Alignment of National Forest Policy Frameworks with the EU Timber Regulation Requirements: Insights from Montenegro and the Republic of Srpska (Bosnia and Herzegovina)

Round 1

Reviewer 1 Report

Montenegro and the Republic of Srpska)  did not translate EUTR obligations into policy and regulatory documents but were only coded for the purpose of this study based on existing documents. What then are then the implications on trade of these States with the European Union at the current state of affairs?

While clearly mentioned that both States are still undergoing policy changes aligning to EUTR guidelines, none has been mentioned about the current and future implications on trade with the EU. What is particularly glaring in this study is the legality issue which poses major challenges in the implementation in both States?

Forest Stewardship Certification (FSC) and which body (national or international?) issues it is still not clear. This issue is of prime importance considering that trade involves several parties and convergence of policies, among other issues, especially those involving  legality has to be addressed and agreed upon by all trading partners. It is in this aspect that all parties need to work out to ensure smooth and speedy transactions. It well known that the forestry sector, in almost all parts of the world, contributes to the economy of nations. 

You can elaborate in your Discussion the implications stipulated above. 

Comments for author File: Comments.pdf

Author Response

• Thank you for your time to revise our paper and for all your comments and suggestions for improving our work. We did our best to address all your feedback. Please find details below as well as amendments within the revised version of the paper. 
• Montenegro and the Republic of Srpska) did not translate EUTR obligations into policy and regulatory documents but were only coded for the purpose of this study based on existing documents. What then are then the implications on the trade of these States with the European Union at the current state of affairs?
• We have now reformulated the sentence to clearly state "As Montenegro (Bosnia and Herzegovina) is not an EU member state, it is not requested to formally implement EUTR". Based on available research and studies, Bosnia and Herzegovina and Montenegro represent countries that provide timber and timber products on the EU market, directly or indirectly. Both countries are EU candidate countries, ready to implement and adapt current national legislative frameworks with the aim of increasing visibility for timber and timber products on the EU market. Previous research also recognized Western Balkan countries as countries with illegal timber flows. The Republic of Srpska, as part of Bosnia and Herzegovina, has all the prescribed national regulations that provide timber and timber products for trade on the EU market. The forest area is totally FSC-certified in the Republic of Srpska. Available trade data on timber and timber products exports are presented on the state level, at the level of Bosnia and Herzegovina.
• While clearly mentioned that both States are still undergoing policy changes aligning to EUTR guidelines, none has been mentioned about the current and future implications on trade with the EU. What is particularly glaring in this study is the legality issue which poses major challenges in the implementation in both States?
• Current and future implications related to trade relations between the analyzed countries and the EU were not the subject of this research in accordance with defined research limitations. Our first aim was just an analysis of national legislation in terms of future EUTR implementation in these countries. This research is part of PhD research and represents the only base for researching stakeholders' perceptions and network analysis in five countries: Slovenia, Croatia, Serbia, Bosnia and Herzegovina, and Montenegro. Our aim was to investigate current legislative frameworks and national laws that prescribe trade regulations and show their relation to EUTR and the future possibility of EUTR implementation. There is the author's intention for the next research in terms of timber trade between Western Balkan countries and the EU.
• Forest Stewardship Certification (FSC) and which body (national or international?) issues it is still not clear. This issue is of prime importance considering that trade involves several parties and convergence of policies, among other issues, especially those involving legality has to be addressed and agreed upon by all trading partners. It is in this aspect that all parties need to work out to ensure smooth and speedy transactions. It well known that the forestry sector, in almost all parts of the world, contributes to the economy of nations.
• FSC certification is fully implemented in the Republic of Srpska. This part of Bosnia and Herzegovina was a research focus primarily because of the specific institutional organization of the Federation of Bosnia and Herzegovina. In Montenegro, at this moment, the process of proving timber legality can only be done in accordance with national law regulations and prescribed documents. In accordance with information provided by the Ministry of Agriculture, Forestry, and Water Management, Directorate of Timber Industry, if there is a situation in which producers need to export timber or timber products to the EU market, the ministry will provide support in the process of proving timber legality.
• You can elaborate in your Discussion the implications stipulated above.
• The discussion section has been revised however, as already reported, implications referred to are important, yet beyond the scope of this research.

Reviewer 2 Report

Thank you very much for this interesting manuscript. Analysing the existing forest policy frameworks’ alignment with EU legislation in potential EU members is worth investigating. The EUTR implementation is important to combat illegal logging, whereas the Western Balkan states have some implementation shortcomings.

The authors claim they extend existing research in the region to include the analysis of the forest policy frameworks of Montenegro and the Republic of Srpska (BH). They use the same methodology as in the previous study Radosavljevic et al. 2021 (reference 22). Although the article presents new knowledge, it is more descriptive than analytical. It refers eleven times to the article Radosavljevic et al. 2021, which I find problematic. 

The abstract is too long and uncomprehensive. It should present the main results. I would consider shorten it. 

The introduction outlines the problem sufficiently, and refers to relevant literature. The research gap is clearly defined. Aim is clear. 

Although the results are potentially interesting to the readers, it lacks the analytical focus a scientific article should have. It merely describes the results of the document analysis without a deeper analysis. The discussion does not contain a section on the limitations of the research design and applied methodology.

There are many typographic errors. Full stops are missing. Spelling errors occur.

Author Response

• Thank you for your time to revise our paper, for all your comments and suggestions for improving our work and, last but not least, for your supportive words. We did our best to address all your feedback. Please find details below as well as amendments within the revised version of the paper. 
• Thank you very much for this interesting manuscript. Analysing the existing forest policy frameworks’ alignment with EU legislation in potential EU members is worth investigating. The EUTR implementation is important to combat illegal logging, whereas the Western Balkan states have some implementation shortcomings.
• Based on previous research, studies, and implemented projects in the region on this topic, we think that the analysis of legislation as a base for future research will contribute to the knowledge on this topic in Western Balkan countries.
• The authors claim they extend existing research in the region to include the analysis of the forest policy frameworks of Montenegro and the Republic of Srpska (BH). They use the same methodology as in the previous study Radosavljevicet al. 2021 (reference 22). Although the article presents new knowledge, it is more descriptive than analytical. It refers eleven times to the article Radosavljevic et al. 2021, which I find problematic. 
• Following your comments, we reviewed this section and significantly reduced the use of the abovementioned reference.
• The abstract is too long and uncomprehensive. It should present the main results. I would consider shorten it. 
• We fully accepted this comment, and you will find a shortened abstract in the revised manuscript.
• The introduction outlines the problem sufficiently, and refers to relevant literature. The research gap is clearly defined. Aim is clear.
• Thank you, we are happy that you recognized our effort in this research.
• Although the results are potentially interesting to the readers, it lacks the analytical focus a scientific article should have. It merely describes the results of the document analysis without a deeper analysis. The discussion does not contain a section on the limitations of the research design and applied methodology.
• According to your comment, we shortened the results, trying to be more concise and analytical in their presentation. We have now restructured the discussion, so it is now divided into five sub-sections. In the discussion, we try to take a more analytical approach, also comparing these results with those of the other three countries (Serbia, Croatia, and Slovenia) from the previous manuscript. Regardless, the idea of this manuscript is indeed to present the results of content analysis pointing to legal requirements for timber legality in both countries, as we believe that such kind of information might be relevant both for the research community working on the issues of the legality, as well as to the practitioners working in forestry or timber industry. As disclosed in the Acknowledgments, This is (together with previously published manuscript doi:https://doi.org/10.3390/f12121665) a part of the Ph.D. research in progress and should provide a basis for identifying formal institutional gaps in forestry sectors. We reflect on the descriptive nature of our analysis within the limitations of the study that are added at the end of the discussion in Section 5.5.

Round 2

Reviewer 2 Report

Thank you very much for the revised manuscript. All my comments have been sufficiently adressed, I have no further comments.