Defra: Consultation on the UK Implementation of the European FLEGT Regulation 2005
(2009)
JNCC Consultation 0939
Submission by the Joint Nature Conservation Committee
Enclosed is JNCC's response to the consultation on the UK Implementation of the European FLEGT Regulation 2005. Submitted on 10th December 2009.
 
 

Summary of key points

 
JNCC have provides comments on some, but not all, questions in the context of their role as statutory adviser to the UK government on nature conservation.  JNCC also act as the UK CITES Scientific Authority on fauna; the complementary role for plants being undertaken by the Royal Botanic Gardens Kew.  Whilst colleagues in Kew may offer more detailed comment on issues pertaining to the timber trade, we believe that there are lessons from the implementation from CITES that might usefully be applied to FLEGT implementation.  Appointing Animal Health as the competent authority for FLEGT licensing offers the opportunity to achieve significant cross-over benefits between the two regulatory functions (especially as some timber species are also CITES-listed).
 
We accept the need for delayed full cost recovery as a means of seeking to ensure that the costs of regulation do not act as perverse incentives to shift trade away from FLEGT licensed timbers to trade from other states (and thus potentially to illegal timber).  We also recognise that the costs being considered are only those for UK importers.  Additional costs may also be incurred before export in the country with the VPA.  As the aim is to provide incentives to make FLEGT timber more attractive to consumers, it would seem reasonable to consider any additional costs that may be incurred at the exporting end into cost-benefit calculations.  Having said that, the suggested costs of licences for traders in the UK seem likely to be modest set against comparable charges for CITES licences.
 
 
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Please cite as: JNCC Consultation 0939, (2009), Defra: Consultation on the UK Implementation of the European FLEGT Regulation 2005, Submission by the Joint Nature Conservation Committee