Timber Risk Score: 73 / 100 in 2017. The Timber Legality Risk Assessment for China contains an evaluation of the risk of illegality in China for five categories and 21 sub-categories of law. We found:
- Specified risk for 5 sub-categories.
- Low risk for 13 sub-categories.
- No legal requirements for 3 sub-categories.
Please note: The Timber legality Risk Asssessment relate to Mainland China only.
This page provides an overview of the legality risks related to timber produced in China.
Forests cover about 21% of the country, of which:
- 3% is bamboo forest
- 64% is natural forest (whether bamboo or not)
- 36% is plantations.
Forest ownership refers to the ownership or use rights to forest, timber and forest land. There are three types of ownership:
- State-owned forest, timber and forest land
- Collectively owned forest, timber and forest land
- Individually owned timber and use rights to forest land.
There are five key trends within Chinese forests:
- Gross forest resources in China are growing
- Forest quality is steadily improving
- Natural forests are steadily growing in total area
- Total plantation area has increased rapidly in recent decades
- More timber is being produced from plantations.
China is the world's largest importer of timber, as domestic supply of industrial wood has failed to keep up with China's industrial manufacturing capacity. China faces increasing pressure to address its influence on illegal logging around the world, due to its growing demand and export of wood and wood products.
Several legality risks are present in China's timber supply chains. If you are sourcing timber from China you should take care to ensure the risks identified are not present in your supply chains, or have been sufficiently mitigated.
Score: 41 / 100 in 2019
Rank: 80 out of 180 countries in 2019
A moratorium on commercial harvesting from state owned natural forests was put in place in 2016 and extended to all natural forests from the beginning of 2017. By the end of 2017, no logging in natural forests will be allowed. Forest maintenance is allowed and timber from this can be sold legally.
"Tensions between China and Japan over the contested Senkaku/Diaoyu islands increase as both countries increase their military capabilities, particularly their radar and missle systems, in the region. However, China and Japan announced a new crisis communication hotline to avoid accidental clashes at air and sea in June 2018, and Japan's Ministry of Defense reported that the number of times Japan's military had to scramble jets in response to Chinese air incursions went down 41 percent in 2017" according to Global Conflict Tracker (2019).
The Uppsala Conflict Data Program records that there were 11 deaths from 2010-2019.
CITES appendix II: Dalbergia spp., Taxus spp., Rauvolfia serpentina, Aquilaria spp
- Find out the different sources of legal timber
- Determine which source type your timber comes from
- Find out the main documents that can be used to indicate legality throughout the supply chain
|Timber source types||Description of source type|
Timber from commercial plantations. These can be collectively, individually or corporately owned commercial plantations, and are mostly state managed. A harvesting permit and logging permit application is required. This is the primary source of timber in China.
Timber from forests planted for other purpose, such as fruit trees, are known as economic forests. When the forest has no yield, it may be cut as materials for forest products. A harvesting permit, logging permit application and forest tenure certificate are required.
State owned natural forests are not a source of timber, except for:
Protected forests (Class III) are a limited source of timber. They are state or collectively owned, and include natural and planted forests. A Harvesting Permit, logging permit application, forest management plan, logging plan, regeneration certification for previous year, forest tenure certificate and the approval of local, provincial and state governments are required.
Timber from trees/bamboo planted around farm houses and households.
Bamboo forest refers to advantageous bamboo species, generally including timber bamboo forest, shoot bamboo forest and timber-shoot bamboo forest. Harvesting permit （in some provinces) and logging permit application (in some provinces) are required.
These are the main documents used to indicate legality.
Trade and transport
Export and custom
Import to China
Export from China
Risk assessment summary
Legal rights to harvest
|Taxes and fees
Timber harvesting activities
|Trade and transport
Specified risk species
|Common/trade name||Scientific name||Risk information|
Natural forest species. Risk of mixing with Mongolian oak from Russia (EIA 2013, WWF 2013)
Natural forest species. Risk of mixing with Korean pine from Russia (WWF 2013)
Mitigate the risks in your supply chain
Learn which actions we recommended to mitigate the risks associated with the timber sources from China.
Source Certified Materials
NEPCon believes that third party certification (for example FSC and PEFC certification) can provide strong assurances of the legality of the products they cover. Companies seeking to mitigate the risks of sourcing illegal timber should seek to purchase third party certified materials wherever possible.
While the European Timber Regulation does not include an automatic “green lane” for certified products, it does recognise the value of certification as a tool for risk assessment and mitigation. The European Commission says that companies “may rate credibly certified products as having negligible risk of being illegal, i.e. suitable for placing on the market with no further risk mitigation measures, provided that the rest of the information gathered and the replies to the risk assessment questions do not contradict such a conclusion.”
For more information on using certified materials in your due diligence, including how to assess whether a certification system meets EUTR requirements, see the page on Certification and Due Diligence.
Mitigation recommendations for non-certified materials
Where certified materials are not available, we have two tools to help you mitigate risks for Chinese timber supply chains:
- the Risk Mitigation Guide gives you a detailed overview of risks in China, and how to mitigate them.
- the Document Guide provides you with a list of all required documents and examples of key documents and how to use them in mitigating risks. OIt is also available in Español, Français and Chinese, Simplified
The tools above give you the most information. Below is a summary of our six recommended actions to mitigate the risks associated with timber sources from China that are not third party certified.
1. Fully map your supply chain
- Our supply chain mapping tool can help you do this.
2. Obtain and verify documents
- Forest level documents
- Business Registration Certificate and Tax Registration Certificate
- Forest Tenure Certificate
- Harvesting permit
- Approved forest management plan
- Tax related documents
- VAT Invoices
- Health and safety related documents
- Accident records and related administrative procedures and measures
- Evidence of accident insurance to cover all workers
- Health and safety procedures documents
- Training records for safe operation
- Employment related documents
- Work permits for special occupations, e.g. chainsaw operator
- Copy of social security card for each worker
- Employment contracts
- Salary payment records
- List of (permanent and temporary) workers
- Trade and transport documents
- Customs Declaration Registration Approval Certificate and Phytosanitary certificate (where applicable)
- Delivery notes
- Physical documentation on species input
- Sales contracts
- Transportation permits
3. Consult with stakeholders
- Neighbours, local communities, landowners and other stakeholder confirm that there are no conflicts on the land.
- County forestry authorities.
- Applicable issuing authority.
- Relevant staff/ workers confirm that they are aware of health and safety procedures and have participated in training.
- Relevant staff/ workers confirm that there are no issues with lack of labour contracts, or other contractual violations.
- Social security authorities confirm that payment of social security is up to date.
4. Carry out on-site verification
- Confirm that health and safety equipment is used during harvesting.
- Confirm that on-site staff are covered by labour contracts.
- Confirm that information provided on invoices and documents of origin matches that of suppliers / sub-suppliers
5. Conduct targeted timber testing
- Conduct timber testing on samples of purchased material to verify the species or origin of timber, where appropriate. Read our Thematic Article on timber testing, a guide to laboratory techniques to determine species and origin of timber products, to find out more.
6. Avoid / do not buy
- Avoid products that include materials bought at spot- and/or open-markets