POLICY BRIEF
LEGAL TIMBER FROM INTENSIVE PLANTATION AREAS OF HOUSEHOLDS IN VIETNAM: STATUS AND POLICY RECOMMENDATIONS[1]
Vietnam Forest Owners Association
(This report was produced with the financial support of the European Union. Its contents are sole responsibility of VIFORA and do not necessarily reflect the views of the European Union) |
1. Introduction
According to the Vietnam Administration of Forestry (VNFOREST), in the period 2011-2020 – the total timber production of our country is 199,768,500m3. The largest exploitation is from natural forests and comprises 418,500m3; exploitation from intensive plantation areas is 127,100,000m3, and the figure for rubber and scattered trees is 71,250,000 m3. The exploitation from intensive plantation areas averages about 63.5 % of the total volume. The total intensive plantation areas in 2020 was 4,398,030 ha of which households and individuals managed 1,874,659 ha (42.6 % of the total intensive plantation area).
Legal timber is wood products that is exploited and produced in accordance with Vietnam’s laws and regulations (The Voluntary Partnership Agreement on Forest Law Enforcement, Government and Trade – VPA/FLEGT) establishes a timber legality assurance system that ensures that wood products conform to Vietnam’s laws. Households are required to adhere to the system’s seven basic principles that comprise legal timber.
In 2015, the Network of Vietnamese Non-Governmental Organizations on Forest Law Enforcement, Governance and Trade (VNGO-FLEGT) conducted a study to assess the ability of households in Nghe An province to meet legal timber standards.
The study found 80% of the group of timber planting, trading, harvesting and transporting households met the regulations on forest use rights. In contrast only 4% of households met the regulations on registration of exploitation, expected forest products and lists of forest products. 8% and 14% of afforestation households kept records of forest products in 2013 and 2014 respectively. In terms of process of logging and timber transporting, there is few households paying license tax and income tax, at the rate of 12% and 4% respectively. Regarding the group of timber processing households, the percentage of households keeping logging records, and timber trading and transportation are 16.7% and 29.2% respectively.
In 2018, the Vietnam Forest Owners Association (VIFORA) conducted a training needs assessment on requirements for legal timber for small-sized forest owners. A survey of 274 households in three provinces of Quang Ninh, Phu Tho and Quang Tri revealed five key points:
(i) 82% of surveyed households had valid Certificates of land use rights;
(ii) 14% of surveyed households had Certificates of forest use rights;
(iii) 60% of surveyed households sold standing trees;
(iv) 73% of surveyed households did not know the regulations on logging;
(v) When selling timber to brokers, 95% of sellers did not require timber trading; 82% of sellers did not keep records of timber sales; and 96% of sellers did not know VAT.
To systematically evaluate and analyze the status of intensive plantation areas and the requirements to ensure legal timber of households and individuals in our country, the research team directly interviewed forest managers in three provinces, namely Tuyen Quang, Quang Tri and Binh Dinh. These interviews were based on a participatory approach and the usage of tools.
Where intensive plantation areas were owned by households, there were four criteria:
1)A legal owner;
2)Sale or purchase contracts and a list of forest products when selling timber or forest;
3)A record of forests and forest products; and
4)Compliance with regulations on social and environmental management, and tax payment obligations.
Where intensive plantation areas were owned by the State, there were two criteria:
1)Compliance with regulations on forest exploitation and use, including rare and precious species as stipulated in the Law on Forestry; and
2)Reports and approval of state administrative agencies when logging.
2. Main findings
2.1. Current status of intensive plantation areas of households
According to VNFOREST, Vietnam had 14,677,215 ha of forest in 2020. This was comprised 7,818,480 ha of production forest, 4,398,030 ha of plantation forest (includes 91,805 ha of special-use forests); 614,985 ha of protection forest areas; and 3,691,240 ha of plantation forest (wood-production areas were 3,392,731 ha).
Approximately 1.1 million households manage 1,874,659 ha of plantation forest nationally giving an average area of plantation forest per household of 1.7 ha. The average area of plantation forest per household in Binh Dinh province is 1.71 ha, compared to 2.9 ha and 4.59 ha in Quang Tri and Tuyen Quang provinces respectively. The main plant species is an acacia hybrid yielding approximately 100m3/ha/5 years, 22m3/ha annually.
Current harvest practice in acacia small tree plantations is that only timber with a small end diameter >= 12cm and 2m long is classified for sale as ‘logs’. Timber that does not meet this criteria is classified ‘small wood’ and is sold to export wood chip factories. The survey found 10 – 15% of timber harvested from small acacia wood forests had a small end diameter >12 cm and thus could be sold as logs. Of the remainder, 55-60% had a diameter of 8-12cm and 25-35% had a diameter <8cm.
2.2. Compliance with requirements of legal timber
The study interviewed forest managers across three provinces in regard to their estimate of compliance with the requirements of legal timber. The results of these interviews are shown in Table 1:
Table 1: Compliance with requirements of legal timber in 3 surveyed provinces in 2020
|
Compliance requirement |
Unit |
Tuyen Quang |
Quang Tri |
Binh Dinh |
1 |
Estimation of the percentage of exploited timber that meets the requirements |
% |
|
|
|
1.1 |
Logging output from wood-plantation forests |
% |
|
|
|
a |
Forest land which has a legal owner are not in conflicts or disputes |
% |
90 |
50 |
90 |
b |
Compliance with regulations on wood-plantation forest that is invested and protected by the State |
% |
90 |
30 |
90 |
c |
Statement of forests invested, contracted, traded and protected by the State |
% |
90 |
100 |
100 |
d |
Having sale or purchase contracts and lists of forest products |
% |
90 |
10 |
90 |
e |
Having a record of forests and forest products at home |
% |
90 |
5 |
30 |
f |
Social, environmental and tax compliance |
% |
90 |
50 |
90 |
1.2. |
The responses of forest owners |
% |
|
|
|
a |
Households, individuals and communities |
% |
90 |
40 |
30 |
b |
Forestry companies |
% |
90 |
30 |
100 |
c |
Other forest owners |
% |
90 |
30 |
100 |
(Source: Survey of research team in June 2021)
Comments:
Intensive plantation areas under the ownership of households
a.Forest land which has a legal owner are not in conflicts or disputes
The land use right certificates of production forest areas of many households have not been issued in accordance with regulations. In Quang Tri province, only about 50% of households and individuals have been granted land use right certificates. Some have land-allocation decisions but documents are not related to land plots meaning that it is difficult to issue the certificate. Most of the remaining area is reclaimed and encroached land, however, the locality could not determine the time of land use. This means land use right certificates cannot be issued in accordance with regulations.
The percentage of households who are legal forest owners is 80% in Quang Tri, and 90% in Tuyen Quang and Binh Dinh province.
b.Having sale or purchase contracts and a list of forest products
Druring the exploiting cycle, households typically make clear forest purchase or sale contracts, then contact the People’s Committees of communes and local rangers to inquire procedures related to the origin of plantation forests. The list of forest products is usually made by the purchasing units and reported to the People’s Committees of communes and local rangers for inspection and certification. However, forest owners now are increasingly selling their forests to a third party and making the list of forest products at that time. Subsequently, the percentage of forest products varies from 10% to 90%, depending largely on the form of the sale and purchase contract
c.Having a record of forest and forest land at home
The type of records of forest and forest products kept by households include land use right certificates, forest purchase or sale contracts, papers and invoices related to the purchase of afforestation seedlings. However, the number of families that make and keep records of forests and forest products at home varies widely between provinces, with interviewed percentages complying of from 5%, 30% and 90% according to province.
d. Social, environmental and tax compliance
The majority of households comply with the regulations on forest fire protection and prevention, environmental protection, and fulfill tax obligations. When exploiting forests, some additional measures such as maintenance and repair of transportation are also performed. When it comes to forestry production, households informed by competent authorities are encouraged to develop plans related to forest fire protection and prevention on their forest areas in accordance with regulations. However, households advises that geographic fragmentation, limited knowledge and conditions related to documents make it difficult to fully implement. The percentage of households complying with these requirements ranges from 50% to 90% according to province.
Intensive plantation areas under the ownership of the State
a.Compliance with regulations on exploitation and the usage of wood-plantation forest
Although households carry out the procedures of main exploitation, salvage exploitation and full exploitation, the procedures are often overlooked due to its complication. The percentage of households complying with this criterion varies from 30% to 90%.
b.Statement of forest invested, contracted, traded and protected by the State
The majority of households have fully completed the declaration procedures and asked for approval from the investors. The rate of implementation by households is between 90% and 100%.
The level of satisfaction of all criteria
The percentage of households that complied with all the criteria was 30%, 40% and 90% by province, depending on the ability to develop and implement sustainable forest management options and issue certificates.
2.3 Problems, gaps and reasons
2.3.1 Problems and gaps
Results of online survey:
Figure 1: Opinions on ensuring legal timber
(Source: Online survey in June 2021)
Comments:
2.3.2 Reasons
a. Compliance with legal timber requirements related to land use rights
The issue of land use right certificates in accordance with regulations relies on comprehensive statistics and data of the timber industry generated synchronously and at a large scale. Implementation of the statistical review has been slow due to limited finding. Additionally, there are still many shortcomings in the work of statistics and review.
b. The level of satisfaction of all legal timber criteria of family forest owners is still low
Main reasons:
1) Many households do not been granted a land use right certificate. This limits their land use rights and obligations.
2) Access to legal documents is limited by a range of factors that range from legitimate to perceptual.
3) Households perceive some provisions of the law as inconsistent.
4) The number of authorities involved adds complexity to processes and procedures..
3. Policy recommendations
3.1. Develop new policies and revise existing policies to ensure households and individuals have access to legal timber
- Complete the policies of land allocation and forest allocation; promote the granting of land use right certificates; assist people in measuring areas and forming a database of production forests.
- Develop forestry extension policies those that support people in building legal timber models, training courses on expanding models and propagating information on legal timber.
- Policies to support households with needs, preferential credit and insurance of large timber plantation.
- Policies to support funding for forest certification to a higher level than in Decision No. 38/2016/QĐ-TTg of the Prime Minister.
3.2. Amendment to Circular No. 27/2018/BNNPTNT dated November 16, 2018 of the Ministry of Agriculture and Rural Development on regulating the management and traceability of forest products
- Regulations on making lists of forest products made by households are difficult to implement and need to be amended and supplemented to facilitate the implementation process.
- Supplement regulations on participation in monitoring and certifying the amount of timber exploited by households when selling forests and assigning them to the purchasers to issue invoices and log records for transportation.
- Supplement regulations on weighing the amount of wood including wood with a diameter of over 6 centimeters.
- Supplement regulations on responsibility for making wood records and instructions for keeping wood records at home.
- Research to amend the regulations on small end specification of the log accordingly.
3.3. Implement measures to enforce the policy of promoting legal timber
- Guide to make records and lists of forest products when selling exploited timber;
- Timber processing and transporting procedures;
- Instructions on how to measure and determine volume.
REFERENCES
1.Bộ NN&PTNT (2019), QĐ số 1558/QĐ-BNN-TCLN ngày 13/04/2021 công bố hiện trạng rừng trên toàn quốc năm 2020.
2.Bộ NN&PTNT (2020), Chiến lược phát triển lâm nghiệp Việt Nam giai đoạn 2021-2030, tầm nhìn đến năm 2050
3.Tổng cục Lâm nghiệp (2020), Báo cáo tại hội nghị tổng kết công tác chỉ đạo, điều hành năm 2020 và triển khai nhiệm vụ trọng tâm năm 2021 của TCLN,6/1/2021.
4.Tổng cục lâm nghiệp (2020), Lâm nghiệp Việt Nam, 75 năm hình thành và phát triển (1945-2020).
5.Mạng lưới các tổ chức Phi chính phủ Việt Nam về Thực thi Lâm luật, Quản trị rừng và Thương mại Lâm sản (VNGO-FLEGT) (2015) , Nghiên cứu đánh giá khả năng đáp ứng tiêu chuẩn gỗ hợp pháp cấp hộ gia đình tại tỉnh Nghệ An.
6.Nguyễn Thanh Hiền, Vũ Thị Bích Hợp, Vũ Thế Thường (Trung tâm Phát triển Nông thôn Bền Vững SRD) (2020), Hiện trang về hộ trồng rừng và doanh nghiệp siêu nhỏ và nhỏ sản xuất gỗ trước khi thực thi VPA/FLEGT
--------------------------------------
LEGAL TIMBER FROM INTENSIVE PLANTATION AREAS OF HOUSEHOLDS IN VIETNAM: STATUS AND POLICY RECOMMENDATIONS[1]
Vietnam Forest Owners Association
1. Introduction
According to the Vietnam Administration of Forestry (VNFOREST), in the period 2011-2020 – the total timber production of our country is 199,768,500m3. The largest exploitation is from natural forests and comprises 418,500m3; exploitation from intensive plantation areas is 127,100,000m3, and the figure for rubber and scattered trees is 71,250,000 m3. The exploitation from intensive plantation areas averages about 63.5 % of the total volume. The total intensive plantation areas in 2020 was 4,398,030 ha of which households and individuals managed 1,874,659 ha (42.6 % of the total intensive plantation area).
Legal timber is wood products that is exploited and produced in accordance with Vietnam’s laws and regulations (The Voluntary Partnership Agreement on Forest Law Enforcement, Government and Trade – VPA/FLEGT) establishes a timber legality assurance system that ensures that wood products conform to Vietnam’s laws. Households are required to adhere to the system’s seven basic principles that comprise legal timber.
In 2015, the Network of Vietnamese Non-Governmental Organizations on Forest Law Enforcement, Governance and Trade (VNGO-FLEGT) conducted a study to assess the ability of households in Nghe An province to meet legal timber standards.
The study found 80% of the group of timber planting, trading, harvesting and transporting households met the regulations on forest use rights. In contrast only 4% of households met the regulations on registration of exploitation, expected forest products and lists of forest products. 8% and 14% of afforestation households kept records of forest products in 2013 and 2014 respectively. In terms of process of logging and timber transporting, there is few households paying license tax and income tax, at the rate of 12% and 4% respectively. Regarding the group of timber processing households, the percentage of households keeping logging records, and timber trading and transportation are 16.7% and 29.2% respectively.
In 2018, the Vietnam Forest Owners Association (VIFORA) conducted a training needs assessment on requirements for legal timber for small-sized forest owners. A survey of 274 households in three provinces of Quang Ninh, Phu Tho and Quang Tri revealed five key points:
(i) 82% of surveyed households had valid Certificates of land use rights;
(ii) 14% of surveyed households had Certificates of forest use rights;
(iii) 60% of surveyed households sold standing trees;
(iv) 73% of surveyed households did not know the regulations on logging;
(v) When selling timber to brokers, 95% of sellers did not require timber trading; 82% of sellers did not keep records of timber sales; and 96% of sellers did not know VAT.
To systematically evaluate and analyze the status of intensive plantation areas and the requirements to ensure legal timber of households and individuals in our country, the research team directly interviewed forest managers in three provinces, namely Tuyen Quang, Quang Tri and Binh Dinh. These interviews were based on a participatory approach and the usage of tools.
Where intensive plantation areas were owned by households, there were four criteria:
1) A legal owner;
2) Sale or purchase contracts and a list of forest products when selling timber or forest;
3) A record of forests and forest products; and
4) Compliance with regulations on social and environmental management, and tax payment obligations.
Where intensive plantation areas were owned by the State, there were two criteria:
1) Compliance with regulations on forest exploitation and use, including rare and precious species as stipulated in the Law on Forestry; and
2) Reports and approval of state administrative agencies when logging.
2. Main findings
2.1. Current status of intensive plantation areas of households
According to VNFOREST, Vietnam had 14,677,215 ha of forest in 2020. This was comprised 7,818,480 ha of production forest, 4,398,030 ha of plantation forest (includes 91,805 ha of special-use forests); 614,985 ha of protection forest areas; and 3,691,240 ha of plantation forest (wood-production areas were 3,392,731 ha).
Approximately 1.1 million households manage 1,874,659 ha of plantation forest nationally giving an average area of plantation forest per household of 1.7 ha. The average area of plantation forest per household in Binh Dinh province is 1.71 ha, compared to 2.9 ha and 4.59 ha in Quang Tri and Tuyen Quang provinces respectively. The main plant species is an acacia hybrid yielding approximately 100m3/ha/5 years, 22m3/ha annually.
Current harvest practice in acacia small tree plantations is that only timber with a small end diameter >= 12cm and 2m long is classified for sale as ‘logs’. Timber that does not meet this criteria is classified ‘small wood’ and is sold to export wood chip factories. The survey found 10 – 15% of timber harvested from small acacia wood forests had a small end diameter >12 cm and thus could be sold as logs. Of the remainder, 55-60% had a diameter of 8-12cm and 25-35% had a diameter <8cm.
2.2. Compliance with requirements of legal timber
The study interviewed forest managers across three provinces in regard to their estimate of compliance with the requirements of legal timber. The results of these interviews are shown in Table 1:
Table 1: Compliance with requirements of legal timber in 3 surveyed provinces in 2020
|
Compliance requirement |
Unit |
Tuyen Quang |
Quang Tri |
Binh Dinh |
1 |
Estimation of the percentage of exploited timber that meets the requirements |
% |
|
|
|
1.1 |
Logging output from wood-plantation forests |
% |
|
|
|
a |
Forest land which has a legal owner are not in conflicts or disputes |
% |
90 |
50 |
90 |
b |
Compliance with regulations on wood-plantation forest that is invested and protected by the State |
% |
90 |
30 |
90 |
c |
Statement of forests invested, contracted, traded and protected by the State |
% |
90 |
100 |
100 |
d |
Having sale or purchase contracts and lists of forest products |
% |
90 |
10 |
90 |
e |
Having a record of forests and forest products at home |
% |
90 |
5 |
30 |
f |
Social, environmental and tax compliance |
% |
90 |
50 |
90 |
1.2. |
The responses of forest owners |
% |
|
|
|
a |
Households, individuals and communities |
% |
90 |
40 |
30 |
b |
Forestry companies |
% |
90 |
30 |
100 |
c |
Other forest owners |
% |
90 |
30 |
100 |
(Source: Survey of research team in June 2021)
Comments:
Intensive plantation areas under the ownership of households
a. Forest land which has a legal owner are not in conflicts or disputes
The land use right certificates of production forest areas of many households have not been issued in accordance with regulations. In Quang Tri province, only about 50% of households and individuals have been granted land use right certificates. Some have land-allocation decisions but documents are not related to land plots meaning that it is difficult to issue the certificate. Most of the remaining area is reclaimed and encroached land, however, the locality could not determine the time of land use. This means land use right certificates cannot be issued in accordance with regulations.
The percentage of households who are legal forest owners is 80% in Quang Tri, and 90% in Tuyen Quang and Binh Dinh province.
b. Having sale or purchase contracts and a list of forest products
Druring the exploiting cycle, households typically make clear forest purchase or sale contracts, then contact the People’s Committees of communes and local rangers to inquire procedures related to the origin of plantation forests. The list of forest products is usually made by the purchasing units and reported to the People’s Committees of communes and local rangers for inspection and certification. However, forest owners now are increasingly selling their forests to a third party and making the list of forest products at that time. Subsequently, the percentage of forest products varies from 10% to 90%, depending largely on the form of the sale and purchase contract
c. Having a record of forest and forest land at home
The type of records of forest and forest products kept by households include land use right certificates, forest purchase or sale contracts, papers and invoices related to the purchase of afforestation seedlings. However, the number of families that make and keep records of forests and forest products at home varies widely between provinces, with interviewed percentages complying of from 5%, 30% and 90% according to province.
d. Social, environmental and tax compliance
The majority of households comply with the regulations on forest fire protection and prevention, environmental protection, and fulfill tax obligations. When exploiting forests, some additional measures such as maintenance and repair of transportation are also performed. When it comes to forestry production, households informed by competent authorities are encouraged to develop plans related to forest fire protection and prevention on their forest areas in accordance with regulations. However, households advises that geographic fragmentation, limited knowledge and conditions related to documents make it difficult to fully implement. The percentage of households complying with these requirements ranges from 50% to 90% according to province.
Intensive plantation areas under the ownership of the State
a. Compliance with regulations on exploitation and the usage of wood-plantation forest
Although households carry out the procedures of main exploitation, salvage exploitation and full exploitation, the procedures are often overlooked due to its complication. The percentage of households complying with this criterion varies from 30% to 90%.
b. Statement of forest invested, contracted, traded and protected by the State
The majority of households have fully completed the declaration procedures and asked for approval from the investors. The rate of implementation by households is between 90% and 100%.
The level of satisfaction of all criteria
The percentage of households that complied with all the criteria was 30%, 40% and 90% by province, depending on the ability to develop and implement sustainable forest management options and issue certificates.
2.3 Problems, gaps and reasons
2.3.1 Problems and gaps
Results of online survey:
Figure 1: Opinions on ensuring legal timber
(Source: Online survey in June 2021)
Comments:
· 93.3% of the survey respondents said that the criterion of forest land has a legal owner and there is not conflict or dispute.
· 56.7% of the survey respondents said that the criterion of compliance with regulations on exploitations and use of plantation forest is problematic.
· 43.3% of the survey respondents said that the criterion of social, environmental and tax compliance is problematic.
· 43.3% of the survey respondents said that the criterion of documentation related to forest and forest products of households is problematic.
· 43.3% of the survey respondents said that the criterion of sale contracts and lists of forest products is problematic.
· 13.3 % of the survey respondents said that there is a problem with the declaration of state-invested forests.
2.3.2 Reasons
a. Compliance with legal timber requirements related to land use rights
The issue of land use right certificates in accordance with regulations relies on comprehensive statistics and data of the timber industry generated synchronously and at a large scale. Implementation of the statistical review has been slow due to limited finding. Additionally, there are still many shortcomings in the work of statistics and review.
b. The level of satisfaction of all legal timber criteria of family forest owners is still low
Main reasons:
1) Many households do not been granted a land use right certificate. This limits their land use rights and obligations.
2) Access to legal documents is limited by a range of factors that range from legitimate to perceptual.
3) Households perceive some provisions of the law as inconsistent.
4) The number of authorities involved adds complexity to processes and procedures..
3. Policy recommendations
3.1. Develop new policies and revise existing policies to ensure households and individuals have access to legal timber
- Complete the policies of land allocation and forest allocation; promote the granting of land use right certificates; assist people in measuring areas and forming a database of production forests.
- Develop forestry extension policies those that support people in building legal timber models, training courses on expanding models and propagating information on legal timber.
- Policies to support households with needs, preferential credit and insurance of large timber plantation.
- Policies to support funding for forest certification to a higher level than in Decision No. 38/2016/QĐ-TTg of the Prime Minister.
3.2. Amendment to Circular No. 27/2018/BNNPTNT dated November 16, 2018 of the Ministry of Agriculture and Rural Development on regulating the management and traceability of forest products
- Regulations on making lists of forest products made by households are difficult to implement and need to be amended and supplemented to facilitate the implementation process.
- Supplement regulations on participation in monitoring and certifying the amount of timber exploited by households when selling forests and assigning them to the purchasers to issue invoices and log records for transportation.
- Supplement regulations on weighing the amount of wood including wood with a diameter of over 6 centimeters.
- Supplement regulations on responsibility for making wood records and instructions for keeping wood records at home.
- Research to amend the regulations on small end specification of the log accordingly.
3.3. Implement measures to enforce the policy of promoting legal timber
- Guide to make records and lists of forest products when selling exploited timber;
- Timber processing and transporting procedures;
- Instructions on how to measure and determine volume.
REFERENCES
1. Bộ NN&PTNT (2019), QĐ số 1558/QĐ-BNN-TCLN ngày 13/04/2021 công bố hiện trạng rừng trên toàn quốc năm 2020.
2. Bộ NN&PTNT (2020), Chiến lược phát triển lâm nghiệp Việt Nam giai đoạn 2021-2030, tầm nhìn đến năm 2050
3. Tổng cục Lâm nghiệp (2020), Báo cáo tại hội nghị tổng kết công tác chỉ đạo, điều hành năm 2020 và triển khai nhiệm vụ trọng tâm năm 2021 của TCLN,6/1/2021.
4. Tổng cục lâm nghiệp (2020), Lâm nghiệp Việt Nam, 75 năm hình thành và phát triển (1945-2020).
5. Mạng lưới các tổ chức Phi chính phủ Việt Nam về Thực thi Lâm luật, Quản trị rừng và Thương mại Lâm sản (VNGO-FLEGT) (2015) , Nghiên cứu đánh giá khả năng đáp ứng tiêu chuẩn gỗ hợp pháp cấp hộ gia đình tại tỉnh Nghệ An.
6. Nguyễn Thanh Hiền, Vũ Thị Bích Hợp, Vũ Thế Thường (Trung tâm Phát triển Nông thôn Bền Vững SRD) (2020), Hiện trang về hộ trồng rừng và doanh nghiệp siêu nhỏ và nhỏ sản xuất gỗ trước khi thực thi VPA/FLEGT