents
(Annex 1.1 (14, 61, 22-24,26, 35-37, 95,96)).
There are case of issuing such documents without
following legal requirements (Annex 1.1 (14, 27, 36, 60,
62, 63)).
1.5 Payment
of royalties
and
harvesting
fees
Annex 1.1 (16,
17), Annex 2.1 (8,
10, 14-18, 67, 68)
Specified risk
Information about debtors among lease agreements
holders from various subjects of the Russian Federation
is available on the official website of the Federal Forestry
Agency and in other information sources (Annex 1.1 (16,
17)).
Risks related to wood harvesting
enabling documents are identified:
Harvesting without these
documents (illegal
harvesting)
Issuing the documents
without following legal
requirements.
Not applicable
Specified risk
(specified risk for entire country)
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
FSC-PRO-60-002a) is met
If harvesting is enabled by forest stands sale
agreements (Annex 2.1 (67, 68)) there is no possibility of
any leases debts, because the agreements are
concluded on the prepayment basis.
Risk of dealing with wood harvested
with violation of Russian legislation
on lease payments is identified.
M – verification of availability of
forest declaration issued on the
basis of concession license or
agreement for gratuitous use
or
M – verification of availability of
forest stands sale agreement
concluded according to legal
requirements
R - monitoring of mass media,
court orders and publications in
order to exclude cases of violation
of legislation by a supplier, facts of
corruptions by authorities during
issuing harvesting enabling
documents.
M – upon concluding a contract
and later on periodically but not
less than once per year verify that
forest manager does not have any
debts for lease agreements, for
verification use websites of:
Federal Forestry Agency
http://www.rosleshoz.go
v.ru/activity/finance/stat
Regional forestry
executive authorities
Other information
sources.
In case of information about debts
is available:
M – request from forest manager
documents confirming that there is
no debt (payment document
confirming that lease payment has
been done in due time as stated in
the lease agreement; documents
confirming amicable settlements,
postponed payments, payment by
installments for lease debts).
13
1.6 Value
added taxes
and other
sales taxes
Annex 1.1
(19,20,22), Annex
2.1 (21)
Specified risk
Information from the Data Bank of the Execution
Proceedings shows that there are debtors violating
requirements of the Russian Tax Code (please also refer
to indicator 1.7).
Not applicable
(specified risk for entire country)
Specified risk
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
FSC-PRO-60-002a) is met
Risk of dealing with wood harvested
in violation of the Russian Tax Code
is identified.
1.7 Income
and profit
taxes
Annex 1.1 (19, 20,
25), Annex 2.1
(21)
Specified risk
Information from the Data Bank of the Execution
Proceedings shows that there are debtors violating
requirements of the Russian Tax Code (please also refer
to indicator 1.6).
Not applicable
(specified risk for entire country)
Specified risk
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
FSC-PRO-60-002a) is met
Risk of dealing with wood harvested
in violation of the Russian Tax Code
is identified.
1.8 Timber
harvesting
regulations
Annex 1.1 (14,15,
24, 36-45)
Annex 2.1 (1, 4,
17-20, 22-31)
R - upon concluding a contract
and later on periodically but not
less than once per year verify that
forest manager does not have any
debts regarding tax payments to
the budget on the website of the
Federal Tax Service (Annex 1.1
(20)
And / or on the website of the
Federal Bailiff Service (Annex 1.1
(19)
R - upon concluding a contract
and later on periodically but not
less than once per year verify that
forest manager does not have any
debts regarding tax payments to
the budget on the website of the
Federal Tax Service (Annex 1.1
(20)
And / or on the website of the
Federal Bailiff Service (Annex 1.1
(19)
Specified risk
Not applicable
Specified risk
Failure to comply with requirements of timber harvesting
rules, forest care and sanitary rules related to timber
harvesting, as well as failure to perform works
considered by the contract, violation of harvesting
deadlines or their implementation by improper
procedures and methods are common for harvesting
activities.
(specified risk for entire country)
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
FSC-PRO-60-002a) is met.
M - On-site inspection of
harvesting sites in forest units,
verification of compliance with
requirements of timber harvesting
rules, forest care and sanitary
rules related to timber harvesting
the requirements of harvesting
rules, rules of forest care and
sanitary rules in the part related to
logging.
Risk of non-compliance with
requirements of timber harvesting
rules, forest care and sanitary rules
related to timber harvesting, as well
as with harvesting enabling
documents, in particular:
• risk of Мutting in plКМes not
specified in harvesting enabling
documents,
• risk of Мutting Нuring К perioН
M – during visits to harvesting
sites carry out:
• verifiМКtion of МompliКnМe аith
technology and requirements
specified in technological maps;
• seleМtive verification of
harvesting site acceptance reports
and work acceptance reports for
performed for thinnings, sanitary
cuttings.
Violations are recorded by bodies authorized for
safeguarding and protection of the forest fund (Annex
2.1 (17, 18)). Supervision over the implementation of
legislation is carried out by executive authorities of the
subjects of the Russian Federation.
Reports of NGOs and regional prosecutors show
evidence of non-compliance with requirements for
harvesting activities.
Annex 1.1 (24, 35, 45).
14
not specified in harvesting
enabling documents (before or
after).
There are facts of tree cutting before or after the expiry
date of harvesting enabling documents (Annex 1.1 (14,
15)).
R - consultations with
representatives of forest districts
(lesnichestvo) for identification if
wood supplier has performed any
cutting beyond his official
harvesting area.
Schedule, frequency, sampling
criteria are to be set by the
organization.
M - Verification of compliance with
harvesting deadlines specified in
forest declaration or in a wood
purchase/sale agreement.
M – Information requests from
forest districts (lesnichestvo) about
detected violations for:
a) presence of documented
violations of the above-mentioned
normative framework by the
supplier, their frequency and
severity of the damage caused;
B) presence of violations of the
above-mentioned normative
framework, which have not been
corrected in the due time (fines
have not been paid, damages
have not been paid,
consequences of violations have
not been rectified).
R - monitoring of mass media,
court orders and publications in
order to exclude cases of violation
of above-mentioned harvesting
related normative framework by a
supplier.
15
1.9 Protected
sites and
species
Annex 1.1 (33, 4659, 61, 62-68)
Annex 2.1 (1, 3, 4,
17, 18, 29-36, 45)
Specified risk
Not applicable
Specified risk
There are forest areas with different forest use
restrictions in the Russian Federation: protected nature
areas (PNA), protection forests and forests located on
forested areas with a special protection regime (Annex
2.1 (1).
There are evidence of violations of established in PNA
regimes, violations of legislation during harvesting in
protection forests and forests located on forested areas
with a special protection regime. There are examples of
commercial harvesting in protection forests under the
guise of sanitary felling.
(specified risk for entire country)
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
FSC-PRO-60-002a) is met
The risk of violation of established
forest management regimes in
protected nature areas, protection
forests and forests located on
forested areas with a special
protection regime as well as risk of
harvesting timber of species cutting
of which is prohibited is identified.
There are evidence of violations of the normative
framework specified in Annex 2.1.
Risk of reduction of forest protection
functions due to excessive
harvesting under the guise of
sanitary felling in protected nature
areas, protection forests and forests
located on forested areas with a
special protection regime is
identified.
M - Verification of forest
declarations and purchase/sale
agreements to be in compliance
with established regime of forest
management in protected nature
areas (PNA), protection forests
and forests located on forested
areas with a special protection
regime.
M – verification of absence of
species prohibited for harvesting,
in supplies of an organization.
M - verification of species
prohibited for harvesting, in acts of
inspection of logging sites and
reports on the use of forests (1) during on-site inspections.
M - in the presence of a permit for
sanitary cuts, on-site verification of
the relevance of such sanitary
and health measures.
Schedule, frequency, sampling
criteria are to be set by the
organization.
R - monitoring of mass media,
court orders and publications in
order to exclude cases of violation
of established regimes of forest
management in protected nature
areas (PNA), protection forests
and forests located on forested
areas with a special protection
regime and harvesting of species
prohibited for harvesting by a
supplier.
1.10
Environment
al
requirements
Annex 1.1 (24, 32,
33, 36, 45, 65-69)
Annex 2.1 (3, 4,
16, 31, 37-38)
Specified risk
Not applicable
Specified risk
Russian Forest Code states that forests have to be
protected from fires, pollution and other negative impact.
(specified risk for entire country)
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
However cases of forest contamination (abandonment of
household and industrial waste in the forest, soil, water
and vegetation contamination with fuel spills) are
16
О - On-site inspection of forest
sites in harvesting areas,
verification of compliance with
environmental legislation during
wood harvesting activities.
Schedule, frequency, sampling
criteria are to be set by the
organization.
recordered. Negative impacts resulted from forest
harvesting activities are identified in a form of erosion
and soil compaction, drainage disorders in rivers and
streams, flooding, marsh formation of after-cut territories
and neighboring areas, and etc. (Annex 1.1 (24, 32, 33,
45, 48, 65, -69)
Other environmental requirements are covered in
indicators 1.8, 1.9.
1.11 Health
and safety
1.12 Legal
employment
FSC-PRO-60-002a) is met
Risk of dealing with wood harvested
with repeated and/or damaging
nature violations of Russian
environmental legislation
(abandonment of household and
industrial waste in the forest, soil,
water and vegetation contamination
with fuel spills and other negative
impacts) is identified.
Annex 1.1 (70-73)
Specified risk
Not applicable
Specified risk
Annex 2.1 (17-18,
39-41)
General provisions on health and safety of workers are
included in the Russian Labor Code. The organization is
obliged to establish safe environment for work, while
workers have to follow health and safety rules. However
violation of health and safety requirements in forestry
sector is noted in many regions of Russia.
(specified risk for entire country)
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
FSC-PRO-60-002a) is met
Annex 1.1 (74-78)
During logging activities, the following violations of
health and safety rules occur:
- partial provision of workers with personal protective
equipment (PPE);
- unsettled working and rest hours;
- unsatisfactory sanitary and household security of
employees;
- violation of technological process;
- non-compliance of workers with rules and regulations
on health and safety.
Specified risk
Annex 2.1 (17, 18,
39-41)
Cases of Russian Labor Code violation are identified in
Russia.
Risk of dealing with wood harvested
with violation of health and safety
requirements is identified.
Not applicable
Specified risk
(specified risk for entire country)
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
FSC-PRO-60-002a) is met
The following violations by the employer are noted:
- violations related to conclusion of employment
contracts;
- violation related to payment of wages and other
amounts due, (including payments for vacation leaves,
payment upon resignation);
- violation of a procedure of employee resignation;
as well as violations in the field of discrimination at the
workplace, use of child labor and convict labor (see
indicator 2.2).
Risk of dealingwith wood harvested
with violation of labor legislation
related to to conclusion of
employment contracts and staying in
compliance with it, including violation
related to payment of wages and
other amounts due.
17
R - monitoring of mass media,
court orders and publications in
order to exclude cases of violation
of environmental legislation by a
supplier.
M - On-site inspection to assess
compliance with health and safety
requirements, including
maintenance of proper working
and rest hours, availability and
condition of PPE, compliance with
safety regulations, compliance
with techniques and requirements
for development of logging sites
specified in a technological map
and related to safe performance of
work.
Schedule, frequency, sampling
criteria are to be set by the
organization.
M – Verification of existence and
compliance with requirements of
employment contracts concluded
between employees and
employers in accordance with
Russian Labor Code
M - Interviews with employees of
an organization during on-site
inspections
Schedule, frequency, sampling
criteria are to be set by the
organization.
1.13
Customary
rights
-
Not applicable
Analysis of the normative framework and consultations
with experts from the Centre for Support of Indigenous
Peoples of the North and Greenpeace Russia (please
see Table 2, page 5) revealed that in the Russian
legislation there are no legislative acts that clarify or
regulate customary rights as they are described by FSC
(КММorНing to МustomКrв right’s НesМription in FSC-STD60-004 V1-0 International Generic Indicators and
explanation of indicator 1.13 in FSC-PRO-60-002a).
Therefore applicable legislation is not identified.
Not applicable
Not applicable
Not required
1.14 Free,
Prior and
Informed
Consent
-
Not applicable
Analysis of the normative framework and consultations
with experts from the Centre for Support of Indigenous
Peoples of the North, Greenpeace Russia (please see
Table 2, page 5) revealed that there is no applicable
legislation in Russia.
Not applicable
Not applicable
Not required
Specified risk
Not applicable
Specified risk
This indicator examines the rights of indigenous peoples,
as stipulated by the current legislation on indigenous
peoples of the North, and related to forest management.
(geographical scale on a level of
the subjects of the Russian
Federation, please see Annex
3.1)
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
FSC-PRO-60-002a) is met
M – confirmation of supporting
indigenous peoples rights through
interview with representatives of
indigenous peoples.
1.15
Indigenous
peoples’
rights5
Annex 1.1 (62, 81,
82)
Annex 2.1 (1-4,
17-18, 41-50, 58)
The status and rights of indigenous and small-numbered
peoples are spelled out in the federal law "On
Guarantees of Indigenous Peoples Rights in the Russian
Federation" and a number of other laws and by-laws
from Annex 2.1.
R - monitoring of mass media,
court orders and publications in
order to exclude cases of violation
of indigenous peoples rights by a
supplier.
The i
For the Russian Federation
DEVELOPED ACCORDING TO PROCEDURE FSC-PRO-60-002 V 3-0
Draft quality translation
Version
V 3-0 Draft 2-0 for public consultations
from 19.07.2017-31.08.2017
Code CWNRA-RU-V3-0
National approval
Coordination Council, AssoМiКtion “NRG”
Date
FSC International Center: Policy and
International approval Standards Unit
Date:
International contact
Period of validity
Name:
Email address:
Date of approval:
Valid until: (date of approval + 5 years)
Body responsible for NRA maintenance FSC Russia, XXX
Summary of risk for the Russian Federation
Controlled Wood categories
Risk level (including
functional scale when
relevant)
1
Illegally harvested wood
Specified risk
2
Wood harvested in violation of traditional and human
rights
Specified risk
3
Wood from forests where high conservation values are
threatened by management activities
Specified risk
4
Wood from forests being converted to plantations or nonforest use
Low risk
5
Wood from forests in which genetically modified trees are
planted
Low risk
Contents
1.
Background information
2.
List of experts involved in the risk assessment and their contact details
3.
National Risk Assessment maintenance
4.
Complaints and disputes regarding the approved National Risk Assessment
5.
List of key stakeholders for consultation
6.
Risk assessment (for each area under assessment)
6.1
Category 1: Illegally harvested wood
6.2
Category 2: Wood harvested in violation of traditional and human rights
6.3
Category 3: Wood from forests where high conservation values are threatened by management activities
6.4
Category 4: Wood from forests being converted to plantations or non-forest use
6.5
Category 5: Wood from forests in which genetically modified trees are planted
Annex 1.1
List of information sources for categories 1, 4 and 5
Annex 1.2
List of information sources for category 2
Annex 1.3
List of information sources for category 3
Annex 2.1
Identification of applicable legislation for categories 1, 4 and 5
Annex 2.2
Identification of applicable legislation for category 2
Annex 2.3
Identification of applicable legislation for category 3
Annex 3.1
List of indigenous peoples and subjects of the Russian Federation where indigenous peoples
complying with criteria of ILO C No.169 are present
1
Background information
FSC National Risk Assessment (NRA) for the Russian Federation is developed by FSC Russia (represented by
AssoМiКtion “NКtionКl Working Group for VoluntКrв Forest CertifiМКtion”) for the neeН of FSC МertifieН orgКniгКtions
sourcing wood from uncertified suppliers for further use with FSC Controlled Wood claim.
The NRA Working Group followed the requirements of FSC-PRO-60-002 V3-0 The Development and Approval of FSC
National Risk Assessments, FSC-PRO-60-002a V1-0 FSC National Risk Assessment Framework, FSC-STD-40-005
V3-0 Requirements for Sourcing FSC Controlled Wood and referred to decisions of the VII General Assembly of FSC
Russia (11-14 April 2016), findings of the Centralized National Risk Assessment (CNRA) for the 1, 2 and 5 category,
consultations with experts and comments received during the first public consultations.
Correspondence of NRA with CNRA:
For CW Category 1
- Results of NRA and CNRA risk assessments are the same for 16 indicators (1.2, 1.4-1.12, 1.14,
1.15, 1.17, 1.19-1.21).
- Thorough analysis of the Russian legislation showed that there is no applicable legislation for the
forest sector in relation to 1 indicator (1.13). This is different from the CNRA findings, which refer to
specified risk.
- Results of NRA and CNRA risk assessments are different for indicator 1.16 because CNRA referred
to the legislКtion аhiМh аКs not вet in forМe. Thus, the inНiМКtor аКs Кssesses Кs “not КppliМКЛle”. At
the moment of NRA development the legislation was already in place. This allowed to conduct a risk
assessment. 3 indicators (1.1, 1.3 and 1.18) are also assessed differently because the NRA working
group considers that these risk designations correspond better to the description and requirements of
indicator assessments and reflect national realities better.
For CW Category 2
- Results of the risk assessments are the same in NRA and CNRA for all indicators (2.1, 2.2, and 2.3).
Even more in NRA, risk related to migrant workers discrimination is assessed as specified and set for
the whole country, while in CNRA it stretches only to 9 subjects of the Russian Federation. In
addition, a new indicator, 2.4, is proposed by the working group on NRA.
For CW Category 3
- CNRA not developed, the category accessed by FSC Russia.
For CW Category 4
- CNRA not developed, yet draft assessment was done by CNRA experts, which was noted by FSC
Russia. The category accessed by FSC Russia.
For CW Category 5
- For its only indicator, 5.1, results of the risk assessment in NRA and CNRA are the same.
NRA development is done according to a timeline confirmed by the Coordination Council of FSC Russia:
2015
2016
2017
2018
May
establishment of the NRA Working Group, collection of information
September development of the first NRA draft
February
evaluation of the first NRA draft by PSU of FSC International Center (FSC IC), feedback analysis,
NRA update
December first public consultation
March
feedback analysis, development of the second NRA draft
July
second public consultation
September feedback analysis, development of the final NRA draft
December evaluation of the final NRA draft by PSU of FSC IC, feedback analysis, final NRA draft update
End of March approval of the NRA
The NRA was developed by the NRA Working Group (NRA-WG), which is represented by the Technical Committee of
FSC Russia. All members of the NRA-WG possess thorough knowledge about FSC, FSC normative documents,
forestry and related national conditions. NRA-WG is established on a chamber-balanced basis with minimum 3
members from each chamber: environmental, social and economic. All NRA-WG members accept the results of risk
evaluation for all controlled wood 5 categories, which are presented within public consultations.
Table 1. Members of the NRA Working Group
Name
Qualification
Contact details
Experience in forest research,
academic research and normative
documents development.
[email protected]
Expert in the field of sustainable
forestry, HCV mapping, and
biodiversity conservation. Broad
experience in FSC standards
development. Member of the
Association “National Working
Group for Voluntary Forest
Certification”, 2005-2010 Chairman of the Coordination
Council of the Association.
[email protected]
Experience in all practical aspects
of certification development.
[email protected]
Experience in forest research,
academic research and normative
documents development.
[email protected]
Practical experience in forest
management certification at the
МompКnв’s level.
[email protected]
m
Practical experience in forest
management certification at the
МompКnв’s level, group mКnКger
Artyom.Zagryadskov@storaenso.
com
Practical experience in forest
management certification at the
МompКnв’s level
[email protected]
Environmental chamber
Aleksey Aleynikov (from April
2016)
- Individual member of FSC
Russia
Mikhail Karpachevskiy (till April
2016)
- Non-commercial partnership
“Transparent World”,
- Individual member of FSC
Russia
Konstantin Kobyakov
- WWF Russia, member of FSC
Russia
- Individual member of FSC
Russia
Anna Nemchinova
- Individual member of FSC
Russia
Economic chamber
Alexey Shorokhov
- LLC Metsa Forest Podporozye
Artyom Zagryadskov
- LLC Stora Enso Forest West
Mikhail Kopeykin (from
December 2016)
- Group of CompКnies “TitКn”
Aleksander Druzhinin (from April
till December 2016)
- Tikhvin Complex Logging
enterprise, International Paper
Practical experience in forest
management certification at the
company’s level
Olga Rogozina (till April 2016)
- Stora Enso Forest West
Practical experience in forest
management certification at the
[email protected]
[email protected]
company’s level, including group
certification.
Elena Pyankova
- ILIM Group
Person in charge of the
МompКnв’s FSC МertifieН forests.
Practical experience in forest
management certification at the
МompКnв’s level.
[email protected]
Social chamber
Antonina Kulyasova (from April
2016)
- Individual member of FSC
Russia
Nadezhda Strakhova (till April
2016)
- Individual member of FSC
Russia
Albert Loginov
- Individual member of FSC
Russia
- Chair of Indigenous Peoples
Local Community (Udora
people)
Nadezhda Efimova (from
December 2016)
- individual member of FSC
Russia
Valeria Moreva (from April till
December 2016)
- individual member of FSC
Russia
Marina Severenchuk (Koroleva)
(till April 2016)
[email protected]
Practical experience in social
aspects of the forest management
certification, including dealing with
traditional peoples, consultant on
FSC social issues
Practical experience in social
aspects of forest management
certification at the company’s
level.
Communication with local
communities and local activists,
including Indigenous Peoples.
[email protected]
[email protected]
[email protected]
Practical experience in social
aspects of the forest management
certification, including local
communities, small holders,
consultant on FSC social issues
[email protected]
Practical experience in social
aspects of the forest management
certification within the Center for
Independent Social Research,
consultant on FSC social issues
Practical experience in social
aspects of forest management
certification, including Indigenous
Peoples and local communities,
at the company’s level.
[email protected]
m
- Individual member of FSC
Russia
2
List of experts involved in the risk assessment and their contact details
Technical experts were involved in writing the first draft of the NRA and providing initial feedback on critical issues.
Table 2. Experts involved in NRA development
Categories 1, 4 and 5
Experts involved in NRA drafting
Kuritsyn Anatoliy
Director, LesExpert LLC
[email protected]
+7 916 150 0532 / +7 499 717
5525
Kuritsyn Aleksey
Deputy Director, LesExpert LLC
[email protected]
+7 909 999 9970
Skype: kuritsin
Experts consulted
Lapokha Yuriy
Entrepreneur, expert on timber
[email protected], [email protected]
+7 914 070 7765 /
+7 951 015 0810
Lukashevich Sergey
Head of the Legal Department,
focal point for FSC certification,
AVA Company LLC
[email protected]
+7 3812 394 949 (
. 119) /
+7 913 150 43 10
Kreyndlin Mikhail
Head of Greenpeace Russia,
programme on specially protected
natural areas
[email protected]
Murashko Olga
Expert, Centre for Support of
Indigenous Peoples of the North,
Anthropology Museum
[email protected]
Gerasimov Vasiliy
Forest management consultant
[email protected]
+7 909 120 2752
Skype: vas.gerasimov
Sungurov Rudolf
Head of the forest management
laboratory, Northern Research
Institute for Forest Management
[email protected]
+7 8182 61 7948
Sulyandziga Rodion
Member of the FSC Permanent
Indigenous Peoples Committee,
Representative of the udeghe
minority Indigenous Peoples
[email protected]
+7 985 751 3636
Zhuravlev Denis
President of the Timber and
RelКteН InНustries Workers’ Union
of Russia
[email protected]
+7 499 124 48 01
Popova Elena
Forest ecology consultant
[email protected]
+7 904 208 7597
Skype: e.a.popova
Sungurov Rudolf
Head of the forest management
laboratory, Northern Research
Institute for Forest Management
[email protected]
+7 8182 61 7948
Head of Greenpeace Russia
forest programme
[email protected]
Category 2
Experts involved in NRA drafting
Expert consulted
Category 3
Experts involved in NRA drafting
Expert consulted
Yaroshenko Aleksey
3
National Risk Assessment maintenance
FSC Russia will ensure that information in NRA remains relevant and up-to-date. FSC Russia will be responsible to
initiКte NRA’s revision КnН upНКte if neeНeН.
1
Questionable issues and decision on revision is taken by its NRA-WG with a final approval by the Coordination
Council of FSC Russia.
4
Complaints and disputes regarding the approved National Risk Assessment
Any person or organization can fill in a complaint regarding the approved NRA.
1. Complaints regarding the approved NRA shall be prepared in written form and submitted to the FSC Russia
by e-mКil or post. A МomplКint shКll inМluНe the informer’s nКme, МontКМt НetКils, the МomplКint НesМription КnН
the proposed actions to be taken.
2. FSC Russia shall confirm the receipt of the complaint in written form within two (2) weeks from its receipt.
3. The NRA-WG shall examine the complaint within 30 calendar days. The duration for complaint examination
can be prolonged up to 60 calendar days, when additional information shall be requested or collected.
4. The decision on the complaint is taken by the NRA-WG on consensus basis between representatives of the
three chambers: environmental, social and economic.
5. The complaint informer will receive the final decision of the NRA-WG within 31 days from the time when the
complaint receipt was confirmed. If the NRA-WG requested additional time for complaint examination, it shall
inform the complaint informer about it within the first 30 days and provide its final decision within 61 days from
the time when the complaint receipt was confirmed.
6. If the complaint informer is not satisfied with the decision of the NRA-WG, he/she can submit the complaint to
the Coordination Council of FSC Russia. The Coordination Council shall confirm the receipt of the complaint
within two (2) weeks and shall provide the informer with the official answer in written form within 30 days from
the date of the confirmation.
7. If the МomplКint informer is not sКtisfieН аith the CoorНinКtion CounМil’s НeМision he/she МКn use the
provisions and follow the process described in FSC-PRO-01-008 V2-0 Processing Complaints in the FSC
Certification Scheme.
8. All complaints regarding the approved NRA are registered in the NRA Complaint Register of FSC Russia.
Information in the Register inМluНes МomplКint informer’s nКme, НКte of МomplКint reМeipt КnН Мlosure,
complaint description, description of complaint examination and final actions taken by the NRA-WG or the
Coordination Council in case of appeals.
5
List of key stakeholders for consultation
The list shows key stakeholders who were approached during public consultations and provided their comments
(Note: below is the list of key stakeholders to be contacted within the first public consultations).
Environmental interests
WWF Russia, Greenpeace Russia, Russian Bird
Conservation Union, mailing list of all stakeholders
registered in FSC Russia, mailing list of all
environmental chamber members of Association
NRG
Social interests
Unions/organizations of indigenous peoples (komi,
etc.), Russian forestry labour union, FSC consultants
on social issues2, mailing list of all stakeholders
registered in FSC Russia, mailing list of all social
chamber members of Association NRG
Economic interests
IKEA TORG, ILIM Group, Mondi SLPK, Stora Enso
Forest West, International Paper, Russian Forest
Group, FSC consultants mailing list of FSC certificate
holders in Russia, mailing list of all economic
chamber members of Association NRG
General
Federal Forestry Agency, FSC-accredited certification
bodies working in Russia
1
Within FSC Russia NRA-WG is represented by Technical Committee, which carries out all the duties for national
standard development, national interpretations and other technical issues related to standard setting.
2
The list of registered with FSC Russia consultants is available on https://ru.fsc.org/ru-ru/cert/consult
6
Risk assessment
Area under assessment: Russian Federation
National risk assessment (NRA) is made for the whole territory of the Russian Federation. It is based on information
from open sources, such as scientific and NGO reports, media publications, analysis of regulatory framework and
consultations with experts.
For each indicator the risk designation is based on gathered information and its correlation to thresholds, violation or
conformation of conditions, which justify the level of risk. If the gathered information complies with low risk threshold,
КnН there is no other informКtion thКt, аhen КssemЛling Кll eviНenМe, leКНs to К ‘speМifieН risk’ НesignКtion,
low risk is designated. If gathered information shows any possibility for threshold violation, then designation of
specified risk is justified.
Control measures are developed for indicators with specified risk. Implementation of control measures shall ensure
mitigation of risk of using unacceptable wood by certified organizations. If implementation of control measures does
not help to lower the risk, wood cannot be purchased as controlled wood and used within the FSC system.
Some control measures are mandatory for implementation, some are recommended. Implementation of control
measures will be evaluated by FSC accredited certification bodies during audits.
How to read the risk assessment table?
The table for CW Categories 1, 2, 4 and 5:
Indicator
Source of
information
Indication of
risk, evidence
used
1
2
3
Functional scale
Risk designation
and specification (if not ‘low risk’)
Provide numbers of thresholds that
are met and justify the outcome for
each threshold
Control Measures
M – mandatory
R – recommended
4
5
6
Description of columns:
1. Number and name of the indicator.
2. Reference numbers of information sources are listed in the column. At the end of the NRA, the information sources
are grouped in 3 Annexes: information sources for CW Categories 1, 4 and 5 are listed in Annex 1.1; information
sources for CW Category 2 are listed in Annex 1.2; and information sources for CW Category 3 are listed in Annex
1.3. The column will be useful for the readers who would like to understand what information justifies the
designated level of risk.
3. The column provides evidence for the designated level of risk.
4. The column shows the non-geographical characteristics that were used for dividing the territory into areas of low
and specified risk. The column is important for all NRA users because the risk assessment for a potential supplier
will depend on the information in this column.
If Not applicable is written in the column, it means that the geographical division was used. Usually this refers to
specified risk for the entire Russian territory. For some indicators, it refers to specified risk for some of the
constituent entities of the Russian Federation (knoаn Кs “feНerКl suЛjeМts of the RussiКn FeНerКtion”).
5. The column lists thresholds with which obtained information was compared. The thresholds are identified in the
FSC procedure FSC-PRO-60-002a. This column is interesting for the readers who would like to better understand
the technic applied for the risk assessment.
6. This column is of crucial importance for NRA users because it includes mandatory or recommended actions that
shall or may be taken by the organization for risk mitigation. In case of low risk, control measures are not needed.
Table for CW Category 3:
HCV
category
and
indicator
Data used for HCV
identification
1
2
Identified
threats
Indication of
risk, evidence
used
3
4
Functional
scale
Risk designation
and specification (if not ‘low risk’)
Provide numbers of thresholds
that are met and justify the
outcome for each threshold
Control Measures
M – mandatory
R – recommended
5
6
7
The table for CW CКtegorв 3 Нiffers from the tКЛle for CКtegories 1, 2, 4 КnН 5 onlв in Мolumn № 3 аhiМh speМifies
threats to high conservation values (HCVs). This information is interesting for the readers who would like to know how
forest management activities threaten each HCV type.
6.1
Controlled Wood Category 1: Illegally harvested wood
3
The volume of harvested wood FSC 100% in 2014 in Russia is estimated to be about 40 mln m as for the beginning
of 2015. The volume of controlled wood which comes from uncertified suppliers and is largely used by medium and
large FSC certified wood processing companies is about 80 mln m3. The overall volume of harvested wood in Russia
3
3
is about 200 mln m . These numbers show the importance of FSC controlled wood for FSC in Russia .
Traditions of centralized forest management, which were set during the state-planned economy (i.e. until the 1990s),
still prevail in Russia:
Property rights belong to the state or municipalities*;
All contracts for wood harvesting are done between state or municipal authorities responsible for forest
management and private forest managers;
The state controls the orgКniгКtions’ МompliКnМe with forest legislation and other regulations.
From 2007 to 2013 there was no system for state recording of volumes of harvested and processed wood. It lead to
increase of illegally harvested wood. As a result foreign woodworking companies requested their Russian partners to
confirm wood legality through FSC certification scheme.
In 2014 К neа feНerКl lКа №415-FZ dated 27.12.2013 came into force which regulates recording of harvested and
processed wood volumes. The law states that property rights for transported wood have to be confirmed by a specific
accompanying document and documents confirming roundwood harvesting and business transaction.
4
In order to comply with Regulation (EU) No 995/2010 Russia has adopted a series of normative documents in 20132015. The documents were targeted at combating illegal wood harvesting. As a result from 1 January 2014 a federal
law № 415-FZ of 28 DeМemЛer “On КmenНing RussiКn Forest CoНe and Russian Code of Administrative Offences”
entered into force (Annex 2.1 (18)). The law introduced changes in fighting against sale of illegally harvested wood
(chapters of the Russian Forest Code 2.1 “WooН accounting КnН lКЛelling”, 2.2 “WooН trКnsportКtion” КnН 2.3 “Unified
State Automated Information System for Accounting of Wood and Deals with It” (EGAIS)) and a new article 8.28.1
“ViolКtion of forest legislКtion on КММounting of Unified State Automated Information System for Accounting of Wood
and Deals with It аooН КnН НeКls аith it” to the RussiКn CoНe of AНministrКtive OffenМes.
A relatively large number of new governmental decrees were adopted in order to support changes in federal laws: №
55 of 28 JКnuКrв 2015 “On Approving Кn OperКting ProМeНure for the Unified State Automated Information System
for Accounting of Wood and Deals with It”; № 11 of 6 January 2015 “On Approving Rules for Submission of
Declaration on Deals with Wood”; № 1525 of 26 DeМemЛer 2014 “On Approving Rules for AММounting of WooН”, №
571 of 21 June 2014 “On AММompКnвing DoМument for WooН TrКnsportКtion”; № 1301 of 3 DeМemЛer 2014 “On
Approving Rules for Information Submission to the Unified State Automated Information System for Accounting
of Wood and Deals with It”; № 1161 of 4 November 2014 “On Approving a Provision on labeling wood of valuable
forest species (oak, beech, ash) (Annex 2.1 (27, 61, 54-56, 58).
The issue of criminal and legal protection of forests from illegal wood harvesting is covered in article 260 of the
Russian Criminal Code (Annex 2.1 (17)). Logging of trees, bushes and lianas in forest areas or areas that are not
seen as forest areas, as stated in the article 260 of the Russian Criminal Code, shall be interpreted as their sawing off,
logging or cutting off by different means of tree trunks, stems of bushes and lianas from their roots.
Illegal logging in the mentioned above areas is logging with violation of legislative requirements for example logging
without necessary documents (including lease agreements, decisions on assigning a forest unit, forest development
project, which was approved by state or municipal expertise, forest stands sale agreements, state or municipal
contract for carrying our work on forest safeguarding, protection and regeneration), in quantity exceeding the
approved volume, logging other than approved species or age composition, our outside of the approved cutting area
(Annex 2.1 (9)).
Federal law of 21 July 2014 № 277-FZ “On amending normative framework of the Russian Federation” (Anneб 2.1
(39)) introduced changes to the Russian Criminal Code, article 191.1, which states criminal responsibility for
purchasing, keeping, transportation, processing for the purpose of sale, and sale of knowingly illegally harvested
wood.
Expert estimates made by the Center for Standardization and Certification of RounН TimЛer КnН LumЛer “LesEбpert”
Regulation (EU) No 995/2010 of the European Parliament and of the Council of 20 October 2010 laying down the obligations of
operators who place timber and timber products on the market Text with EEA relevance
3
4
10
Risk designation
Control
and specification (if not ‘low risk’)
Measures
Provide numbers of thresholds5 that are met and
M – mandatory
justify the outcome for each threshold
R - recommended
In the majority of cases wood is harvested on forestlands, defense and security lands and in the smaller volumes in protected nature areas. Logging and dealing with such wood is fully described in Russian
legislation. Executive authorities of the subjects of the Russian Federation manage forest units located on these lands.
It can be stated that also there are forests on agricultural lands, some of which are meant for protection from negative nature, anthropogenic or technogenic disasters. In addition to it there are overgrown
agricultural lands. This has happened due to their longstanding nonexploitation. Experts estimate these lands to be from 50 to 100 mln ha. These lands are not subject to conversion to forestlands and are
regulКteН Лв the lКа “On КgriМulturКl lКnН trКnsКМtions” (Anneб 1.1 (10), Anneб 2.1 (5)). For these lКnНs there Кre no forest planning and management. The process of harvesting and procedures of selling and
purchase of wood from these territories are not yet reflected in the state legislation.
Therefore wood harvested on overgrown agricultural lands temporarily is not considered as FSC controlled wood and is not assessed in the current document. In case of changes in relevant legislation the
decision about assessing wood harvested on overgrown agricultural lands as controlled wood will be reconsidered and relevant changes to NRA will be made.
Indicator
Source of
information
(Annex 1.1)
1.1 Land
tenure and
management
rights
Annex 1.1 (1, 2, 7,
8, 9, 30, 31);
Annex 2.1 (1, 2, 5,
6)
Indication of risk, evidence used
Low risk
State forestlands account for 96,8% of all forestlands in
Russia. It is either state or municipal owned. Relevant
tenure and management rights are regulated by the
Forest and Land Codes and other normative framework
developed in accordance with them (Annex 2.1 (1, 7)).
Defense and security lands are in possession of the
Ministry of Defense. State management of forestry
related issues is handled by the federal state
autonomous enterprise “Department of Forest
Management” of the Ministrв of Defense through 39
forest districts (lesnichestvo) listed in its Chapter (Annex
2.1 (5)). Square surface of forests located on these
territories is 0,4% of all Russian forestlands.
Functional scale
Not applicable
(low risk for entire country)
Low risk
Not required
Loа risk thresholН (thresholН № 1
Identified laws are upheld. Cases
where law/regulations are violated
are efficiently followed up via
preventive actions taken by the
authorities and/or by the relevant
entities from FSC-PRO-60-002a) is
met
Land tenure and management rights
belong to the state. There are no
evidences of other holders of
forestland tenure rights.
There are no evidences of other holders of forestland
tenure rights.
Taking into account that wood harvesting companies are
not the owners of forestlands, but the users holding
concession licenses (see indicator 1.2) the risk is
assessed as low.
1.2
Concession
licenses
Annex 1.1 (1, 2, 3,
4, 6, 10, 11,12,13,
30,31), Annex 2.1
(1, 8 ,9,10)
Specified risk
Not applicable
Specified risk
Lease agreements and agreements for gratuitous use
are evaluated in this indicator.
(specified risk for entire country)
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
FSC-PRO-60-002a) is met
All forests in Russia are state-owned and there are no
private forests. Forests can be licensed as concessions
to enterprises for a period from 1 to 49 years, based on
the results of auctions conducted by the authorities.
The following risks are identified:
The risk of violation of legislation,
unfair competition and corruption of
state authorities during bidding for
All rights are regulated by Russian legislation.
Forests can also be licensed as concessions based on
decisions of the Government of the Russian Federation
11
M – verification of availability of
either concession license
concluded according to legislation
or agreement for gratuitous use,
as well as verification of presence
of such a concession agreement in
EGAIS.
R – monitoring of mass media,
court orders and publications in
order to exclude cases of violation
of legislation by a supplier, facts of
corruptions by authorities during
bidding for forest units and/or
issuing concession licenses.
without any auctions. Concessions are concluded with a
purpose to implement "priority investment project in the
sphere of forest exploitation" by a concession holder.
The government oversees competitive bidding among
such projects.
forest units and issuing concession
licenses.
Unfair competition exists in concluding a concession
agreement, as well as corruption. According to a worldknown ranking on Corruption Perception Index Russia is
on the 131 place out of 176.
1.3
Management
and
harvesting
planning
Annex 1.1 (7, 2224, 91)
Annex 2.1 (1, 1113, 66)
Low risk
Not applicable
Management and harvesting planning in Russia is done
according to the following normative documents: Forest
Plan (on the level of a subject of the Russian
Federation), forestry regulations (on the level of forest
districts), and Forest Development Project (on the level
of a forest unit in lease). Control over forest
management is established and carried out in such a
way that if the mentioned above documents are not in
place or are not approved through a valid procedure, it is
almost impossible to receive subsequent documents
authorizing concrete forest management activities.
(low risk for entire country)
Low risk
Loа risk thresholН (thresholН № 1
Identified laws are upheld. Cases
where law/regulations are violated
are efficiently followed up via
preventive actions taken by the
authorities and/or by the relevant
entities from FSC-PRO-60-002a) is
met
Forest Plans for subjects of the
Russian Federation and forestry
regulations for forest districts are
approved on the governmental level
according to the legislation of the
Russian Federation. Forest
Development Project for the forest
unit in lease also must be developed
according to the national legislation.
No cases of any long-term and/or
large-scale management activities
carried out in the absence of
legitimately approved documents for
forest management are known to
experts of the NRA-WG.
Known cases when documents for management
planning and issued according to them harvesting
permits were canceled, only prove that control over
existing and valid procedure for obtaining the documents
is effective.
There are no known cases of any long-term and/or
large-scale management activities carried out in the
absence of legitimately approved documents for forest
management.
Therefore the risk can be assessed as low.
12
Not required
1.4
Harvesting
permits
Annex 1.1 (5, 2224, 26, 27, 34, 35,
36, 37, 60-63, 95,
96), Annex 2.1 (1,
9, 14-17, 20)
Specified risk
The problem of illegally harvested wood shows the
necessity to verify the existence of harvesting enabling
documents.
Not applicable
Specified risk
(specified risk for entire country)
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
FSC-PRO-60-002a) is met
Documents entitling wood harvesting in Russia are:
Forest declarations,
Forest stands sale agreements.
The problem of illegal harvesting ( in the absence of
such enabling documents) is recognized by
governmental forestry authorities. Publicly available
evidences exist.
There are cases of harvesting without such documents
(Annex 1.1 (14, 61, 22-24,26, 35-37, 95,96)).
There are case of issuing such documents without
following legal requirements (Annex 1.1 (14, 27, 36, 60,
62, 63)).
1.5 Payment
of royalties
and
harvesting
fees
Annex 1.1 (16,
17), Annex 2.1 (8,
10, 14-18, 67, 68)
Specified risk
Information about debtors among lease agreements
holders from various subjects of the Russian Federation
is available on the official website of the Federal Forestry
Agency and in other information sources (Annex 1.1 (16,
17)).
Risks related to wood harvesting
enabling documents are identified:
Harvesting without these
documents (illegal
harvesting)
Issuing the documents
without following legal
requirements.
Not applicable
Specified risk
(specified risk for entire country)
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
FSC-PRO-60-002a) is met
If harvesting is enabled by forest stands sale
agreements (Annex 2.1 (67, 68)) there is no possibility of
any leases debts, because the agreements are
concluded on the prepayment basis.
Risk of dealing with wood harvested
with violation of Russian legislation
on lease payments is identified.
M – verification of availability of
forest declaration issued on the
basis of concession license or
agreement for gratuitous use
or
M – verification of availability of
forest stands sale agreement
concluded according to legal
requirements
R - monitoring of mass media,
court orders and publications in
order to exclude cases of violation
of legislation by a supplier, facts of
corruptions by authorities during
issuing harvesting enabling
documents.
M – upon concluding a contract
and later on periodically but not
less than once per year verify that
forest manager does not have any
debts for lease agreements, for
verification use websites of:
Federal Forestry Agency
http://www.rosleshoz.go
v.ru/activity/finance/stat
Regional forestry
executive authorities
Other information
sources.
In case of information about debts
is available:
M – request from forest manager
documents confirming that there is
no debt (payment document
confirming that lease payment has
been done in due time as stated in
the lease agreement; documents
confirming amicable settlements,
postponed payments, payment by
installments for lease debts).
13
1.6 Value
added taxes
and other
sales taxes
Annex 1.1
(19,20,22), Annex
2.1 (21)
Specified risk
Information from the Data Bank of the Execution
Proceedings shows that there are debtors violating
requirements of the Russian Tax Code (please also refer
to indicator 1.7).
Not applicable
(specified risk for entire country)
Specified risk
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
FSC-PRO-60-002a) is met
Risk of dealing with wood harvested
in violation of the Russian Tax Code
is identified.
1.7 Income
and profit
taxes
Annex 1.1 (19, 20,
25), Annex 2.1
(21)
Specified risk
Information from the Data Bank of the Execution
Proceedings shows that there are debtors violating
requirements of the Russian Tax Code (please also refer
to indicator 1.6).
Not applicable
(specified risk for entire country)
Specified risk
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
FSC-PRO-60-002a) is met
Risk of dealing with wood harvested
in violation of the Russian Tax Code
is identified.
1.8 Timber
harvesting
regulations
Annex 1.1 (14,15,
24, 36-45)
Annex 2.1 (1, 4,
17-20, 22-31)
R - upon concluding a contract
and later on periodically but not
less than once per year verify that
forest manager does not have any
debts regarding tax payments to
the budget on the website of the
Federal Tax Service (Annex 1.1
(20)
And / or on the website of the
Federal Bailiff Service (Annex 1.1
(19)
R - upon concluding a contract
and later on periodically but not
less than once per year verify that
forest manager does not have any
debts regarding tax payments to
the budget on the website of the
Federal Tax Service (Annex 1.1
(20)
And / or on the website of the
Federal Bailiff Service (Annex 1.1
(19)
Specified risk
Not applicable
Specified risk
Failure to comply with requirements of timber harvesting
rules, forest care and sanitary rules related to timber
harvesting, as well as failure to perform works
considered by the contract, violation of harvesting
deadlines or their implementation by improper
procedures and methods are common for harvesting
activities.
(specified risk for entire country)
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
FSC-PRO-60-002a) is met.
M - On-site inspection of
harvesting sites in forest units,
verification of compliance with
requirements of timber harvesting
rules, forest care and sanitary
rules related to timber harvesting
the requirements of harvesting
rules, rules of forest care and
sanitary rules in the part related to
logging.
Risk of non-compliance with
requirements of timber harvesting
rules, forest care and sanitary rules
related to timber harvesting, as well
as with harvesting enabling
documents, in particular:
• risk of Мutting in plКМes not
specified in harvesting enabling
documents,
• risk of Мutting Нuring К perioН
M – during visits to harvesting
sites carry out:
• verifiМКtion of МompliКnМe аith
technology and requirements
specified in technological maps;
• seleМtive verification of
harvesting site acceptance reports
and work acceptance reports for
performed for thinnings, sanitary
cuttings.
Violations are recorded by bodies authorized for
safeguarding and protection of the forest fund (Annex
2.1 (17, 18)). Supervision over the implementation of
legislation is carried out by executive authorities of the
subjects of the Russian Federation.
Reports of NGOs and regional prosecutors show
evidence of non-compliance with requirements for
harvesting activities.
Annex 1.1 (24, 35, 45).
14
not specified in harvesting
enabling documents (before or
after).
There are facts of tree cutting before or after the expiry
date of harvesting enabling documents (Annex 1.1 (14,
15)).
R - consultations with
representatives of forest districts
(lesnichestvo) for identification if
wood supplier has performed any
cutting beyond his official
harvesting area.
Schedule, frequency, sampling
criteria are to be set by the
organization.
M - Verification of compliance with
harvesting deadlines specified in
forest declaration or in a wood
purchase/sale agreement.
M – Information requests from
forest districts (lesnichestvo) about
detected violations for:
a) presence of documented
violations of the above-mentioned
normative framework by the
supplier, their frequency and
severity of the damage caused;
B) presence of violations of the
above-mentioned normative
framework, which have not been
corrected in the due time (fines
have not been paid, damages
have not been paid,
consequences of violations have
not been rectified).
R - monitoring of mass media,
court orders and publications in
order to exclude cases of violation
of above-mentioned harvesting
related normative framework by a
supplier.
15
1.9 Protected
sites and
species
Annex 1.1 (33, 4659, 61, 62-68)
Annex 2.1 (1, 3, 4,
17, 18, 29-36, 45)
Specified risk
Not applicable
Specified risk
There are forest areas with different forest use
restrictions in the Russian Federation: protected nature
areas (PNA), protection forests and forests located on
forested areas with a special protection regime (Annex
2.1 (1).
There are evidence of violations of established in PNA
regimes, violations of legislation during harvesting in
protection forests and forests located on forested areas
with a special protection regime. There are examples of
commercial harvesting in protection forests under the
guise of sanitary felling.
(specified risk for entire country)
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
FSC-PRO-60-002a) is met
The risk of violation of established
forest management regimes in
protected nature areas, protection
forests and forests located on
forested areas with a special
protection regime as well as risk of
harvesting timber of species cutting
of which is prohibited is identified.
There are evidence of violations of the normative
framework specified in Annex 2.1.
Risk of reduction of forest protection
functions due to excessive
harvesting under the guise of
sanitary felling in protected nature
areas, protection forests and forests
located on forested areas with a
special protection regime is
identified.
M - Verification of forest
declarations and purchase/sale
agreements to be in compliance
with established regime of forest
management in protected nature
areas (PNA), protection forests
and forests located on forested
areas with a special protection
regime.
M – verification of absence of
species prohibited for harvesting,
in supplies of an organization.
M - verification of species
prohibited for harvesting, in acts of
inspection of logging sites and
reports on the use of forests (1) during on-site inspections.
M - in the presence of a permit for
sanitary cuts, on-site verification of
the relevance of such sanitary
and health measures.
Schedule, frequency, sampling
criteria are to be set by the
organization.
R - monitoring of mass media,
court orders and publications in
order to exclude cases of violation
of established regimes of forest
management in protected nature
areas (PNA), protection forests
and forests located on forested
areas with a special protection
regime and harvesting of species
prohibited for harvesting by a
supplier.
1.10
Environment
al
requirements
Annex 1.1 (24, 32,
33, 36, 45, 65-69)
Annex 2.1 (3, 4,
16, 31, 37-38)
Specified risk
Not applicable
Specified risk
Russian Forest Code states that forests have to be
protected from fires, pollution and other negative impact.
(specified risk for entire country)
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
However cases of forest contamination (abandonment of
household and industrial waste in the forest, soil, water
and vegetation contamination with fuel spills) are
16
О - On-site inspection of forest
sites in harvesting areas,
verification of compliance with
environmental legislation during
wood harvesting activities.
Schedule, frequency, sampling
criteria are to be set by the
organization.
recordered. Negative impacts resulted from forest
harvesting activities are identified in a form of erosion
and soil compaction, drainage disorders in rivers and
streams, flooding, marsh formation of after-cut territories
and neighboring areas, and etc. (Annex 1.1 (24, 32, 33,
45, 48, 65, -69)
Other environmental requirements are covered in
indicators 1.8, 1.9.
1.11 Health
and safety
1.12 Legal
employment
FSC-PRO-60-002a) is met
Risk of dealing with wood harvested
with repeated and/or damaging
nature violations of Russian
environmental legislation
(abandonment of household and
industrial waste in the forest, soil,
water and vegetation contamination
with fuel spills and other negative
impacts) is identified.
Annex 1.1 (70-73)
Specified risk
Not applicable
Specified risk
Annex 2.1 (17-18,
39-41)
General provisions on health and safety of workers are
included in the Russian Labor Code. The organization is
obliged to establish safe environment for work, while
workers have to follow health and safety rules. However
violation of health and safety requirements in forestry
sector is noted in many regions of Russia.
(specified risk for entire country)
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
FSC-PRO-60-002a) is met
Annex 1.1 (74-78)
During logging activities, the following violations of
health and safety rules occur:
- partial provision of workers with personal protective
equipment (PPE);
- unsettled working and rest hours;
- unsatisfactory sanitary and household security of
employees;
- violation of technological process;
- non-compliance of workers with rules and regulations
on health and safety.
Specified risk
Annex 2.1 (17, 18,
39-41)
Cases of Russian Labor Code violation are identified in
Russia.
Risk of dealing with wood harvested
with violation of health and safety
requirements is identified.
Not applicable
Specified risk
(specified risk for entire country)
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
FSC-PRO-60-002a) is met
The following violations by the employer are noted:
- violations related to conclusion of employment
contracts;
- violation related to payment of wages and other
amounts due, (including payments for vacation leaves,
payment upon resignation);
- violation of a procedure of employee resignation;
as well as violations in the field of discrimination at the
workplace, use of child labor and convict labor (see
indicator 2.2).
Risk of dealingwith wood harvested
with violation of labor legislation
related to to conclusion of
employment contracts and staying in
compliance with it, including violation
related to payment of wages and
other amounts due.
17
R - monitoring of mass media,
court orders and publications in
order to exclude cases of violation
of environmental legislation by a
supplier.
M - On-site inspection to assess
compliance with health and safety
requirements, including
maintenance of proper working
and rest hours, availability and
condition of PPE, compliance with
safety regulations, compliance
with techniques and requirements
for development of logging sites
specified in a technological map
and related to safe performance of
work.
Schedule, frequency, sampling
criteria are to be set by the
organization.
M – Verification of existence and
compliance with requirements of
employment contracts concluded
between employees and
employers in accordance with
Russian Labor Code
M - Interviews with employees of
an organization during on-site
inspections
Schedule, frequency, sampling
criteria are to be set by the
organization.
1.13
Customary
rights
-
Not applicable
Analysis of the normative framework and consultations
with experts from the Centre for Support of Indigenous
Peoples of the North and Greenpeace Russia (please
see Table 2, page 5) revealed that in the Russian
legislation there are no legislative acts that clarify or
regulate customary rights as they are described by FSC
(КММorНing to МustomКrв right’s НesМription in FSC-STD60-004 V1-0 International Generic Indicators and
explanation of indicator 1.13 in FSC-PRO-60-002a).
Therefore applicable legislation is not identified.
Not applicable
Not applicable
Not required
1.14 Free,
Prior and
Informed
Consent
-
Not applicable
Analysis of the normative framework and consultations
with experts from the Centre for Support of Indigenous
Peoples of the North, Greenpeace Russia (please see
Table 2, page 5) revealed that there is no applicable
legislation in Russia.
Not applicable
Not applicable
Not required
Specified risk
Not applicable
Specified risk
This indicator examines the rights of indigenous peoples,
as stipulated by the current legislation on indigenous
peoples of the North, and related to forest management.
(geographical scale on a level of
the subjects of the Russian
Federation, please see Annex
3.1)
Specified risk threshold (threshold
№2
Identified laws are not upheld
consistently by all entities and/or are
often ignored, and/or are not
enforced by relevant authorities from
FSC-PRO-60-002a) is met
M – confirmation of supporting
indigenous peoples rights through
interview with representatives of
indigenous peoples.
1.15
Indigenous
peoples’
rights5
Annex 1.1 (62, 81,
82)
Annex 2.1 (1-4,
17-18, 41-50, 58)
The status and rights of indigenous and small-numbered
peoples are spelled out in the federal law "On
Guarantees of Indigenous Peoples Rights in the Russian
Federation" and a number of other laws and by-laws
from Annex 2.1.
R - monitoring of mass media,
court orders and publications in
order to exclude cases of violation
of indigenous peoples rights by a
supplier.
The i