We read the AS/NZS 4708 draft. Europe’s 2006 deforestation cut-off is now written into an Australian standard

The draft is a public comment document titled DR AS/NZS 4708:2021 Amendment 1:2026, and it carries the standards-drafting warning on its cover: liable to alteration, do not use as a standard. Comment opened 28 May 2026 and closes 7 August 2026. What follows is what the document itself says, clause by clause.

Why it is being amended, in the draft’s own words

The draft lists five aims. The Standard is to be aligned with PEFC ST 1003:2024 so it continues to be suitable for PEFC endorsement; aligned with the EU Deforestation Regulation; to consider the impacts of climate change; to make management of significant biodiversity values consistent with the Environment Protection and Biodiversity Conservation Act 1999; and to be strengthened to align with the expectations of Indigenous peoples, “especially to recognise free, prior and informed consent (FPIC)”.

On the first two, the draft is blunt about the compulsion involved: “All PEFC endorsed Standards must be updated to align with PEFC ST 1003:2024 to maintain PEFC endorsement and recognition”, and PEFC ST 1003:2024 “was developed and updated to align the PEFC system with the EU Deforestation Regulation and to ensure that PEFC certified products are deforestation free and comply with the EUDR”.

That confirms from the primary document what we could previously only attribute to a media release. It is not a discretionary Australian policy choice. It is a global condition of keeping the PEFC mark, and every endorsed standard in the world is doing the same thing.

The three new clauses

The amendment touches the Preface, clauses 1.1 and 1.2, the definitions, and clauses 4.1, 5.2, 6.1.2, 7.4.5, 11.1.4, 11.2.9, 11.3.2, 11.3.3, 11.6.1 through 11.6.5, and Table A2. Three clauses are entirely new.

11.1.6 Forest degradation is the shortest and the bluntest: “The forest manager shall not engage in forest degradation.” A note carves out plantations established for protection or ecosystem restoration, and forests established by planting or seeding that resemble, or will resemble at maturity, naturally regenerating forests.

11.1.7 Conversion of forest to other land use is where the European date arrives. The forest manager must demonstrate that the defined forest area does not include areas converted from forest to other land uses after 31 December 2006, excluding cases where legal approvals predate that day. Conversion after the cut-off is permitted only in justified circumstances meeting six conditions at once, among them that it complied with national and regional land-use planning by a government authority, that affected stakeholders could contribute through transparent consultation, that it did not adversely affect significant biodiversity values or legally recognised offsets, that it did not destroy areas of significantly high carbon stock, and that it involved no greater than 5 per cent of an ecosystem type within the certified area. Infrastructure built for forest management does not count as conversion.

11.1.5 Reversion of plantations to agricultural use prohibits returning a plantation to farmland unless there is ecological, social, cultural and economic justification and a similar list of conditions is met, including that the plantation was established on land converted from native forest before the same 31 December 2006 date. It carries an explicit EUDR note: where land was under agricultural use before the cut-off and was temporarily afforested without legal protection, EUDR guidance deems it to remain agricultural.

Free, prior and informed consent

The second substantial change is Indigenous rights, and it is more than a wording tidy. The draft inserts a new definition at 3.34 defining FPIC as “the right of Indigenous Peoples to make decisions about activities that may affect their lands, territories, resources, or rights”, and breaks the term into its four parts: consent given voluntarily and without coercion; sought sufficiently in advance; informed by information provided before and during the process; and reached through the customary decision-making processes of the communities. It points readers to the Commonwealth’s FPIC guidelines and the AIATSIS FPIC Policy Snapshot.

Clause 11.6.2 is rewritten so that the forest manager must recognise Indigenous rights, responsibilities and values, referencing ILO No.169, Te Tiriti o Waitangi and the UN Declaration on the Rights of Indigenous Peoples, and states that those rights “shall not be infringed upon without free, prior and informed consent”. A rewritten 11.6.5 requires that any use of Indigenous traditional knowledge occur only with FPIC and “subject to equitable benefit sharing and agreed arrangements regarding confidentiality and attribution”, and adds a note defining care for Country.

Who this actually lands on

Yesterday we suggested printers should look for anything changing what a certificate holder must evidence. Having read it, the honest answer is that these obligations sit with forest managers. Every new clause begins “the forest manager shall”. There is nothing here that adds a direct audit requirement to a printer or converter holding chain-of-custody certification.

That is worth saying plainly rather than manufacturing relevance. But it is not the same as saying it does not matter, for a reason the standard states about itself: it “provides the first link in the ‘Chain of custody’ supply chain”. What a certified forest has to prove is what the mark on your stock ultimately means. If the upstream test becomes a documented, dated, deforestation-free test, then the claim a printer passes to a client gets stronger, and the supply of fibre that can meet it may get tighter. Our view, and it is a view: the commercial question for this industry is not compliance cost, it is whether certified Australian fibre becomes more valuable because it can satisfy a European buyer’s due diligence, or scarcer because some growers decide the new conditions are not worth meeting.

Comment closes 7 August 2026. The submission form goes to standards@responsiblewood.org.au, and the draft asks that clause numbers be placed beside each comment.