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“Continuous Improvement” in Illegal Practices in the Peruvian Forest Sector

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This report by the Center for International Environmental Law (CIEL) analyzes the systemic use of official documentation to launder illegal timber from the Peruvian Amazon for international export. By reviewing 865 Visual Inspection Certificates and 2,364 Forest Transport Permits (GTFs) from 2015, CIEL identifies patterns where exporters exploit gaps in supervision and transparency tools to bypass legality controls, particularly when exporting to markets with weak due diligence requirements.

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  • A significant portion of Peruvian timber exports are high-risk or lack verifiable legality. Of the 2,364 GTFs analyzed, only 33% of the Forest Management Plans (FMPs) were supervised by OSINFOR, while 48% were not supervised and 18% failed to indicate the harvest year, making it impossible to determine the legal status of the timber.
  • Exporters appear to strategically target markets based on the legal risk of the timber. High-risk timber (on OSINFOR's "red list") is disproportionately exported to countries without strict illegal logging prohibitions, such as Mexico (75%) and China (71%), while exports to the United States (72%) and France (91%) are more likely to be from the "green list."
  • Six companies accounted for over 50% of the GTFs used for worldwide exports in the dataset. These companies are Maderera Bozovich SAC, Inversiones La Oroza SAC, Peruvian Flooring SAC, Inversiones Técnicas Maderables SAC, Consorcio Maderero SAC, and Maderera Rio Acre SAC.
  • There is a shifting pattern in harvest modalities used to sell illegal timber, with a significant increase in the use of Forest Permits in Indigenous Communities and Local Forests since 2013. In the 2015 dataset, Forest Permits in Indigenous Communities represented 38.03% of GTFs, and Local Forests represented 15.23%.
  • Local Forests are identified as a high-risk modality frequently used for fraud. In the 2015 export data from Callao, 96% of supervised FMPs from Local Forests were on the "red list" due to legal violations.
  • Indigenous communities are often negatively impacted by the laundering of illegal timber. Third parties may use GTFs from these communities to harvest timber from unauthorized areas, leaving the communities responsible for fines and sanctions they cannot afford to pay.
  • The report identifies five specific patterns of "continuous improvement" used by companies to evade transparency: (i) using documentation from harvest modalities not subject to OSINFOR oversight, (ii) using permits on private land not submitted to OSINFOR by the granting authority, (iii) using unsupervised FMPs from high-risk titles, (iv) using GTFs missing the harvest season (zafra), and (v) exporting timber despite FMPs being on the "red list."

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APA
Gómez, R. N., & Sky, M. B. (2017). “Continuous Improvement” in Illegal Practices in the Peruvian Forest Sector. Center for International Environmental Law. https://www.ciel.org/wp-content/uploads/2017/11/EnglishVersionFinal.pdf
Chicago
Gómez, Rolando Navarro, and Melissa Blue Sky. “Continuous Improvement” in Illegal Practices in the Peruvian Forest Sector. Center for International Environmental Law, 2017. https://www.ciel.org/wp-content/uploads/2017/11/EnglishVersionFinal.pdf.
Wikipedia
{{cite report |last1=Gómez |first1=Rolando Navarro |last2=Sky |first2=Melissa Blue |title=“Continuous Improvement” in Illegal Practices in the Peruvian Forest Sector |publisher=Center for International Environmental Law |date=2017 |url=https://www.ciel.org/wp-content/uploads/2017/11/EnglishVersionFinal.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}
BibTeX
@techreport{gmez2017continuous, author = {Gómez, Rolando Navarro and Sky, Melissa Blue}, title = {{“Continuous Improvement” in Illegal Practices in the Peruvian Forest Sector}}, institution = {Center for International Environmental Law}, year = {2017}, url = {https://www.ciel.org/wp-content/uploads/2017/11/EnglishVersionFinal.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }

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