NGO Statement of Concern on Tokyo 2020 Olympics’ revised Timber Sourcing Code

We, the undersigned NGOs, are deeply disappointed by the recent revision of Tokyo 2020 Olympics’ timber sourcing policy (1), which fails to end the use of timber associated with rainforest destruction and human rights abuses that have been repeatedly found in Tokyo 2020’s timber supply chain. By allowing Tokyo 2020 suppliers to continue sourcing high-risk timber from controversial companies, without meaningful due diligence, the Olympics will be leaving a bitter legacy for Japan.

The Tokyo 2020 Olympics has been mired in controversy since the bidding process (2), and its substantial use of unsustainable rainforest wood to construct several new Olympic venues is a clear case in point, constituting a violation of Tokyo 2020’s commitment to host a sustainable Olympics. According to records published by the Tokyo Organising Committee of the Olympic and Paralympic Games (TOCOG), between December 2016 and November 2018, over 171,900 large sheets of concrete formwork plywood from the tropical rainforests of Malaysia and Indonesia were used to construct the new Olympic venues, equivalent to approximately 9,823 m3 logs.(3) 73% of this wood derived from Indonesia, including the clear-cutting of natural tropical rainforests, thus negatively impacting one of the most biodiverse forest ecosystems in the world.(4)

In response to concerns raised by NGOs, numerous petitions, and Tokyo 2020’s own experts on sustainability, TOCOG initiated a review of the existing timber sourcing policy in July 2018. Regrettably, the new policy announced on January 18th of this year makes minimal improvements and fails to ensure the sustainability or even legality of the timber being procured.

Firstly, the revised policy explicitly excludes timber products derived from the clearance of forests for other purposes, so-called conversion timber, and encourages Olympic suppliers to trace the timber they supply back to the forest and assess and mitigate the risk of procuring from producers that do not comply with the policy. While these additions appear to be improvements, a normal interpretation of the existing policy (5) already ruled out conversion timber, and the provisions related to supplier due diligence are not binding. Secondly, the revised policy maintains an egregious loophole which allows the use of plywood that fails to meet the policy’s criteria on sustainability and rights; fails to require meaningful due diligence that is critical for avoiding controversial wood (6); fails to require suppliers to obtain the free, prior and informed consent (FPIC) of communities affected by timber harvesting; and presumes all certified products to be sustainable without additional due diligence, despite clear evidence of unsustainable wood in such supply chains.(7)   

Moreover, the process for revising the timber policy has been deeply flawed and has failed to follow the PDCA (plan-do-check-act) model to which Tokyo 2020 committed to (8). During the entire review process, Tokyo 2020 withheld from its own procurement committee the methodology and findings from their ongoing monitoring of Tokyo 2020’s timber supply chain in Malaysia and Indonesia. The policy review was intended to assess the risks within Tokyo 2020’s tropical timber supply chain and the policy’s suitability to address such risks. Instead, the review was conducted in a vacuum, without any input from the ongoing supply chain monitoring and with very limited discussion on the issues raised regarding Tokyo 2020’s actual supply chain. Furthermore, despite significant public interest in the policy review process, no public comment period was offered on the revised policy.

We call on all Tokyo 2020 organizers to 1) promptly disclose a detailed assessment of how sustainability and legality has been assured for all tropical timber products that have been procured to date; 2) immediately end the use of all wood products from the tropics or other high risk areas for Olympic construction unless full traceability to the area of harvest is established and compliance with the timber sourcing policy’s five criteria for legality, sustainability and rights, along with FPIC, are third party verified; and 3) publish a thorough explanation of how the revised sourcing policy will make a difference in Tokyo 2020’s assurance of legality and sustainability throughout its supply chain, particularly with respect to high-risk timber.  All disclosures should be made in a language accessible to affected communities.

Rainforest Action Network (RAN)

Japan Tropical Forest Action Network (JATAN)

Bruno Manser Fund

Environmental Investigation Agency (US)

FoE Japan

Hutang Group

Sarawak Dayak Iban Association (SADIA)


WALHI North Maluku

Sarawak Campaign Committee (SCC)



  1. Announcement of revised Tokyo 2020 Sustainable Sourcing Code for Timber, Jan. 18 2019, (in Japanese only)
  2. Washington Post, Takeda corruption probe sullies 2020 Tokyo Olympics and IOC, Jan. 15 2019,
  3. Information on the concrete formwork plywood procured for Tokyo 2020 Olympics, In Japan, concrete formwork plywood is typically sized at 15x910x1820mm. Volume of plywood can be converted to volume of logs (round wood) used in manufacturing using a factor of 2.3. (Source: UNECE/FAO)
  4. A large proportion of the Indonesian wood used on the Olympic construction sites is known to have been supplied by a notorious Korean-Indonesian logging and palm oil company named Korindo, which has been associated with illegal logging, human rights violations and the clear-cutting of rainforests for coal mining and the cultivation of palm oil. This is currently the subject of a complaint brought by RAN and others. See
  5. Tokyo 2020 Sustainable Sourcing Code for Timber, para 2 (ii) & (iii),
  6. See, for example,
  8. Tokyo 2020 Olympic and Paralympic Games Sustainable Sourcing Code (3rd edition), p14,