Key documents required for timber legality and trade of China

The below listed key documents are based on the applicable legislation and are considered to play a key role in demonstrating legal origin. The full list of applicable legislation is accessible from the Forestry Legality Alliance website. A list of necessary documents can be found here. The following overview gives important documents necessary for forest product exporters from China.

HARVESTING

Key document	Explanation	Legal authority	Validity
Forest Authority Certificate or Tenure Certificate	Forest tenure certificate is evidence of use right and ownership of forest and forest land, and is also an important document for applying for a harvesting permit. Control checks Certificate validity; rights holder identity; georeference; forest-land category; tenure term; supporting filing.	Real estate registration agency and natural resource administration authority under the State Council	No fixed expiry on the certificate itself; tenure term depends on land class: collective forest 30–70 yrs; farmer reserve hillside (ziliushan) no fixed termination; state forest land no fixed expiry.
Harvesting Permit	The harvesting permit is required prior to harvesting and provides evidence of legal harvesting. Permits according to source type and scale of forest area are issued by different authorities. While harvesting trees, holders must act according to the required time, area, species, and measures of the permit to harvest forest. Contents of the harvesting permit include permit code, harvesting location, species, forest tenure certificate code, harvesting area and stock volume, time period of harvesting and authorized organization etc. Control checks : Land tenure; Harvesting boundary; species control; forest-land class; Harvesting window; regeneration obligation.	The relevant Forestry Administration	Fixed by forestry authority by scale/season; expiry printed on face of permit.

Key document

Explanation

Legal authority

Validity

Forest Authority Certificate or Tenure Certificate

Forest tenure certificate is evidence of use right and ownership of forest and forest land, and is also an important document for applying for a harvesting permit.

Control checks

Certificate validity; rights holder identity; georeference; forest-land category; tenure term; supporting filing.

Real estate registration agency and natural resource administration authority under the State Council

No fixed expiry on the certificate itself; tenure term depends on land class: collective forest 30–70 yrs; farmer reserve hillside (ziliushan) no fixed termination; state forest land no fixed expiry.

Harvesting Permit

The harvesting permit is required prior to harvesting and provides evidence of legal harvesting. Permits according to source type and scale of forest area are issued by different authorities. While harvesting trees, holders must act according to the required time, area, species, and measures of the permit to harvest forest. Contents of the harvesting permit include permit code, harvesting location, species, forest tenure certificate code, harvesting area and stock volume, time period of harvesting and authorized organization etc.

Control checks :

Land tenure; Harvesting boundary; species control; forest-land class; Harvesting window; regeneration obligation.

The relevant Forestry Administration

Fixed by forestry authority by scale/season; expiry printed on face of permit.

Processing & Trade

Key document	Explanation and control checks	Legal authority	Validity
Business registration certificate	As of 1 October 2015, the business registration certificate, tax registration certificate and organization code certificate have been combined into one certificate, which means that fora company established after1 October 2015 there will be only one certificate. The new certificate will be referred to as a business registration certificate. The contents of the business registration certificate include: name and address of the company, type of the certificate, legal representative, amount of investment, valid period, issuing date, business scope etc. With the new certificate, there will be a unique social credit code which takes the place of the business registration number, tax registration number and organization code. Control checks : Unified Social Credit Code; entity name & legal rep; business scope.	Industry and commerce administration authority	Indefinite (subject to annual reporting).
VAT invoice China	An invoice provides evidence of a goods transaction. A VAT invoice (Fapiao) can be evidence of a company paying the tax and tax reimbursement. A VAT invoice can be used to refund tax when exporting and in deducting output tax.		Indefinite (audit trail).
Phytosanitary Certificate	In order to prevent the insect and disease related to plant or export, Chinese inspection and quarantine institutions would conduct quarantine and issue the plant quarantine certificate for qualified products. It must be quarantined for the plants or plant products on the quarantine list, especially at epidemic area. Further, all seeds, seedlings and other breed materials should be quarantined before transportation. In China, pant quarantine certificate could be classified into 3 categories: intra-province, out-province, import-export.	China Inspection and Quarantine Services	21 daysafter issuance (presentation window).Document remains valid indefinitely
Customs Declaration Registration Approval (Certificate for Customs Declaration Company)	All entities that have import and export business should register at Ministry of Commerce of China to obtain the right to import and export. The registration form shows that the holder has the right to legally import and export. The contents of the registration certificate are: name of the entity (both English and Chinese names), address, organization code, contact information, business registration code etc.	Ministry of Commerce
CITES Permit / Certificate for Import / Export & Re-export	According to the “Regulation of the People’s Republic of China on Administration of Import and Export of Endangered Wild Animals and Plants”, people or companies that would import or export endangered wild animals and plants and relevant products are required to apply for this permit/certificate at local authority. The valid period of the permit would not exceed 6 months from issued date, and one-batch-one-license. checks : Authenticity & currency; consignor/consignee exact match; species precision; source compliance; port & use control; foreign supporting docs; quantity control.	National Endangered Species Import-Export Mgmt Office (Admin Authority of China).

LABOUR RIGHTS

	Key document	Explanation and control checks	Legal authority	Validity
	labour contract	Labour contracts are legally required under Chinese labour legislation. Compliance is primarily subject to supervision by the competent Chinese labour authorities. Where substantiated concerns arise, verification of employment contracts may be conducted by competent authorities or qualified auditors through appropriate sampling.	Prepared by operator/harvest contractor; supervised by county-level forestry-grassland + human-resources-social-security authorities.	Contract term + ≥3 yrs retention.

Environmental Protection Requirements

	Key document	Explanation and control checks	Legal authority	Validity
	Environmental Impact Assessment Report or registration Form	Environmental documentation requirements depend on the type of project: New timber production plantations (raw-material forest bases): An Environmental Impact Report Form is required. Other new economic forest plantations: An Environmental Impact Registration Form is required. Existing plantations and routine forest management or harvesting: No new environmental impact assessment is generally required solely for ongoing operations. Wood-processing facilities: Environmental assessment requirements depend on the type of industrial activity and production process. Control checks : Approval validity; scope consistency with EA; EA approval currency.	Competent ecological and environmental authority, according to the applicable approval or registration procedure.	5 years. No general five-year expiry applies to an operating plantation.

Key document

Explanation and control checks

Legal authority

Validity

Environmental Impact Assessment Report or registration Form

Environmental documentation requirements depend on the type of project:

New timber production plantations (raw-material forest bases): An Environmental Impact Report Form is required.
Other new economic forest plantations: An Environmental Impact Registration Form is required.
Existing plantations and routine forest management or harvesting: No new environmental impact assessment is generally required solely for ongoing operations.
Wood-processing facilities: Environmental assessment requirements depend on the type of industrial activity and production process.

Control checks :

Approval validity; scope consistency with EA; EA approval currency.

Competent ecological and environmental authority, according to the applicable approval or registration procedure.

5 years.

No general five-year expiry applies to an operating plantation.

DEFORESTATION-FREE

	Key document	Explanation
	Plot tenure & boundary precise identification	Forest Right Cert / Real-Property Cert, cadastral survey map, forest inventory data, tenure registration archive Control checks Clear non-disputed tenure; boundary matches registration; lawful rights-holder; no pending dispute.
	No-deforestation compliance check	Forest Harvesting Permit, Harvesting operation design, satellite remote-sensing imagery Control checks : Harvesting within permitted boundary; no over-boundary / over-AAC harvest; complete approval chain; no deforestation act.

Key document

Explanation

Plot tenure & boundary precise identification

Forest Right Cert / Real-Property Cert, cadastral survey map, forest inventory data, tenure registration archive

Control checks

Clear non-disputed tenure; boundary matches registration; lawful rights-holder; no pending dispute.

No-deforestation compliance check

Forest Harvesting Permit, Harvesting operation design, satellite remote-sensing imagery

Control checks :

Harvesting within permitted boundary; no over-boundary / over-AAC harvest; complete approval chain; no deforestation act.

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