Concerns Regarding ISO’s Proposed Collaboration with the GHG Protocol and Support for ISO Standards to Remain as Independent Initiatives

The International Council of Forest and Paper Associations (ICFPA) serves as a forum of
global dialogue, coordination and co-operation. Currently, the ICFPA represents 16 pulp,
paper, wood and fibre-based associations that encompass 27 countries, including many
of the top pulp, paper and wood producers around the world. ICFPA and its members
participate in various ISO committees and in the development of ISO standards. We wish
to share our concerns regarding the International Organization for Standardization’s (ISO)
proposed collaboration with the Greenhouse Gas Protocol and express our strong support
for ISO standards to remain as independent initiatives.

The international business community is increasingly enthusiastic about ISO’s leadership
in greenhouse gas (GHG) accounting and net-zero standards, particularly following the
publication of the ISO 13391 Series, Series on Wood and Wood-Based Products –
Greenhouse Gas Dynamics. This demonstrates strong demand for ISO’s role as a credible,
science-based, and independent non-governmental international standardizing body.
However, any partnership must uphold the integrity of ISO’s well-established development
process, which is the foundation of its global credibility.

ISO’s process—anchored in its Directives and built through broad consultation and
consensus with national standard bodies—has ensured that its standards are trusted
globally by industry, governments, and civil society. ISO’s Directives require ISO to confirm
that there are no contradictions created with published ISO standards by any such
standardization work, particularly on land sector and removals guidance matters.
This robust governance structure must not be compromised by aligning with external
organizations that do not adhere to the same principles. In particular, ISO must not
abandon or dilute its process by lending its brand to an organization such as the GHG
Protocol, which has yet to fully adopt or demonstrate commitment to ISO’s governance
practices.

Of particular concern is the possibility that existing ISO standards—developed through
rigorous consultation—could be superseded or prematurely eliminated in favor of GHG
Protocol products. This would not only violate the ISO Directives but also create confusion
about what qualifies for ISO endorsement, undermining confidence in ISO’s
independence and consistency. Any retirement of existing standards must follow formal
ISO procedures, including technical committee approval.

The proposed co-branding of GHG Protocol’s LandSector and Removals Guidance (LSRG)
raises significant governance and scientific integrity concerns. The LSRG has been
delayed multiple times since its development process started in 2020 due to persistent
and well-documented criticisms of both its technical content and the opaque nature of its
development. These issues have been raised repeatedly with the GHG Protocol, including
in a public letter by leading scientists and through working group feedback. Despite this,
concerns remain unresolved.

From a governance standpoint, advancing this collaboration without proper safeguards or
stakeholder input is premature and risky. No apparent analysis has been conducted to
assess the reputational, financial, or operational impacts for ISO. There is a real danger
that such a partnership could erode ISO’s reputation, especially in the climate change and
land-use sectors where the trustworthiness of standards is critical.

ISO should therefore be prepared to walk away from negotiations with the GHG Protocol
unless its process and governance principles are fully respected and adopted as a
condition of any partnership. The organization can take confidence in the fact that many
governments and institutions already prefer standards developed through national
standard bodies affiliated with ISO, which gives ISO a unique and influential position in
shaping credible global climate guidance.

In summary, while collaboration can be constructive, it must not come at the expense of
ISO’s independence, credibility, and long-standing governance framework. ICFPA strongly
supports the continued development and finalization of climate-related ISO standards
and urges ISO to reconsider any co-branding or standard development agreements with
the GHG Protocol that may compromise scientific integrity or sidestep ISO’s trusted
process. It is critical that ISO standards remain as independent initiatives.

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