Over the past few years, the SUMAL system has become one of the most important tools through which Romania has managed to reduce vulnerabilities related to illegal logging and increase transparency in the forestry sector. In this context, WWF-Romania welcomes the launch of the process to review the regulatory framework governing timber traceability and the future development of the system.
Greater transparency, stronger control capacity, and the digital monitoring of timber traceability have helped transform SUMAL into a reference model at both European and international levels. At the same time, experience gained in the field shows that risk factors and methods of operation are constantly evolving, making it necessary to continuously adapt the system, close remaining loopholes that allow non-compliance to occur, and place a stronger focus on prevention.
In this context, we believe that the modernization of SUMAL should continue in line with:
- the provisions of the new Forest Code and the objectives of the National Forest Strategy 2030;
- the requirements of the new EU Deforestation Regulation (EUDR) (Regulation (EU) 2023/1115).
WWF-Romania has submitted a series of proposals and recommendations to the Ministry of Environment, Waters and Forests regarding improvements to SUMAL 2.0 and the development of the future SUMAL 3.0, including:
- Increasing the Efficiency of Field Controls
Introducing rapid methods for verifying the volume of transported timber (expedited volume assessment), enabling Forest Guards to inspect a greater number of timber transports in the field and prioritize cases with a high risk of overloading and misreporting declared timber quantities. - Reducing Unnecessary Administrative Burdens and Reflecting Actual Harvested Volumes
Operationalizing SUMAL for the “pilot areas” provided for in the new Forest Code, where timber volume assessments may be carried out after harvesting, acknowledging the estimated nature of standing timber volume calculations. - Advanced Digitalization of Transport Traceability
Developing the concept of a “digital fingerprint” for timber transports, including electronic cargo seals and automated digital measurement systems. - Preventive and Automated Control Mechanisms
Automatically generating alerts for non-compliant timber transports and integrating them into an objective and automated mechanism for prioritizing inspections. - Automated Satellite-Based Alerts to Support Risk-Based Controls
Publishing forest canopy changes identified through remote sensing only after prior verification by forest managers and local authorities, ensuring that public alerts effectively support risk-based inspection prioritization and avoid flagging legal forestry operations or damage caused by natural disturbances as potential non-compliance. - Preventing Fraud and Closing System Loopholes
Eliminating opportunities for fraud through the use of offline applications or fictitious timber origin documents. - Supporting Small Forest Owners
Developing the SUMAL Owner module to facilitate the legal and simplified use of timber for personal consumption, including timber originating from forest vegetation located outside the National Forest Fund. - Highlighting Valuable Biodiversity Features
Introducing procedures within SUMAL for the identification and monitoring of remarkable trees and aging islands. - Interconnecting SUMAL with European EUDR Systems
Ensuring interoperability with the information system developed by the European Commission for implementing due diligence and traceability obligations at the European level.
We believe that the continued development of SUMAL is essential for strengthening transparency, improving the effectiveness of controls, and unlocking the system’s potential to become a modern tool for compliance with new European requirements on traceability, due diligence, and the prevention of illegal logging.