GFW Pro User Spotlight: SLR Consulting

We spoke to Daniel Witte, Associate Director at SLR Consulting, who is leading the Book Chain Project about how they help companies make sense of the complex supply chains for books and why they decided to work with GFW Pro on their EUDR solution for the publishing industry.

Daniel Witte, Associate Director at SLR Consulting, leads the Book Chain Project

Can you tell us about the Book Chain Project?

The Book Chain Project (BCP) brings together 26 publishers, over 300 paper mills and 400 direct suppliers to work toward responsible book supply chains. We started in 2006 by coming up with a consistent approach to gathering data on the tree fiber sources that were being used to make paper and assessing those sources for deforestation risk. Since then, we have grown to cover all major sustainability challenges facing the publishing industry: climate change and environmental performance, human and labor rights, circularity, and chemical safety.

We provide sustainability information to publishers to enable them to make informed buying decisions, engage supply chain partners on sustainability and build capacity through tools, reports, webinars and guidance documents. We also bring the industry together regularly at events in Asia, Europe and North America.

Printing press. Photo credit: Bank Phrom

The European Union’s deforestation regulation (EUDR) poses unique challenges for the publishing industry. Can you discuss some of these challenges, as well as the practical steps a company in the industry can take to align with the regulation?

First of all, we support the EUDR as we think it is a good regulation. Deforestation is a major global issue as it is a driver of both biodiversity loss and climate change. With deforestation rates increasing in recent years — and global greenhouse gas emissions soaring — more has to be done to tackle deforestation and the twin climate and nature crises that it contributes to.

The challenges lie in the practical implementation. The pulp & paper sector uses large volumes of material, and there is a high degree of mixing. A large paper mill consumes the equivalent of one 32-tonne articulated lorry of wood per hour. Typically, there is no tracing of this material to the end product (the paper reel). Responsible forestry certifications like FSC and PEFC operate on a mass-balance basis.

In addition, pulp and paper mills can get their timber material from tens of thousands of smallholder forest owners in any given year, particularly in places such as North America and Scandinavia. EUDR's definition of a forest covers all those separate forest patches, which all have to be individually monitored.

Photo credit: Mohammed Ahmed

Because the volume of possible forest sources for any paper reel — and by extension, any book — is so large, BCP has always operated on an annual through-put basis: Paper mills would provide us with their annual (audited in some cases) forest source data, which we then assessed for risks using our forest country risk tool, biodiversity risk tool and species risk tool. Paper mills tell us they will be using quite a narrow definition of a “batch” for EUDR— often the production date and even the production time — to minimize the commercial risk from having to discard any batch. However, this poses an issue for us because if we have to assess the source information for the same paper brand 365 times per year, this will lead to enormous duplication of effort and data gathering, particularly given that a mill’s pulp sources are often fairly static. A reactive approach, where an assessment for a particular batch only happens when a publisher or printer requests it, could also lead to supply chain delays.

We are aiming to circumvent these challenges by allowing mills to proactively upload paper source data at intervals of their choosing — for example, on a monthly basis. We will share results of our risk assessment with the mills, so if a monthly “super-batch” comes back as low-risk, the mill knows that each individual batch within that month is considered low-risk.

The other challenge is setting up a robust yet implementable risk assessment system. Given the volume of source material described above and the lack of resources to assess every single data point, we are building an approach based on risk: gathering data only on sources that were not covered by a previous due diligence statement, and risk-assessing sources that require it based on the EU benchmark. Automated risk assessments flag possible risks using GFW Pro for deforestation and forest degradation and an AI-enabled system for legality documentation, built by SLR Consulting in collaboration with the Zoological Society of London (ZSL). Person hours are then only used to review those possible risks and confirm them, such as by looking at satellite imagery or querying a legality document. This allows us to focus limited resources on the areas of greatest risk.

A final challenge is to do with the lack of feasible options for ground-truthing. As the volumes of material are so large with so much mixing occurring, it is almost impossible to get “boots on the ground” to follow up on risk assessment findings. We are attempting to work around this as much as possible through the use of technology and available information, such as the high-resolution Planet satellite imagery that is available on GFW Pro, and by taking an engagement-led approach, working closely with the paper mills and print suppliers upstream.

Timber. Photo credit: Aleksandar Radovanovic

Why did the Book Chain Project decide to work with GFW Pro on its EUDR solution?

We explored various options, but the decision in the end was based on the fact that we had already worked with GFW on our forest country risk assessment tool for many years. WRI and GFW Pro are recognised and highly respected names in this field and recommended by the European Union. Plus, we wanted to support GFW in its mission to provide data on deforestation to the public for free. This aligns with our approach of making our risk tools and other key resources freely available on the BCP website.

With the current proliferation of data sets and methodologies for risk assessment, how does BCP help foster a common understanding of risks among its customers?

We have conducted detailed reviews of different data sets and methodologies, and taken a consultative approach in developing BCP’s EUDR risk assessment methodology, fleshing this out in in-person workshops with the publishers, with input from mills and suppliers. We have taken a pragmatic approach. The draft methodology has been reviewed by GFW Pro and ZSL, with whom we are collaborating on the legality risk assessment.

Currently, there is regulatory uncertainty that may lead to inaction among companies. What is your advice to companies regarding this?

Our main advice is: Don’t let it delay action. This is a complex regulation and it takes time to make the necessary adaptations to systems and processes, and gather the required data from suppliers. We have been taking a flexible approach, adapting as more information about the interpretation and implementation of EUDR becomes available. It won’t be for nothing — even if the regulation is delayed again or diluted, doing the work now means we are still able to improve our due diligence systems and become better prepared for compliance.

Photo credit: Kimberly Farmer