The amended U.S. Lacey Act has already impacted the wood industry, from the investigation of Gibson Guitars to a recently-reported seizure of Peruvian hardwood. Both of these cases involved solid wood products. But what about paper?
Paper poses the challenge of linking an illegally harvested tree in a faraway forest to a piece of paper purchased in the United States -- after all the mixing and bleaching. Companies in the Forest Legality Alliance and others asked whether or not it is even possible to find Lacey violations in paper products.
Working with others, the World Resources Institute (WRI) decided to check it out.
We sent samples from 32 imported paper products to an independent fiber analysis laboratory. Samples we had tested came from stationery, paper bags, cardboard boxes, toilet paper, facial tissue paper, wrapping paper, and books, including pages, glossy cover sleeves, and cardboard from hardback covers. All products were purchased from stores and outlets in the United States.
With fiber analysis, scientists use high powered microscopes to look at plant fibers and vessels in a snippet of paper to identify what types of trees were used to make it. Vessels are structures that transport nutrients and water in plants, and they have distinct anatomical features that allow for identification of its genus and, in some cases, species.
What we found is telling. 
The tests identified vessels with anatomical features consistent with those of ramin (Gonystylus spp) in a page of a coffee table book and in the cover paper of a childrens' book. These books were purchased from a U.S. retailer and published by U.S. firms but were manufactured in and imported directly from Indonesia. Increasingly rare, ramin trees have been protected internationally since 2003 under the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). Likewise, the Indonesian government has imposed an export ban on all ramin products. In other words, ramin fibers should not be found in paper.
In the cover of another childrens' book, the tests found vessels consistent with those of mangrove trees (Rhizophora spp -- pictured right). Import/export trade databases indicated that this book, too, was manufactured in Indonesia. Mangrove trees are protected from harvest under Indonesian coastal protection, conservation, and forest management laws.
Consequently, all three of these books potentially violate the 2008 amendments to the U.S. Lacey Act, which prohibit trade within the United States of products made from plants that are harvested in contrary to international law or the law of their countries of origin. Since 2008, it has been illegal to import, export, transport, sell, receive, or purchase such plant products -- including pulp and paper -- in the United States. All actors in the supply chain, including importers, publishers, and retailers can be liable under Lacey. Penalties can include forfeiture of goods and fines of up to $500,000 and jail time.
These results demonstrate that it is possible to detect potential Lacey violations for paper, thanks to modern technology. In addition, they suggest that the prevalence of illegally harvested fiber in paper products may be more common than assumed -- three of just 32 products had suspicious fibers.
Furthermore, they portend the possible use of this technology by third parties to uncover Lacey violations. Some NGOs have already used fiber analysis to determine whether books were made from plantation wood or from natural tropical rainforests. Now we know they can find potentially illegal species in paper, too.
So what can companies in the paper supply chain do to avert the risk of purchasing paper with illegal fiber in it?

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