Background Information about the Interpretation(INT)
One of FSC´s strategic goals is the improved access for smallholders, usually being farmers without significant economic resources, to the FSC system. In many regions of the world where smallholders are present, burning of sites to prepare for agriculture and forestry activities is common and traditional practice, due to the reduced availability of economic and human resources for the smallholders. It is without doubts that burning activities have negative ecological impacts on vegetation, species and sites in regions where natural fires do not belong to the ecosystem. However, different burning techniques are used which have more or less negative ecological impacts. E.g. complete burning of sites compared to controlled burning by organizing the material in piles or stripes before burning. In many countries, the responsible Ministries have developed guidelines on burning activities adapted to the situation of the individual country (e.g. the MARD Vietnam permits controlled burning in afforestation activities in production forest but completely prohibits burning on special-use and protection forest land - Circular No. 1515/VBHN-BNNPTNT "REGULATIONS ON FORESTRY MEASURES" dated November 25, 2022).
Looking at smallholders who do not have similar access to funds, human resources and knowledge as other professional forest operators, a complete prohibition of burning activities for site preparation (once per rotation period) could lead to the exclusion of many smallholders from participation in a FSC certified group scheme.
Looking at the situation specifically for Vietnam, burning activities per se are not banned, neither by the NFSS for Vietnam, nor by the SEA Smallholder Standard which is also applicable in Vietnam (see requirements 10.5.1 und 10.11.3 cited above). After recent ASI compliance assessments related to burning activities, it turned out that there is no clarification on the topic of burning for site preparation for smallholder schemes. Whereas complete burning of sites should be prohibited, controlled burning for site preparation once per rotation cycle, following the guidelines of the local Ministries, could be an adequate compromise for smallholder groups.