Identifying high-risk timber exports from Viet Nam to JapanAn ITTO-backed study
has explored how
to identify high-risk
species in timber
products exported
from Viet Nam toJapan, including
those using timber
originating inother countries
by Taiji Fujisaki,1Xuan Phuc To2 andMakino Yamanoshita1
1 Institute for Global Environmental

Strategies (IGES)

2 Forest Trends(fujisaki@iges.or.jp)

Clear sourcing required: Imported poles in Ninh Binh Province, Viet Nam. Photo: T. Fujisaki/IGES

Viet Nam has emerged as a globally important supplier ofprocessed timber products, positioned as second in Asia andfifth in the world in export value (MARD 2021). Timber
products from Viet Nam are exported to over 140 countries
and territories, with the United States of America being thelargest market, accounting for over 60% of the resulting
export revenue, followed by Japan (10.6%), China (10.1%),
the Republic of Korea (6.8%) and the European Union (4.5%)(To et al. 2021).
While domestic plantations are a major source of timber inViet Nam, the country also relies on imported raw materials
to sustain its timber industry. Annually, Viet Nam imports
5–6 million m3 of logs and sawnwood of which 30–40%
are tropical species, and 60–70% temperate species (Cao etal. 2021).
However, there has been less transparency on which imported
species are used in Viet Nam’s wood industry and where thesector’s products are consumed. High-value tropical hardwood
species are a lucrative target for illegal logging, and someJapanese importers are concerned that Vietnamese products
may involve risk species imported from other countries.
Despite the recent push by the Vietnamese government toestablish legal frameworks to exclude illegal timber from all
supply chains, the absence of comprehensive informationand data could hinder efforts to promote the trade of legally
harvested timber and timber products.
In this context, a study was conducted under an ITTO project3
to generate an overview of timber products exported fromViet Nam to Japan and identify high-risk imported species
in timber products. This article shares key findings andinsights from the study.
3 ITTO Project PP-A/56-342B “Analysis of Timber Legality Assurance Systems

and Good Practices in China and Viet Nam for Sustainable Timber Trade”

10 ITTO Tropical Forest Update 32/2

The study considered products to be high-risk when
Vietnamese exporters had used imported timber classified
as a high-risk shipment under Decree No.102/2020/ND-CP
on Viet Nam Timber Legality Assurance System (hereafterDecree 102), which was issued in September 2020. It drew
on both quantitative and qualitative data. Quantitative
data was obtained from timber trade statistics provided
by Viet Nam’s General Department of Customs. The levelof risk was identified based on detailed examination of thedata concerning timber products exported from Viet Nam
to Japan between January 2018 and June 2021, combinedwith insights derived from in-depth interviews withrepresentatives of Viet Nam’s Ministry of Agriculture andRural Development (MARD), relevant industry groups,
and timber traders and processors in Viet Nam.

Risk criteria
Decree 102 stipulates that the control of timber imports
be undertaken based on the country of origin and the tree
species involved. Article 5 of the decree details the criteria
for geographical risk identification, and Article 6 focuseson the criteria for species risk identification (Box 1).
MARD has published the list of the positive geographies
and the list of imported species on the website of theForest Protection Department.4 Imports from countries
that are not on the list of the positive geographies orof timber species not on the species list are consideredhigh-risk shipments. In general, under Decree 102, almost
all tropical timber imports into Viet Nam are regarded
as high-risk, as they are from countries not listed in thepositive geographical area list.

4 http://www.kiemlam.org.vn/ (Vietnamese language)

High-risk traces? Even pellets, for which this plantation wood in Viet Nam’s Nghệ An Province has been harvested, could contain traces of high-risk species.
Photo: T. Fujisaki/IGES

Box 1: Risk criteria for timber shipments as stipulated
by Viet Nam’s Decree 102

A source country is considered low-risk if it meets one of thefollowing criteria:• It has a timber legality assurance and Forest Law Enforcement,Governance and Trade licensing system in place.
• It has a national regulatory framework for due diligence covering
entire supply chains that is recognized by the Viet Nam Timber
Legality Assurance System.
• The Governance Effectiveness Index of the country is 0 or higher(using the World Bank’s most recent Global Governance Index),
and the regulatory framework for the country’s implementationof the Convention on International Trade in Endangered Speciesof Wild Fauna and Flora (CITES) is ranked and announced as
Level I by the CITES Secretariat, and one of the two following
conditions are also met: (i) the country has a bilateral agreementwith Viet Nam on timber, or (ii) the country has a national timber
certification system recognized by Viet Nam.
A source country that does not meet one of the three criteria above isconsidered a “non-positive geographical area”, indicating high risk.
A source country meeting at least one of the criteria is considereda “positive geographical area”, or of low risk. Notably, a source
country refers to the country of export and does not necessarily
represent the country of harvest.
An imported species is considered high-risk if it is:• listed in the CITES Appendixes;• listed as a critically endangered or rare species in Category IAand Category IIA according to Viet Nam’s regulations;  
• is being imported into Viet Nam for the first time; or• is illegally traded or threatened with extinction in the countryof harvest as identified by Vietnamese authorities.
Imported species with none of these characteristics are identified
as low-risk.

Results and findings
Figure 1 shows the value of timber products exported fromViet Nam to Japan between January 2018 and June 2021
that contained high-risk species, based on the risk criteria
laid down in Decree 102.
Overall, during the period covered by the study, timber
products exported from Viet Nam to Japan containing
imported high-risk species were small in value (Table 1).
Among the high-risk species involved, Khaya senegalensis(trade name: faux acajen), Dipterocarpus spp. (keruing),
Pterocarpus spp. (padauk) and Entandrophragma spp.
(sapelli) were the most common, accounting for more than
70% of high-risk shipments by value over the period. Thesespecies were imported from Cambodia, the Lao People’s
Democratic Republic, and African countries.
The use of imported high-risk species varied among themajor product groups. In value terms, joinery shows thehighest percentage of risk species used, at a rate between
1% and 3.6%. High-risk species were also found in productsthat use wood-based panels as key materials (e.g. office,kitchen and bedroom furniture). However, the likelihood ofhigh-risk species being used in these products was very low.
High-risk species were not found in wood chips, pellets
or plywood. However, some proportion of pellets may be
produced from the residues of high-risk species, dependingon their sources. Some plywood products may use tropical
hardwoods such as Aucoumea klaineana (okoumé),Calophyllum spp. (bintangor) and MLH (mixed lighthardwood). However, any high-risk species are likely used insmall amounts, and exporters may not declare them. Also,if a product is made from several species (e.g. a chair is madefrom 4–5 species), not all species are necessarily declared.

ITTO Tropical Forest Update 32/2 11

… Identifying high-risk timber exports from Viet Nam to Japan
Table 1: Presence of high-risk tree species by major product type in exports from Viet Nam to Japan, January 2018–June 2021Customs code (product)

Overview of export trade (values approximate)

High-risk species identified

HS 440122 (Wood chips)

Annual export value USD 400–500 million. Acacia
commonly used, also eucalyptus and pine.

None

HS 440131 (Wood pellets)

Annual export value USD 160 million. Acacia
commonly used, also rubber, eucalyptus and pine.

None

HS 4412 (Plywood)

Annual export value USD 40–50 million. Acacia
commonly used, also eucalyptus and styrax.

None

HS 4418 (Joinery)

Annual export value USD 50 million. 40 species used;rubber, oak, ash and pine most prominent.

Five, keruing and padauk most common,accounting for 1–3.6% of export value.

HS 9401 (Seats)

Annual export value USD 120 million. Rubber, acacia,eucalyptus and oak (imported) commonly used.

Five, faux acajen most common, accounting
for 0.4–0.9% of export value.

HS 94033 (Office furniture)

Annual export value USD 80 million. Rubber, oak(imported), ash and pine commonly used.

Three, sapelli most common, accounting
for only 0.002–0.050% of export value.

HS 94034 (Kitchen furniture)

Annual export value USD 60 million. Rubber, acacia
and pine commonly used.

One, accounting for negligible shareof export value; none since 2019.

HS 94035 (Bedroom furniture)

Annual export value USD 110 million. Rubber, MDF
and pine most commonly used.

One, rosewood, in 2018, accounting
for negligible share of export value.

HS 94036 (Other wood furniture products)

Annual export value USD 110 million. Rubber, acacia,pine, walnut and oak commonly used.

Five, accounting for 0.26–0.35% of export value.

Source: To et al. (2022)

Figure 1: Value of timber products containing high-risk species exported to Japan, January 2018–June 2021
1800
1600
1400(USD 1000)

1200
1000
800
600
400
200

2019

2020

p.
sp

ag

hrrop

nd

En

ta

or
rhela
n

maer

sp

cif

a

oe
alac

ille
tti
M
M

2018

ap.

p.
sp
sro
py
os

Di

Pa

ras

ho

rea
sp
Af
p.
ze
lia
Pt
ers
ppo.
Di carp
pt
us
er
sp
oc
p.
arpu
s
sp
p.

ta
ala
ali
arm
in

Te

Kh

ay
ase
ne
ga
len
Sh
sisor
eaob
Da
tu
sa
lb
er
gi
asp
p.
Xy
lia
xylocarpa0

Jan–Jun 2021

Source: To et al. (2022)

Lessons from the study
Although timber exports from Viet Nam may vary in volume
and product type depending on the destination country,
and may also differ in terms of the timber species used in
the products, the findings of this study focused on exportsof timber products from Viet Nam to Japan seem broadly
applicable to other countries.
It is important that competent authorities of countries
importing timber products from Viet Nam are familiar withthe high-risk species identified under Decree 102 and request
12 ITTO Tropical Forest Update 32/2

importers to clearly declare both species and country ofharvest, which would ensure compliance with regulations
such as the Japanese Clean Wood Act, and the EU Timber
Regulation. If the species in products from Viet Nam are
high-risk according to Decree 102, authorities need to ask
importers to exercise due diligence to mitigate the risk.
The findings of the study are also applicable to the overalltimber trade. As Figure 1 and Table 1 show, customs data
can help identify species contained in traded timber
products, providing a valuable basis for authorities inimporting countries to carry out risk-based management.

Also, identifying risks could help importers mitigate risks
associated with their shipments. On the other hand, it isimportant to recognize the limitations of customs data,
which are derived from the declarations of traders. The
study indicates that there are cases where traders did notdeclare the species used in their timber products; forexample, traders might only declare the major species
in a product and omit minor species.
The risk criteria laid out in Viet Nam’s Decree 102 can beeasily applied. However, different countries use different
criteria for risk assessment and may have different views
on geographical and species risks. The authorities of exportingand importing countries should communicate with eachother to better understand the legal frameworks and legality
criteria of their trading partners. Authorities should informtheir importers/exporters of any differences in risk criteria
between countries so that adequate due diligence canbe conducted.

References
Cao, T.C., Tran, L.H., and To, X.P. 2021. Market update report onViet Nam’s timber import as of August 2021. VIFOREST, BIFA, FPA
Binh Dinh, HAWA and Forest Trends. Available (in Vietnamese) at:
https://goviet.org.vn/upload/aceweb/content/FN_Viet%20Nam%20
Nhap%20khau%20go%20nguyen%20lieu%208%20thang%20
2021.24.9.pdf
Ministry of Agriculture and Rural Development (MARD). 2021.
Proposal on the sustainable and effective development of woodprocessing industry sector in 2021–2030 period. (Unpublished draftfrom August 2021; Vietnamese language).
To, X.P., Cao, T.C., and Tran, L.H. 2021. Viet Nam’s import and exportof wood and wood products: Situation in 2020 and trends in 2021.
VIFOREST, BIFA, FPA Binh Dinh, HAWA and Forest Trends.
Available (in Vietnamese) at: https://goviet.org.vn/upload/aceweb/
content/1626947564_BC%20XNK%20G.SPG%20Nam%202020_FINAL.pdf
To, X.P., Fujisaki,T., and Makino, Y. 2023. Viet Nam’s timber exports toJapan during 2018–2021 with a focus on products made using high-risk
species. Institute for Global Environmental Strategies (IGES) andInternational Tropical Timber Organization (ITTO), Yokohama, Japan.

More details of the project can be found at:
www.itto.int/news/2023/04/05/new_analysis_of_timber_legality_assurance_systems_and_good_practices_in_china_and_viet_nam_released/
Project outputs can be found by inserting the project code
PP-A/56-342B into the ITTO project search function atwww.itto.int/project_search.
This ITTO project was made possible by funding from theGovernment of Japan.

ITTO Tropical Forest Update 32/2 13