Pages tagged "paper"

Toba Pulp Lestari: In depth on one of the worst actors in pulp and paper


TobaPulp.pngIndonesian pulp and paper giant Toba Pulp Lestari has been operating recklessly in North Sumatra for years. The company's mill has been poisoning communities and disrupting life and livelihoods for the local people who call this area home. The mill, and it’s operators, are responsible for horrific land conflicts between the company and villagers who hold traditional land rights to the company’s concessions.

These communities, whose land is protected by customary rights under Indonesian law, rely on these forests for their life and livelihoods. As reported by RAN’s on-the-ground partner, Kelompok Studi dan Pengembangan Prakarsa Masyarakat, well over 17,000 hectares of natural forest have been destroyed, impacting or displacing over 13,000 Indigenous people.

These communities are fighting back, and at least 59 activists have been arrested for resisting Toba Pulp Lestari’s continued expansion and destruction. In the past few years, land conflict has only escalated between villagers and Toba Pulp Lestari employees over the forest area. Meetings with government representatives and Toba Pulp Lestari management have brought no results, and local villagers have resorted to protests and blockades of company operations in order to protect the forests.

The behavior of Toba Pulp Lestari employees shows clear disregard for the livelihoods of local people. In February 2013, local farmers from Pandumaan and Sipituhuta Villages caught Toba Pulp Lestari employees entering their forest areas and cutting down frankincense trees. Instead of apprehending those causing the destruction, resulting clashes between farmers and the employees led to the arrests of 31 farmers.

The harvest of frankincense is essential to the local economy. These communities, who have farmed this land for generations, extract the frankincense without destroying the trees in order to maintain the health of the forest and keep this vital source of income intact for future generations. When the forests are wiped out for pulp plantations, Toba Pulp Lestari destroys not only the livelihoods of the community, their childrens’ livelihoods, and the ecosystem, but it destroys their culture as well.

Local communities have opposed the mill since it began operations in North Sumatra in 1989 due to the rainforest destruction, land grabbing and toxics pollution central to the company’s business model. In 1990, 10 elderly women from Sugapa Village were arrested for pulling up and destroying eucalyptus plantings on their traditional land. Protests by the local community escalated in 1998 and temporarily shut down the mill. But in recent years, the company has changed its name from PT Inti Indorayon Utama to PT Toba Pulp Lestari and reopened the mill; it is now in the process of expanding its destructive operations further into pristine rainforest. Along with name changes, the company has changed affiliations multiple times in order to hide its destruction. The company was formerly affiliated with pulp and paper giant, Asia Pacific Resources International Limited (APRIL) and its parent Royal Golden Eagle (RGE), and is still controlled by notorious Indonesian business tycoon Sukanto Tanoto through holding companies.  

This may seem like a conflict far away from those of us in the Americas, Europe, or Australia, but it’s closer than one would think. A wide variety of consumer products contain pulp from rainforests like those in North Sumatra, including paper, food, cosmetics, household goods—even clothing. This pulp, and the conflict that produced it, is sold on store shelves in your neighborhood - unmarked and unidentifiable.

Unless Toba Pulp Lestari respects the rights of the Indigenous people, including the right to Free, Prior and Informed Consent (FPIC), conflicts will only continue. And while Indonesia’s Constitutional Court has acknowledged the customary forest rights of the communities, Toba Pulp Lestari’s concessions and operations continue to undermine the ability of local people to access and manage their own forests.

We plan to keep you up to date on this conflict and bring more information continue to explore and expose the pulp supply chains threatening global rainforests.... stay tuned.

APRIL Makes A Mockery Of Its Own "Sustainable" Forest Policy


Almost six months after the release of its Sustainable Forest Management Policy, Asia Pacific Resources International Ltd (APRIL)—the second-largest Indonesian pulp & paper company—continues business-as-usual rainforest destruction, betraying the spirit and substance of its policy.

The Sydney Morning Herald reported in May that APRIL-owned PT RAPP cleared massive swaths of carbon-rich peatlands on Pulau Padang, an island off the Sumatran coast that APRIL promised to help restore. Members of island community Desa Bagan Melibur have called on APRIL to terminate operations on their community land, and Desa Bagan Melibur’s May 17 protest is the most recent clash in a stark legacy of land disputes between APRIL and Padang’s thirteen villages since 2009.

Pulau Padang’s peatlands store millions of tons of carbon and are home to endangered species and communities that depend on these forests for their livelihoods. You could also say the island itself is endangered: decaying peat causes the low-lying island to subside, and scientists warn that if no action is taken, Padang may very well be under sea level and useless for any type of cultivation by 2050.

APRIL’s forest policy itself is rife with loopholes and allows APRIL to continue slashing natural forests in its concessions through December and source rainforest fiber until 2020. Yet the company’s refusal to uphold even its weak policy commitments brings APRIL’s intentions entirely into doubt. In addition to the Pulau Padang case, earlier this year, APRIL suppliers were caught clearing natural forests on legally protected peat land in Borneo and high conservation value forest on peat land in Riau. In the latter case, not only were internationally protected ramin trees cut down, but APRIL supplier PT Triomas allegedly attempted to hide the evidence by burying the contraband logs.

There is mounting recognition that APRIL’s policy and actions are insufficient and not credible. Last Friday, RAN and an international collation of allies co-authored a letter highlighting the severe shortcomings in APRIL’s policies, such as the lack of a moratorium on natural forest and peat land conversion, unclear commitments on resolving social conflicts, and the policy’s narrow scope, which does not extend to cover APRIL’s sister companies within owner Sukanto Tanoto’s rogue cartel of companies, such as Toba Pulp Lestari, Sateri, and Asian Agri. The letter also points to the inadequacy and questionable credibility of the Stakeholder Advisory Committee (SAC) APRIL set up to help develop, implement, and monitor the forest policy in a transparent and independent manner.

APRIL’s new policy and the SAC risk being nothing but a parade of environmental lip service built on teetering scaffolds of environmental destruction, social conflict, and corruption. Customers and financiers must cut ties with APRIL and other companies owned by Sukanto Tanoto and pressure APRIL to end rainforest clearing and respect community rights.

TAKE ACTION: Tell APRIL owner Sukanto Tanoto to stop pulping Pulau Padang’s rainforests.

STAPLES: Don't Jump the Gun with APP

Strawberry at StaplesActivists with Rainforest Action Network staged a direct communication today at office-supply giant Staples. Displaying a banner that read, “Staples: It’s Too Soon to Buy from APP,” a group of activists voiced their opposition to the company’s recent decision to resume purchasing paper from Asia Pulp and Paper (APP). One of Indonesia’s most notorious deforesters, APP’s history of broken promises, rainforest destruction and human rights abuses in Indonesia is well documented and extends across an area almost the size of Massachusetts. After numerous contract cancellations from major customers over APP’s ties to deforestation and land grabs, the company issued a Forest Conservation Policy (FCP) in February 2013 promising broad reforms and a halt to further rainforest destruction. To its credit, APP has extended a moratorium on further rainforest clearing and conversion across all of its concessions and those of its suppliers. RFP_Staples_Diagonal1But APP is still in the early stages of implementing the environmental and social commitments in its Forest Conservation Policy (FCP). And though an auditor has been agreed on, there has been no independent verification of APP’s performance in implementing the FCP. Furthermore, APP has yet to develop credible plans for addressing key gaps in the FCP—for example, on restoring some of the extensive landscapes it has devastated—which have been summarized in the Environmental Paper Network’s “Performance Targets and Milestones for APP” endorsed by Greenpeace, WWF, RAN and Indonesian NGO WBH, among others. Based on past experience, RAN maintains that companies are more motivated to undertake robust implementation of commitments if rewarding such implementation comes after, not before, it is carried out and independently verified. Although Staples is jumping the gun by purchasing from APP, the circumstances could be far worse. Staples has put in place environmental and social performance requirements as part of its contract with APP. It's also starting small and phasing its purchases. Those safeguards are something that all paper purchasers should require after APP’s FCP has been fully implemented and verified. This conditional purchasing reflects a strategic approach, but still leaves Staples open to risk of APP defaulting on its commitments. Finally, Staples and all paper buyers must not let the fact that APP is undertaking reforms undermine or replace their purchases of recycled and FSC certified paper and wood products. Contractual requirements and verification of performance on APP’s Forest Conservation Policy are not equivalent to the comprehensive, multi-stakeholder agreed standards and accredited verification apparatus that underpin FSC certification. While we remain optimistic that APP’s commitments will be fully implemented, at the moment it is simply too early to tell, and too early to buy. RFP_Staples_Diagonal3

Asia Pulp and Paper Caught Clearing Rainforest: Credibility of APP Deforestation Moratorium in Doubt

Indonesian paper giant APP says it wants to change, but, given its track record, the company must prove itself before it can be trusted as a supplier of pulp and paper products. Unfortunately, APP's four-month-old commitment to stop destroying Indonesia's rainforests has already been called into question. WWF Indonesia recently published an open letter to APP's CEO Linda Widjaja that raises concerns related to documented rainforest logging in APP supplier concessions. The logging is a breach of the paper giant’s public commitment not to clear rainforests starting February 1, 2013. As the story comes to light, it appears that APP may have been misleading paper buyers and the public about what it was actually doing. This video evidence of APP timber supplier PT Riau Indo Agropalma clearing natural forest in a peat area where APP pledged to impose a moratorium on rainforest clearance was released by Eyes on the Forest:

In response to this evidence of clearing in violation of its highly publicized moratorium on logging, APP has claimed that the area is an “exclusion area” that it had failed to disclose. APP’s admission that it has been clearing rainforests even as it has been telling the world otherwise puts the credibility of the company's entire "Forest Conservation Policy" (PDF) in doubt. Ongoing rainforest clearance by APP is a major cause for concern for Rainforest Action Network and many others. We want APP to succeed in its commitments, but to do so it must implement them earnestly and effectively. APP must stop logging rainforests and expanding on peatlands immediately. The company must address its legacy of deforestation and human rights violations, must start protecting and restoring High Conservation and High Carbon Value areas, and must work to resolve and prevent land conflicts while agreeing to remedies with communities that have been adversely impacted by APP and its suppliers. It's not just local rainforest communities and wildlife that are impacted by the destruction of Indonesia's rainforests. Since its founding, APP has cleared and pulped an area of Indonesian rainforest almost the size of Massachusetts. By cutting down forests and degrading peatland, APP spewed an estimated 67 million to 86 million tons of carbon dioxide into the atmosphere in 2006 alone, putting APP's annual emissions ahead of those of 165 countries. APP's forest-clearing operations are contributing a significant amount of greenhouse gas emissions that are driving climate change, and that will affect us all. This latest revelation about APP clearing rainforest demonstrates that there is still significant risk for consumer companies and investors in associating with APP before the company has proven, through actions, that it is environmentally and socially acceptable. APP's misleading claims also call into question the trust that can be placed in the company. A clear set of performance targets and milestones is needed so that APP can be held accountable to implementing its commitments before buyers consider renewed purchasing. Large corporate paper buyers around the world have sent a strong message that it is no longer acceptable to pulp rainforests or inflame land conflicts as the “hidden” cost for the paper they buy. Now that APP has come to the table to reform its bad practices, paper buyers must insist on transparency, honesty and independent verification, not just another round of sweet-sounding promises.

Indonesian Forest Protections Under Attack

I wish I didn't have to write this blog post on Earth Day. The rainforest where I saw my first wild orangutan is under threat. I can't believe it! There are many reasons to protect the Leuser Protected Ecosystem, a forest area on the island of Sumatra, Indonesia. Thousands of Indigenous people rely on the forest for their lives and livelihoods, and it is the last place on Earth where endangered species like the Sumatran orangutan and the Sumatran tiger coexist with elephants, rhinos, and Sunbears. But the government of Aceh, the province in which the Leuser Protected Ecosystem lies, is considering a plan that would remove large regions of forest from the protected area, opening them up to palm oil and pulp plantations, logging, mining, and all of the roads and other infrastructure that come with them. The Indonesian government is now considering the plan, and has the power to reject it. We need to be making sure that what’s left of the world’s rainforests are protected, not opening them to destructive industries seeking to profit from rainforest destruction. Send Indonesian President Susilo Bambang Yudhoyono and Secretary General of the Ministry of Forestry Hadi Daryanto an email now calling on them to reject this misguided plan and keep the Leuser Protected Ecosystem protected. Of course, it’s not just local communities and wildlife that need to be protected from bulldozers and forest fires. Indonesia’s rainforests are a valuable carbon sink—destroying them would make our climate problem that much worse, imperiling the future of everyone on this planet just to enrich a few well-connected businessmen. Urge the President of Indonesia and the Secretary General of the Ministry of Forestry to protect local communities, endangered species, and the climate now.

An Open Letter From RAN: What Do APP’s New Commitments on Forests, Peatlands and Community Rights Mean for Buyers and Investors?

Save Indonesia's rainforests RAN has been campaigning since 2009 to persuade Asia Pulp and Paper (APP) to reform its destructive business practices. To that end, we have worked with dozens of major companies to develop policies that eliminate paper associated with rainforest destruction from their supply chains, including, most recently, Disney and HarperCollins. With APP's newly announced Forest Conservation Policy, paper purchasers and investors who have avoided doing business with APP in the past may wonder if the time has come to reconsider. RAN's position is described below.
To Whom It May Concern, On February 5 Asia Pulp and Paper (APP), the largest paper company in Indonesia and the third largest in the world, announced a new “Forest Conservation Policy” to undertake environmental and social reforms to its business practices. APP has become notorious in international markets for the exceptionally negative environmental, climate and human rights footprints of its operations. The APP announcement is a testament to the positive collective impact that the actions of almost 100 international corporate customers, including Disney, Staples and Mattel, have had by refusing to purchase papers linked to tropical deforestation, land and social conflicts with local communities and human rights violations. RAN welcomes APP’s new rainforest commitments as an important milestone. It includes commitments related to peatlands, engagement with local communities, and protection of high conservation value areas and high carbon stock forests. Indonesia rainforest destructionAPP’s commitments[1], which went into effect February 1, apply to both lands controlled directly by the company and lands controlled by their suppliers – about half of APP’s paper fiber comes from ‘independent’ suppliers, including fiber from the clearing of rainforests and drainage of peatlands. The company says it will defer clearing and conversion of natural forests and carbon-rich peatlands while conservation and carbon values are assessed. It is still uncertain when the deferred logging will resume and whether the company will stop the use of natural tropical rainforest fiber in all of their mills. In addition, the commitment acknowledges the company’s problems associated with land conflict, and recognizes that indigenous and local communities may have customary rights to land that APP would like to use for its pulp plantations. The company must now work with stakeholders to develop, announce and meet detailed implementation plans including performance targets, benchmarks and timetables related to their environmental and social promises. It must also put in place transparent systems for independent monitoring, reporting and verification of its implementation plans. APP’s new commitment is just the starting point, not the finish line.  The hidden story here is the controversial paper giant’s long and deep history of broken promises, land conflicts and human rights violations across its operations. The lesson learned again and again is the essential importance of clear measurable implementation measures and mechanisms, implemented in close cooperation with key stakeholders, including NGOs, and confirmed by credible, independent verification. It is still too early to say if APP’s latest commitments will bear fruit, as we all hope they will, or withers on the vine as has happened too consistently in the past. For potential buyers of APP products and investors in the company, the key take away is that APP should not be seen as a responsible company in the marketplace and companies should not consider doing business with APP or its affiliates until independent verification confirms that APP’s new commitments have been implemented and that it is constructively resolving the devastating rainforest and human rights crises it has caused in Indonesia. More information on the APP announcement and specific social and environmental challenges the company is facing can be found in this statement on our website. Sincerely, Lafcadio Cortesi, Asia Director and Robin Averbeck, Forest Campaigner, Rainforest Action Network

RAN and Allies Call on APP to Respect Human Rights

[caption id="attachment_20698" align="alignleft" width="300"]Community opposing APP Members of an Indigenous farmers group from Siabu, Riau Province meet to make plans for reclaiming their traditional lands currently being used by a pulp plantation supplying APP.[/caption] While Asia Pulp and Paper’s (APP) questionable financial dealings and destructive impact on rainforests and the climate have been widely reported, the human rights violations and social conflict associated with the company’s expropriation of community lands are less well known. Last week, RAN proudly joined with several Indonesian and international human rights and environmental organizations to send a letter to APP outlining the steps the company must take to address its human rights record and prevent further land grabs and rights violations. Along with CAPPA, HuMa, WBH, Scale Up and Forest Peoples Programme, we sent the letter to outline the shortcomings in APP's operations and to emphasize that the company must take responsibility for the social and environmental footprint associated with all the wood coming into its mills to make pulp and paper. While the company has recently taken some tentative steps in the right direction, they must make urgent and far-reaching changes to the way they do business in order to remedy previous and prevent further disastrous environmental and human rights impacts. To quote the letter:
At a general level, we urge that APP inform its direct (“owned”) and indirect (“independent”) suppliers that it will stop purchasing from any suppliers that: • Do not respect the rights of affected communities to the ownership and control of their titled and customary lands and to give or withhold their Free, Prior and Informed Consent (FPIC) to proposed developments on their lands as expressed through their own freely chosen representatives; • Have failed to resolve social conflict and human rights violations with affected communities to the mutual satisfaction of affected parties; • Evict communities with land claims in concessions and consider CSR activities as adequate and final resolution of conflicts • Do not place a moratorium on logging and natural forest clearance until High Conservation Values have been identified and maintained, and; • Continue to clear and drain areas of peat soil or convert High Carbon Stock Forest
RAN has been working with leading businesses, civil society and local communities to get APP—which is one of the two biggest pulp and paper companies operating in Indonesia, along with Asia Pacific Resources International (APRIL)—to own up to and change how it does business, and it must do so before going forward with its expansion plans. APP could use its position in the industry to effect real and positive change, which is exactly what we're urging the company to do:
We ask that APP inform its suppliers that it will only be able to purchase wood from them if they follow the same human rights and environmental commitments that we suggest APP take on itself.
You can download the letter as as PDF, or read it here:

HarperCollins Paper Policy Under Construction - An Opportunity to Get it Right

This morning I logged onto to HarperCollins' website to check out the company's paper policy. What I found was something different than I'd seen before—just the first paragraph of their previous policy. I suspect that the policy may be under construction as we speak, and if that's the case, I am urging HarperCollins to be a leader by meeting or beating other best in class policies. Luckily, there are many examples within the publishing industry to look to for guidance. Scholastic, Hachette, and Disney all have robust, comprehensive paper policies. Write to HarperCollins CEO Brian Murray now and urge him to get it right. In a letter to HarperCollins' CEO earlier this week, we urged the company to adopt a meaningful, comprehensive, company-wide paper policy with numeric, time-bound goals to a) eliminate controversial sources, b) maximize post-consumer recycled content, and c) give preference to fibers and products certified by the Forest Stewardship Council (FSC) if virgin fiber or materials are used. HarperCollins’ UK division’s policy, last updated in 2008, incorporates many of these elements, yet they are not present in HarperCollins’ U.S. policy. RAN is looking to HarperCollins to adopt a globally consistent, comprehensive policy. [caption id="attachment_20575" align="alignnone" width="550" caption="HarperCollins Paper Policy Friday 12/14/12"][/caption] [caption id="attachment_20577" align="alignnone" width="550" caption="HarperCollins Paper Policy Tuesday 12/11/12"][/caption] In our letter we also urged HarperCollins to eliminate its use of controversial Indonesian fiber and publicly sever all financial ties with Asia Pulp and Paper (APP), Asia Pacific Resources International (APRIL) and their affiliates until key reforms are adopted. While the company stated that it "currently does not do business with APP or APRIL" in a Mother Jones article that came out today, it has not yet answered key questions, such as: Does this commitment includes APP subsidiaries and affiliates, such as Gold East? Given that APRIL is primarily a pulp company supplying paper mills in China and elsewhere, has HarperCollins learned from printers and paper suppliers whether the mills they are purchasing from use pulp from APRIL? Has the decision to stop working with APP and APRIL been communicated to printers and paper suppliers and has this requirement been inserted into all HarperCollins' contracts and purchase orders? HarperCollins looks to be heading in a positive direction—now it has the opportunity to cross the finish line with a robust paper policy, and clarification and strong implementation of its commitments to avoid controversial suppliers APP and APRIL. Hopefully HarperCollins won't be ruining any more Christmases with rainforest destruction in its books.

Victory for Forests: Disney Changes Sourcing On All Its Paper Products, Takes a Stand for Endangered Forests and Animals

[caption id="attachment_20104" align="alignleft" width="300" caption="Click image to send a thank you letter to Disney!"][/caption] Today, Disney adds its significant voice to the growing chorus of companies demonstrating that there’s no need to sacrifice endangered forests in Indonesia or elsewhere for the paper we use every day. This entertainment giant, which is the world's biggest publisher of children's books and magazines, has adopted what may be one of the most far-reaching paper policies ever, including groundbreaking safeguards for the climate and human rights. RAN began our Disney campaign in 2010 after lab tests found that its children’s books were printed with rainforest fiber from Indonesia. You might remember the vivid protest where Mickey and Minnie Mouse locked themselves to the gates of Disney's headquarters in May 2011? That risky tactic got the company's attention. Within a week, Disney senior executives flew to San Francisco to meet with RAN’s forest team. Now, after 18 months of productive negotiations, RAN is standing with Disney as the company announces it will eliminate paper connected to the destruction of endangered forests, human rights violations, and the loss of high carbon value forests. In practical terms, this significant new paper policy means that Disney will be eliminating paper connected to the destruction of endangered forests and animals from its extensive operations and those of its licensees; it applies to both the way Disney sources and uses paper, reaching every corner of the company’s business. The policy covers everything from the pages of a Marvel comic book in New York and the copy paper at ABC’s headquarters in LA to the packaging of a Mickey doll sold in Moscow. In the 21st century it is indefensible that any paper still comes from endangered rainforests. And yet, in places like Indonesia, which has one of the most biologically and culturally diverse forests, the pulping of trees for paper is a part of why the country has one of the highest rates of deforestation in the world. Conservatively, an estimated 2.5 million acres of rainforest are lost in Indonesia per year. Thanks to this policy, Disney will be joining the growing list of major brands that have cut ties to notorious Indonesian rainforest destroyers and paper giants Asia Pulp and Paper (APP) and Asia Pacific Resources International Holdings (APRIL). Disney’s commitment will reduce the demand for paper made at the expense of rainforests while creating incentives for improved forest management and green growth. So, just how big is this announcement? For a bit of perspective, consider that Disney products are produced in almost 25,000 factories worldwide, 10,000 in China alone. Disney owns a vast media empire including media networks such as ABC and ESPN alongside studios including Pixar and Touchstone, and is the largest licensor of toys and the largest operator of theme parks in the world. All that takes a LOT of paper—none of which can be connected to the destruction of endangered forests and animals in Indonesia or elsewhere. What excites me most about Disney’s commitment is its depth, affirming that the company will avoid not only tropical deforestation, but also go above and beyond to protect human rights and to recognize the high carbon value of rainforests – two things rarely seen in policies of this kind. Join me in thanking Disney for taking this stand. It is time every company acknowledge that Rainforests are more valuable left standing than being pulped for paper!

Congress: Protect the Forests and Wildlife of the World From Illegal Logging

Did you know that almost half of all rainforest destruction is done illegally? Government corruption, lax laws and poor enforcement result in widespread illegal deforestation across the globe. This unofficial forest clearing makes it extremely challenging to truly protect critically endangered species like the orangutan or Sumatran tiger from extinction and it contributes enormous amounts of carbon into our atmosphere. And now, the best law on the books to prevent illegal logging worldwide – the Lacey Act - is under attack. The Republican leadership cancelled for now a vote originally scheduled for this week in the House of Representatives on H.R. 3210, the “RELIEF Act.” A broad coalition of forest products companies, workers, conservation groups, and musicians praised House leadership for halting the measure, which would have many negative economic and ecological consequences if passed. Please send a letter today asking your congressional representative to vote against the RELIEF Act if Republicans move forward and call for a vote in the House. The Lacey Act ensures that only legally sourced wood and wood products are imported into the country, reducing global deforestation rates and preventing job losses in the American forest products industry. The act has been so successful that other countries are looking to create their own versions of the law. Over sixty major forest products companies, thirty-five leading conservation organizations and labor unions, and over thirty top-selling musicians sent letters to members of Congress asking them to oppose any attempts to weaken the Lacey Act. But the Lacey Act remains in jeopardy by those wishing to end environmental protections and regulations. Their proposals, such as the "RELIEF" Act and "FOCUS" Act, would effectively gut the Lacey Act, reversing years of hard fought efforts to stop international deforestation. These bills would directly benefit notorious forest destroyers like Asia Pulp and Paper (APP) and would allow illegal loggers to around the world to operate with impunity. The result would be a flood of illegal wood into the U.S. market. Send a message today urging your representative to vote No on H.R. 3210, H.R. 4171 or any other bill that would weaken the Lacey Act.

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