Illegal ramin documented in APP's pulpwood supply
This investigation exposes how illegal ramin is entering APP’s pulpwood supply at its flagship mill, Indah Kiat Perawang – a violation of Indonesia’s ramin ban and its national CITES regulations. The pulp mill is supplied with rainforest logs from the clearance of areas including peat swamp forest; its pulpwood logyards contain illegal ramin logs. The mill trades to at least 12 APP paper mills in Indonesia and China.
Indah Kiat Perawang, Riau, Sumatra, Indonesia, September 2011: A year-long undercover investigation documented numerous illegal ramin logs mixed in with other rainforest logs waiting to be pulped at APP's Indah Kiat Perawang pulp mill.
Previous field investigations of APP's supply chain have documented the group's dependence on mixed tropical hardwood (MTH) from the clearance of peat swamp forests, a key ramin and tiger habitat, in areas including Kerumutan (Riau, Sumatra) and Bukit Tigapuluh (Jambi, Sumatra).
This investigation exposes how ramin - a legally protected tree species both within Indonesia and in international trade - is regularly and illegally entering APP's MTH pulpwood supply at APP Indonesia's flagship pulp mill, Indah Kiat Perawang in Sumatra. The presence of ramin in Indah Kiat Perawang's MTH pulpwood logyards is a violation of Indonesia's ramin ban and its national CITES regulations.
The investigation documents three supply chain issues relating to Indah Kiat Perawang's violation of Indonesia's ramin ban and its national CITES regulations:
- Indah Kiat Perawang's dependence on fibre from natural forest clearance is significant and increasing. Indah Kiat Perawang supply areas include large areas of peat swamp forest, a key ramin habitat (showing the extent of MTH use and the overlap of the supply area with ramin habitat).
- Indah Kiat Perawang's logyards contain ramin logs mixed in with other species of logs from natural forest (demonstrating the presence of illegal ramin in the MTH supply).
- Indah Kiat Perawang trades to at least 12 APP paper mills in Indonesia and China that then trade paper products to the global market (showing multiple global trafficking routes for Indah Kiat Perawang). Fibre tests have confirmed the presence of MTH in the supply chains of most of these mills.
Within any published documents or web pages associated with this investigation, 'The Ramin Paper Trail', 'Greenpeace' refers to Greenpeace International, registered in Amsterdam, which is solely responsible for the content and findings.
APP pulpwood supplies depend on clearance of a key ramin habitat
APP’s pulpwood supplies areas – primarily located on Sumatra – include extensive peat swamp forest. Between 2003 and 2009, an area of peat swamp forest twice the size of New York was cleared in these areas. Nearly half of the pulpwood supplied to APP’s Indah Kiat Perawang mill comes from natural forest clearance. Contrary to its commitments to use only renewable plantation fibre, APP has been increasing the proportion of rainforest logs – so-called mixed tropical hardwood or MTH – in its supply.
Ramin risk: APP's Indonesian pulpwood supplies are located predominantly in provinces that include ramin habitat
APP has two main pulp mills in Indonesia, both located on the island of Sumatra. According to APP's latest (published November 2011) 2008/2009 corporate sustainability report:
- Indah Kiat Perawang, in Riau, produced ~2 million tonnes of pulp in 2009 and accounted for 73% of APP Indonesia's pulp production.
- Lontar Papyrus, in Jambi, produced ~700,000 tonnes of pulp in 2009 and accounted for 27% of APP Indonesia's pulp production.
APP pulpwood supply areas are primarily also located on Sumatra, chiefly in the provinces of Riau, Jambi and South Sumatra. This includes large areas of peatland, a key habitat for ramin identified by the Ministry of Forestry.
Greenpeace mapping analysis shows that in areas currently controlled by APP suppliers, there was 440,000 ha of Sumatran peat swamp forest in 2003 and 260,000 ha of peat swamp forest in 2009. The 180,000 ha of peat sawmp forest loss equates to the clearance of an area more than twice the size of New York City.
Further, a 2009 Ministry of Forestry document naming the supply areas for Indah Kiat Perawang reveals that an important volume of the MTH supplied to the mill comes from concessions located on peatland.
Extensive historic MTH use: APP Indah Kiat Perawang has historically depended on natural forest clearance
Since the 2001 ramin logging ban, APP pulp mills have continued to be heavily dependent upon MTH fibre from clearance of natural rainforests to meet pulp production needs. A Sinarmas Forestry document obtained by Greenpeace details the share of raw material supplies between 2002 and 2006 to APP's Indah Kiat Perawang mill that were met by MTH pulpwood (ie natural forest clearance):
- In 2002, 77% of pulpwood supplied to the mill was MTH.
- In 2006, 45% of pulpwood supplied to the mill was MTH.
Extensive current MTH use: nearly half of pulpwood supplied to APP Indah Kiat Perawang comes from natural forest clearance
Indah Kiat Perawang, Riau, Sumatra, Indonesia, May 2011: Rainforest logs waiting to be pulped at APP's Indah Kiat Perawang pulp mill.
According to APP's 2008/2009 corporate sustainability report, published in 2011, about 20% of the declared pulpwood supply to Indah Kiat Perawang in 2009 was mixed tropical hardwood.
However, the same report indicates that Indah Kiat Perawang was seeking approval to increase its licensed pulp production capacity by an additional 1 million tonnes per year, a 50% increase from its 2009 licensed capacity.
According to Ministry of Forestry data for 2011, pulpwood supplies to Indah Kiat Perawang were predicted to be sufficient to produce over 2.3 million tonnes of pulp, thus indicating that the mill is already expanding pulp production.
Ministry of Forestry data suggest that the mill is increasing its dependence on MTH in order to accommodate this expanding production. According to Ministry data, the mill used 2.4 million m3 of MTH in 2009 - roughly equating to the proportion of pulpwood supply APP declared as coming from MTH. Ministry of Forestry data show that this volume rose to over 4.5 million m3 in 2010 and was planned to increase to nearly 5 million m3 in 2011 - equating to 44% of the pulpwood supply to the mill.
Using harvest rates assumed by internal Sinarmas Forestry planning documents, 5 million m3 of MTH logs amounts to ~64,000 ha of rainforest clearance in 2011 alone - that is the area of Jakarta.
This means that APP is currently increasing use of MTH as a proportion of its supply at the same time as expanding production of pulp. This is in spite of APP's repeated promises over the past decade to become fully reliant on renewable plantation fibre - initially by 2007, subsequently revised to 2009 - and to end its dependence on logs from rainforest clearance in Indonesia. In 2011, APP's head of sustainability, Aida Greenbury, again revised the commitment to use only plantation fibre, postponing it to the end of 2015 - eight years after the initially promised date. However, the above figures suggest ongoing increases in production levels that far outstrip availability of plantation-grown supplies, meaning expansion is continuing to fuel forest destruction.
Ramin is a readily recognisable wood with distinctive characteristic features. Testing laboratories can confirm the identity of ramin wood. During this investigation, samples of wood from the Indah Kiat Perawang mill were analysed by an internationally respected authority on protected wood species, and 46 samples were confirmed as ramin.
Ramin is readily recognisable as a log
Indah Kiat Perawang, Riau, Sumatra, Indonesia, August 2011: Illegal ramin log identified at APP's Indah Kiat Perawang pulp mill. Ramin wood is susceptible to a distinctive blue mould.
Ramin, particularly Gonystylus bancanus, is a readily recognisable white wood species, identifiable by a number of key characteristics beyond the timber colour and grain.
According to various Ministry of Forestry documents, felled ramin logs are easily identifiable from a number of characteristic features. These include:
- Wood: the heartwood is whitish to pale yellow.
- Outer bark: the outer bark surfaces are smooth to cracked, shallowly fissured or scaly, dull gray to red-brown or dark brown in colour, occasionally with white patches.
- Inner bark: the inner bark contains numerous fine, brittle fibres that break off and irritate the skin, yellow, brown, pink or orange in colour.
- Mould: wood is susceptible to fungal attack, producing a blue stain discolouration.
From a small sample of ramin wood, a trained eye can identify the characteristic wood structure and anatomy of Gonystylus species using a handheld magnifying glass.
Testing laboratories can confirm the identity of ramin wood
Dr Gerald Koch, an internationally-recognised expert on wood species, inspects a ramin sample collected at APP's Indah Kiat Perawang pulp mill.
Institute of Wood Technology and Wood Biology, vTI, University of Hamburg, Germany, March 2011: Radial view of ramin vessels. Microscopic image of wood sample EC198612 confirms that it is ramin. The sample was collected from an illegal ramin log identified at APP's Indah Kiat Perawang pulp mill.
Testing laboratories can readily confirm the identity of ramin wood from small samples collected in the field:
- Grain/vessel structure: through macroscopic and microscopic analysis of small sectioning blocks prepared from individual wood samples the identity of ramin can be confirmed based on its characteristic grain/vessel structure.
Investigating the pulpwood supply for Indah Kiat Perawang
Indah Kiat Perawang, Riau, Sumatra, Indonesia, March 2011: Collection of wood sample EC198612 from an illegal ramin log identified at APP's Indah Kiat Perawang pulp mill. Samples were locked with a security seal and sent for independent verification.
Indah Kiat Perawang, Riau, Sumatra, Indonesia, August 2011: Collection of wood sample EC198979 from illegal ramin log identified at APP's Indah Kiat Perawang pulp mill. A total of 46 wood samples were taken from the numerous illegal ramin logs documented at the pulp mill. An independent expert verified that the samples were ramin.
Over the course of a year, small samples of wood were taken from a selection of the logs identified as ramin in the MTH logyards for Indah Kiat Perawang. The sample wood specimens were placed in tamper-proof bags, which were then locked with a security seal bearing the manufacturer's unique identification code.
The samples were sent to the Institute of Wood Technology and Wood Biology at vTI, in Germany. At the laboratory, the seals were removed and an expert specialising in the identification of CITES-listed woods analysed the wood samples from the bags in order to confirm their identity as ramin.
vTI, the German Federal Government Research Institute for Rural Areas, Forestry and Fisheries, is an internationally respected authority on identification of wood samples. One of its roles is to aid the German government with enforcement of CITES trade regulations through the identification of timber species.
Of the samples collected within the mill's logyards, the wood specialist at the institute confirmed that 46 were ramin.
Illegal ramin is part of the mix at Indah Kiat Perawang
Independent laboratory testing and video documentation in the logyards at the Indah Kiat Perawang pulp mill expose the regular presence of ramin in APP’s pulp supply – a violation of Indonesia's ramin ban and its national CITES regulations. As the agency responsible for enforcing Indonesia’s ramin ban and national CITES regulations, the Indonesian Ministry of Forestry should impose sanctions against APP.
A year-long investigation into the supply chain for APP exposes that illegal ramin logs are regularly mixed in with other rainforest species waiting to be pulped at APP’s Indah Kiat Perawang pulp mill.
Video footage documenting these ramin logs was collected between February 2011 and January 2012 from within accessible areas of the various extensive logyards within the compound surrounding Indah Kiat Perawang’s pulp mill.
Wood samples collected from a number of those logs during the course of the investigation were sent to an internationally recognised expert for independent identification.
In total, 46 of these wood samples collected within the mill’s logyards between February and December 2011 were confirmed to be ramin by this expert.
In December 2011, a further 13 wood samples were collected from logs suspected to belong to other species listed on the IUCN Red List of Threatened Species. Results of expert analysis show that 10 of these belong to genera with species classified as threatened on the IUCN’s Red List, including Shorea spp, Durio spp, Palaquium spp and Alstonia spp.
Summary of overall findings
A total of 59 wood samples were collected within the mill’s logyards and sent for independent identification: 46 were ramin, ten were IUCN Red List genera and 3 were other species.
Exposing the regular presence of ramin in the pulp supply
Indah Kiat Perawang, Riau, Sumatra, Indonesia, September 2011: Illegal ramin log identified at APP's Indah Kiat Perawang pulp mill. Ramin bark is characterised by fine, brittle fibres.
APP's Perawang complex covers 2,400 ha and hosts its Indah Kiat Perawang pulp mill, plus key paper and tissue mills. These mills are surrounded by vast logyards organised into separate, distinct avenues of MTH and plantation logs.
In early 2011, a preliminary assessment within the Indah Kiat Perawang complex as part of this investigation into the mill’s pulpwood supply documented ramin within one of the MTH logyards.
To confirm that this was not an exceptional instance, the investigation included subsequent visits over the period of a year to accessible areas of the various logyards. These included points where MTH logs are initially unloaded, stockpiled or transported to the chipping facility attached to the pulp mill. In each of the nine different months when evidence was gathered within the compound, ramin logs were observed, confirming the regular presence of ramin within the MTH supply chain.
Indah Kiat Perawang, Riau, Sumatra, Indonesia, October 2011: Collection of wood samples from illegal ramin logs identified at APP's Indah Kiat Perawang pulp mill. Three sample bags can be seen on ramin logs lying within just a few paces of each other.
Video documentation gathered during the investigation shows:
- Ramin logs were readily recognisable and distinguishable from other species in the MTH logyards.
- Multiple ramin logs could be found within a given avenue of MTH logs, often within just a few short paces of one another, indicating that the mill pulpwood supply includes logs from the indiscriminate clearance of ramin habitat. The number of ramin logs within accessible short sections of logpiles often ranged from 10 to 17.
- Ramin logs ranged in size, including mature logs with diameters of up to 1 metre.
- Representative samples from logs identified as ramin were sent for independent verification. These were collected from different logs from accessible areas within the logyards in the mill compound and sealed in tamper-proof evidence bags.
An internationally respected expert at the Institute of Wood Technology and Wood Biology at vTI, University of Hamburg in Germany confirmed that 46 samples were ramin. This shows that the readily recognisable ramin logs were correctly identified in the investigation.
Our evidence proves the presence of ramin in the MTH pulpwood supply for Indah Kiat Perawang. This is a violation of Indonesia’s ramin ban and its national CITES regulations.
APP has failed to enforce its fibre policy, despite ample opportunity
Indah Kiat Perawang, Riau, Sumatra, Indonesia, October 2011: Collection of wood sample EH897527 from illegal ramin log identified at APP's Indah Kiat Perawang pulp mill. The log measures about a metre wide.
This component of the investigation focused on the final transit stage in the pulpwood supply chain for Indah Kiat Perawang, prior to entry to the pulp mill chipping facility. Despite the fact that ramin is readily recognisable, our evidence indicates the failure of APP’s Fiber Procurement Policy to ensure compliance with CITES regulations and eliminate illegal ramin at any stage along the supply chain prior to arrival in the mill’s MTH stockyard. Opportunities for visual inspection to control the pulpwood supply chain before it enters the mill gate – ie, from the forest to the mill logyard – would include:
- Before it is logged: within the forest area prior to any planned clearance.
- Before it leaves the logging concession: within the logging operation's logpiles and logyards.
- At any point along the inbound shipment to the mill: as cargo loaded on trucks or barges en route to the mill.
- Before it enters the mill's MTH logyards: at the wood checking station before the mill gates or at an equivalent checkpoint at Indah Kiat Perawang's port where log barges are offloaded.
While publicly APP claims to have a verification process to exclude illegal wood prior to it entering the pulp mill, our investigation exposes how this document-checking exercise obscures the reality that illegal ramin logs are entering the supply chain of APP’s largest pulp mill, Indah Kiat Perawang.
The case for Ministry of Forestry sanctions against APP
Merang, South Sumatra, Sumatra, Indonesia, May 2010: Logging truck loaded with rainforest logs near concession area of APP pulpwood supplier PT Rimba Hutani Mas. The concession, located primarily on peat swamp, has been largely cleared of rainforest since 2006.
At the time the Indonesian government proposed the CITES Appendix II listing for ramin, although it identified the clearance and conversion of ramin habitat as a problem, it did not identify any national or international trade in pulp or paper products associated with utilisation of ramin from that clearance. It reported that ramin was logged only to supply the timber sector.
However, as this investigation demonstrates, one of the key ramin habitats – peat swamp forest in Sumatra – is being cleared to supply APP with MTH pulpwood and ramin logs are ending up in the pulpwood supply for APP.
A key role of Indonesia’s CITES Management Authority, the Ministry of Forestry, is to enforce Indonesia’s ramin logging and trade ban and to ensure that no ramin enters international trade in violation of CITES regulations.
Under the requirements of Indonesian CITES regulations implementing the Convention, one of the roles of the Indonesian CITES Management Authority is to prevent any company from utilising illegal ramin, including the export of products derived from ramin. In the case of APP, this would mean preventing any illegal ramin logs from the indiscriminate clearance of ramin habitat entering the APP pulp supply chain.
The MTH pulpwood supply for Indah Kiat Perawang is undermining the law
Merang, South Sumatra, Sumatra, Indonesia, May 2009: Barge loaded with rainforest logs near Merang in South Sumatra.
APP’s pulp and paper operations in Indonesia service an export-oriented market, for which Indah Kiat Perawang, Indonesia’s largest pulp mill, is the primary source of pulp raw materials. MTH pulp from this mill is utilised by export-oriented APP paper mills in Indonesia and China, which ultimately trade with up to 136 CITES party countries.
The mill sources its MTH logs via Sinarmas Forestry from rainforest clearance, including significant clearance of peat swamp forest. Hence, the presence of MTH fibres in an end product is a useful risk indicator that the product includes fibre from the indiscriminate clearance of ramin habitat; this pulpwood supply to Indah Kiat Perawang has been documented to include illegal ramin.
While MTH fibres are readily identifiable in paper products, the isolation and identification of individual protected species such as ramin within the mix can be difficult and chance – testing laboratories look at 1 cm2 samples.
The next section documents how MTH fibre from Indah Kiat Perawang’s pulp production enters into international trade and may be associated with APP products manufactured and traded in key CITES countries.