Critics say FSC update risks weakening accountability for forest harm

  • The world’s biggest sustainable timber certifier has updated how it applies its “corporate group” rules, which determine whether certified companies are held responsible for violations by affiliates, suppliers or subsidiaries.
  • NGOs like Forest Peoples Programme, Greenpeace and Rainforest Action Network warn the change could let forestry giants such as APP and APRIL rejoin the FSC without fully remedying past deforestation and land conflicts.
  • The NGOs took part in the review process, but say it favored corporate voices and misrepresented civil society input, raising concerns that the update prioritizes company reputations over community rights.
  • Critics say narrowing the corporate group scope risks shielding parts of conglomerates from scrutiny just as the FSC tests its remedy framework with some of the world’s largest forestry companies.

JAKARTA — The world’s largest sustainable timber label is under fire for revising how it applies its rules on corporate accountability — a move activists say could let forestry giants long tied to deforestation and land conflicts rebrand themselves as “green.”

The Forest Stewardship Council (FSC), which certifies wood and paper products worldwide, confirmed to Mongabay that it has revised its internal guidance on the scope of a company’s “corporate group.” The concept is central to the FSC’s rules because it determines how to deal with a company that’s certified if one of its uncertified subsidiaries, suppliers or affiliates is found to have committed forestry violations.

The FSC’s corporate group definition is currently based on the standard of “common control” drawn up by the Accountability Framework Initiative (AFi), a collaborative effort by 25 NGOs to build and scale up ethical supply chains for agricultural and forestry products.

“This work considers the learnings to date on identifying and concluding the scope of the corporate group and builds on the strengths of the [AFi’s] definition,” the FSC said in a statement. “This is not the same as reviewing the definition itself.”

The distinction matters because under the FSC’s Policy for Association and Remedy Framework, an entire corporate group can be held accountable for destructive practices like illegal logging, human rights abuses, or deforestation by any of its members.

Under the remedy framework, firms that have lost their FSC certification, or been “disassociated,” can only return to the FSC fold if they make up for past harms across their corporate group — not just at the single violating mill or plantation.

Two of the world’s largest pulp and paper producers — Asia Pulp & Paper (APP) and APRIL — are currently engaged in the remedy framework in a bid to rejoin the FSC. Both were previously cut off for clearing vast swaths of rainforest in Indonesia and being embroiled in social conflicts with Indigenous and local communities there.

Critics warn that any narrowing of the corporate group scope could allow these conglomerates to leave parts of their networks outside the rules, shielding affiliated entities from scrutiny.

“Given the centrality of the corporate group definition to the remedy process, this creates a real risk that companies could exploit the process to narrow accountability,” said Angus MacInnes, a project officer at the U.K.-based Forest Peoples Programme (FPP). “This would undermine remedies for communities harmed by APRIL, APP, and other major forestry conglomerates.”

Active clearance and drainage of peatland rainforest in PT Asia Tani Persada. The Sinar Mas group affiliated concession, which contains orangutan habitat, is a supplier of pulpwood to Asia Pulp and Paper (APP).

Concerns over the revision process

Civil society groups that engaged in the review say the process was skewed toward corporate interests and may pave the way for weaker accountability.

Only three NGOs — FPP, Greenpeace, and the U.S.-based Rainforest Action Network (RAN) — were consulted, alongside what FPP described as “a plethora” of private sector actors, according to MacInnes.

The imbalance has fueled concerns that industry perspectives dominated the consultation, while Indigenous communities, regulators and independent experts were left out.

“This made us very nervous, as we feared that this was an attempt to water down group-level responsibility,” MacInnes said.

The review was carried out by PT Inovasi Digital, the private consultancy arm of the nonprofit Earthqualizer Foundation, which the FSC contracted to gather stakeholder views. The Indonesia-based firm confirmed to Mongabay that its role was to summarize stakeholder responses based on a survey template and submit a report to the FSC.

According to MacInnes, the framing of the survey questions appeared to be geared toward corporate concerns — for example, asking how companies “defend their reputation” against affiliates, or how they “educate” subsidiaries and suppliers to comply with sustainability policies. “As a result, the process was narrowly structured and potentially skewed toward corporate perspectives,” he said.

FPP, Greenpeace and RAN also expressed frustration that Inovasi Digital initially drafted conclusions that misrepresented their views, forcing the NGOs to rewrite their sections of the report. The preamble now notes that “the original report’s findings have been rejected by NGOs, and an alternative section has been prepared by the NGOs to better represent their views.”

Deforestation for pulp and paper production in Sumatra. Photo by Rhett A. Butler.
Deforestation for pulp and paper production in Sumatra. Photo by Rhett A. Butler.

Fears of narrowing accountability

While the FSC insists it has only updated its guidance on applying the corporate group definition — not the definition itself — NGOs remain wary.

MacInnes noted that the FSC’s statement “leaves open how much latitude FSC has in adapting or narrowing the application” of the AFi definition, which is intentionally broad to reflect the realities of corporate control.

In response, the FSC said periodic reviews of corporate group scope are normal given “the nature of shifting ownership and control in forestry operations.”

“New best practices or lessons learned on how to determine that scope would be applied when reviews take place, in such a way that is consistent and comprehensible for companies and stakeholders,” the FSC added.

The FSC framed this as a way to provide clarity and consistency, but NGOs remain unconvinced, warning that “best practices” could in reality mean lowering the bar for accountability.

FPP also criticized the FSC for failing to pilot an investigative methodology developed by Greenpeace and supported by more than 25 groups, designed to map corporate structures against the AFi definition and ensure that affiliated entities under effective control are captured within the FSC’s accountability net.

This despite repeated requests by NGOs for the FSC to pilot the methodology.

“Doing so would have represented a meaningful step in the right direction toward strengthening accountability,” MacInnes said. “Instead, FSC commissioned a study that has only delayed the proper application of the AFi definition.”

For NGOs, the concern is that the FSC’s updated guidance could shift the balance toward corporate convenience just as APP and APRIL are seeking readmission. For the FSC, the credibility of its most ambitious accountability experiment hangs in the balance.

“We will have to see the updated guidance to see whether this has been the case,” MacInnes said. “Let’s hope FSC share a version publicly as soon as possible.”

 

Banner image: Rainforest beside cleared and drained peatland in the PT Bina Duta Laksana concession. The Sinar Mas group affiliated concession, a supplier of pulpwood to Asia Pulp and Paper (APP), is located within the Kerumutan Peat Swamp Forest in Riau, Sumatra. Image courtesy of © Kemal Jufri / Greenpeace.

 

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