In the SHC Assurance System, the risk of illegal harvesting is assessed against the “Framework for Jurisdictional Risk Assessment (JRA) of Legal Compliance of Hardwood Production in the USA”. The JRA Framework is designed to consider all aspects of legal compliance in the hardwood producing industry in the U.S., from point of harvest to point of export. It is applicable to hardwood logs sourced from forest properties used in the production of sawnwood, mouldings, veneer, plywood, engineered wood products, and co-products from hardwood mill residuals.
The JRA Framework sets out qualification criteria for the Risk Assessor responsible for preparing the JRA. The Assessor must be independent of the parties that are the subject of the risk assessment and that any payments for preparation of the risk assessment must not depend on its outcome. The Assessor must have appropriate professional experience and training and is expected to utilise a team of experts.
The Framework also sets out the criteria and indicators to be evaluated during the JRA. These draw on and aim to align with a wide range of regulatory requirements (Lacey Act, EUDR, UKTR), certification standards (FSC, PEFC, SFI, SBP), government procurement policies (UK Government TPP), UN guidelines (FAO Guiding Legal Elements) and non-governmental guidelines (WWF Global Forest & Trade Network). The JRA Framework has built on these sources — which exhibit a high level of consistency and overlap — to facilitate robust legality assessment in the context of U.S. hardwood forests, jurisdictions, and legislative approaches.
SHC endorses JRAs that have been assessed by an Independent Scrutineer, appointed by SHC, as in compliance with the JRA Framework. An SHC-endorsed JRA is a publicly accessible document that is valid for 5 years. A single JRA is required per jurisdiction, defined as individual states in the United States. All SHC-endorsed assessments are publicly available and shall be used by hardwood mills implementing the SHC chain of custody standard to verify the legal status of hardwood materials. SHC-certified mills shall take action to mitigate any risks identified in the SHC-endorsed JRA for jurisdictions from which they source timber.
In September 2023, AHEC commissioned a first tranche of risk assessments in line with the JRA Framework, one for each of the 33 states that together represent almost 99% of the volume of hardwoods harvested annually in the United States. The 33 risk assessments are due for completion in October 2024. They are being prepared by Dovetail Partners, a 501(c)(3) organisation which has more than twenty years of experience with responsible sourcing standards, environmental assessments, and associated expert review and consultation processes, with a strong focus on small-scale and non-industrial hardwood forests.
The Dovetail Partners Risk Assessment Team is composed entirely of U.S.-based experts with a high level of familiarity and experience with the U.S. legal framework, as it applies to forestry and the forest products sector. In addition to the core team, subject matter experts are engaged as needed throughout the project to address specific requirements of the standard within local contexts.
The JRAs, prepared by Dovetail Partners and endorsed by SHC, consider the hardwood forests of the United States in all their complexity and diversity, in terms of ecology, geography and role within society. Each assessment considers the private sector, dominated by small-scale, non-industrial producers (family forests), through to larger industrial operations and state or federally owned and managed operations. They consider federal laws and state laws and the role and effectiveness of forest governance.
Each State Risk Assessment typically consists of a 60+ page document following the outline set out in the JRA Framework. On completion, the assessments will collectively amount to around 2000 pages of analysis and refer to 3000+ reports, statutes and academic papers. In the process of producing the assessments, 500+ individuals and organisations have been contacted of which 200+ have been consulted directly. The insight of the local consultees assists greatly in helping the assessors understand their realities, in addition to the enormous volume of raw data and public information available.