ISO 14001 · Supply Chain Integrity · Global Policy Watch
By Diana Lynn, President and Principal ISO Consultant, MSI · Updated October 27, 2026
Direct Answer
The environmental crime protocol is a proposed UN treaty that would treat wildlife, timber, mineral and waste trafficking as serious organized crime. On October 23, 2026, governments voted 83 to 12 to start negotiating it. It is not law yet, and it will bind only the countries that ratify it.
Key Takeaways
- On October 23, 2026, parties to the UN Convention against Transnational Organized Crime voted 83 to 12 to negotiate an environmental crime protocol covering wildlife, timber, minerals, precious metals and waste.
- The environmental crime protocol does not exist yet; a committee will negotiate it over roughly two years, and it will bind only the countries that ratify it.
- According to Igarapé Institute commentary, the United States was among four countries that sought to dilute the initiative, so U.S. ratification is uncertain as of October 27, 2026.
- U.S. prosecutors already enforce the Lacey Act: Boise Cascade paid a $6,382,000 fine in April 2026 over plywood its supplier had smuggled.
- Even without ratifying, every country is bound by the customary “no-harm” rule against causing significant environmental harm to other countries, as the International Court of Justice confirmed in July 2025.
- ISO 14001:2026 already requires you to determine compliance obligations (6.1.3), control or influence externally provided processes (8.1) and evaluate compliance (9.1.2).
The environmental crime protocol is a proposed UN treaty to treat wildlife, timber, mineral and waste trafficking as serious organized crime. To see why it matters to a management system, start with a container of plywood.
Somewhere between a factory in China and a distribution yard in Pompano Beach, Florida, that plywood changed its story. According to the U.S. Department of Justice, the supplier moved Chinese wood into new containers during stops in Malaysia, then filed import paperwork that hid where it came from. A building-materials distributor bought about $30 million of that plywood between 2018 and 2021. In April 2026, the distributor pleaded guilty to a felony.
The distributor did not falsify the paperwork. Its supplier did. What made the buyer criminally responsible was conduct that legal analysts summarized as “actions manifesting willful blindness.” The warning signs were there. Nobody acted on them.
On October 23, 2026, in Vienna, governments voted to begin writing the first global treaty aimed squarely at this kind of trade. This article explains what the environmental crime protocol is, how enforceable it is likely to be, and where 2026 U.S. cases show the problem is already happening. It also explains why I am asking every reader, whether you run an environmental management system, buy materials or simply care about forests and wildlife, to watch what happens next.
The Vote
What did the UN vote for on the environmental crime protocol?
Vote. Commit. Negotiate.
Direct Answer
The environmental crime protocol vote passed 83 to 12 on October 23, 2026, at the 13th Conference of the Parties to the UN Convention against Transnational Organized Crime in Vienna. It created an ad hoc committee to draft a protocol on wildlife and timber trafficking, illegal mining, mineral and precious-metal trafficking, and waste trafficking.
The UN Convention against Transnational Organized Crime (UNTOC), adopted in 2000, is the main global treaty on organized crime. It already carries three protocols, on trafficking in persons, smuggling of migrants and firearms. The environmental crime protocol would be the first protocol under UNTOC dedicated to crimes that affect the environment. The UNODC working groups page tracks the bodies that support the convention.
The proposal came from Bolivia, Brazil, Colombia, Costa Rica, Ecuador, Panama, Peru and Uruguay, joined by Mauritania, the Democratic Republic of the Congo and São Tomé and Príncipe, according to Noticias Ambientales. Many of these are the countries where forests, rivers and wildlife are being stripped. The vote enables negotiations but does not approve any text.
The groundwork took years. The Global Initiative Against Transnational Organized Crime reports that Brazil, France and Peru tabled a resolution in October 2024 that created an intergovernmental expert group on crimes that affect the environment. That group first met in Vienna from June 30 to July 2, 2025, and reported to the October 2026 conference.
The Wildlife Conservation Society called the decision a landmark moment, saying governments now recognize wildlife trafficking and illegal mining as serious forms of transnational organized crime that need a coordinated international response.
The resolution also recognizes the role of Indigenous Peoples and local communities in combating crimes that affect the environment, as Amazon Watch reported. That matters in practice. The people who live where timber is cut and gold is mined are often the first to see illegal activity and the most exposed to its violence.
Why now? Environmental crime is lucrative. The scale is visible in enforcement alone: INTERPOL’s Operation Thunder 2025 spanned 134 countries, rescued nearly 30,000 live animals and identified more than 1,100 suspects. The Environmental Investigation Agency welcomed the vote as a step toward treating these offenses with the same cooperation tools used against other organized crime.
Enforceability
How enforceable will the environmental crime protocol be?
Sign. Ratify. Enforce.
Direct Answer
The environmental crime protocol will be only as enforceable as the countries that ratify it make it. There is no UN police force behind it. Its real strength would come from requiring ratifying states to treat these offenses as serious crimes, which unlocks UNTOC tools for extradition, mutual legal assistance and asset recovery.
Enforceability is the right question to ask, and timing comes first. The Wildlife Conservation Society expects the text to be negotiated over the coming two years, with ratifications after that, so realistically the environmental crime protocol is a late-decade instrument, not a 2027 one. Beyond timing, how much it can be enforced depends on four things.
1. Only countries that ratify it are bound
Like every UNTOC protocol, the environmental crime protocol would bind only states that ratify it, a point the Igarapé Institute authors stress in Mongabay. Negotiations come first, then signature, then each country’s own ratification process. A protocol also needs a minimum number of ratifications before it enters into force.
2. The “serious crime” threshold does the heavy lifting
UNTOC’s cooperation machinery applies to “serious crime,” meaning offenses punishable by four years or more in prison. As The Globe and Mail explains, much environmental crime in many countries falls below that bar. Canada’s wildlife trafficking offense clears it, with a maximum of five years. If the environmental crime protocol pushes countries to raise penalties above the threshold, extradition, joint investigations and asset tracing become available. That is where most of its force would come from.
3. The United States opposed it
According to Igarapé Institute commentary, the United States was among the countries that sought to dilute the initiative. Unless that position changes, American ratification of the environmental crime protocol is unlikely, so it would add no new legal obligations here. The more realistic effect on American companies is indirect: trading partners that ratify will tighten customs checks, documentation demands and supply chain scrutiny. The next section weighs both sides of that position.
4. Enforcement will land at borders and in supply chains
Several countries that pushed for the environmental crime protocol have the least capacity to police remote forests and mines. Its practical bite will depend on importing countries checking what crosses their borders, and on companies refusing to buy what they cannot trace. That is where an environmental management system comes in.
| What the protocol could do | What it cannot do |
|---|---|
| Set common definitions of wildlife, timber, mineral and waste trafficking offenses | Arrest anyone or impose penalties on its own |
| Push ratifying states toward penalties above the four-year serious crime threshold | Bind any country that does not ratify |
| Open extradition, mutual legal assistance and asset-recovery tools between parties | Fund enforcement in countries without the capacity to investigate |
| Give customs and prosecutors a shared legal basis for cross-border cases | Replace national laws such as the U.S. Lacey Act |
The bottom line: expect the environmental crime protocol to work like the other UNTOC protocols. It will be useful between countries that join, uneven in practice and strongest at the point of import.
Common Language
Why does the environmental crime protocol need shared definitions and trusted science?
Define. Measure. Trust.
Direct Answer
The environmental crime protocol exists because countries define and punish the same harm differently, so traffickers exploit the gaps. Shared definitions and trusted, verifiable science are what let a crime in one country be recognized, investigated and proven in another. That is the same reason International Standards begin with defined terms.
The resolution itself spells out what is at stake. As reported by Mongabay and republished in the Los Angeles Times, it states:
“Crimes that affect the environment may also have a negative impact on the rule of law, economies, sustainable development, public health, human safety, food security, livelihoods and habitats.”
— UNTOC COP13 resolution, October 23, 2026
That list reaches far beyond wildlife. It touches public health, food security and the livelihoods of people who never see a trafficker. The obstacle to fighting it is not only political will. It is language.
“Different jurisdictions end up speaking different legal languages, with some environmental offences being criminalized in one country but not the other.”
— Alice Pasqualato, Wildlife Conservation Society
“[The decision] sends a powerful message that governments recognize the scale, seriousness and interconnected nature of environmental crime.”
— Mark Jones, Head of Policy, Born Free
“This is a greater reason for International Standards on definitions and trusted science resources.”
— Diana Lynn, President and Principal ISO Consultant, MSI
Definitions come first in every ISO standard
Every ISO management system standard opens its requirements with terms and definitions, because a requirement nobody can define is a requirement nobody can meet. ISO 14001:2026 Clause 3.2.7, for example, defines prevention of pollution precisely. The whole environmental vocabulary is collected in ISO 14050:2020, Environmental management – Vocabulary.
Those definitions are agreed by consensus among ISO’s national member bodies worldwide. That is why an ISO 14001 certificate means the same thing in Brazil, Ghana and Georgia. The environmental crime protocol needs the same kind of shared language for “timber,” “trafficking” and “illegally harvested” if a case built in one country is to hold up in another. MSI explains how consensus standards work in voluntary ISO standards.
Trusted science turns suspicion into proof
Definitions are only half of it. Prosecutors also need evidence that a court will trust. The Forest Policy Trade and Finance Initiative notes that a U.S. timber prosecution involved the first use of tree DNA evidence in a federal criminal trial. Species identification, wood forensics and origin testing are what move a case from a hunch to a verdict.
Management systems run on the same principle. Evidence-based decision making is one of the quality management principles behind ISO standards, and it applies just as much to your supply chain. If your supplier specification names species by scientific name and requires a verifiable country of harvest, you are speaking the same language a prosecutor would. See MSI’s guide to evidence-based decision making.
The U.S. Position
Why did the United States oppose the environmental crime protocol?
Listen. Weigh. Decide.
According to the Igarapé Institute commentary, the United States, Argentina, Saudi Arabia and Iran sought to dilute the initiative and did not succeed. As of October 27, 2026, I could not find a detailed public U.S. explanation of its vote on the environmental crime protocol, so I will not put words in the delegation’s mouth.
Both sides have serious arguments. Skeptics of new treaty obligations generally raise national control over criminal law, the risk of duplicating existing instruments such as the Convention on International Trade in Endangered Species (CITES), and the cost of new commitments. The United States also already has one of the strongest import-side laws in the world in the Lacey Act. Supporters answer that gaps between national laws are exactly what lets criminals launder illicit gold, timber and wildlife into legitimate markets, and that only common offenses close those gaps.
MSI’s lesson does not depend on how that debate ends. Whatever happens in Vienna, U.S. law already applies to what American companies buy. The cases below prove it, years before any environmental crime protocol could apply.
No Ratification, No Excuse
Can a country that never ratifies the environmental crime protocol still be held liable?
Prevent. Protect. Answer.
Direct Answer
Yes, in principle. A country that never ratifies the environmental crime protocol is not bound by it, but customary international law already requires every country to prevent activities in its territory from causing significant environmental harm to another country. The International Court of Justice confirmed in July 2025 that breaching that duty can carry legal responsibility.
A treaty binds only the countries that agree to it. That is a basic rule of international law, set out in Article 34 of the Vienna Convention on the Law of Treaties. On its own, the environmental crime protocol cannot reach a country that stays out.
“Even if a country does not ratify the treaty, if it causes harm to another country, it should still be liable. Harm does not stop at a border, and neither should responsibility.”
— Diana Lynn, President and Principal ISO Consultant, MSI
International law already agrees with much of that. Customary international law binds every country, signed or not, and one of its oldest rules is the “no-harm” principle.
- Trail Smelter (1941). An international arbitration panel held Canada responsible for smelter fumes that damaged farms in Washington State. See the arbitral award summary.
- Pulp Mills (2010). The International Court of Justice confirmed that countries owe a duty of due diligence to prevent significant cross-border environmental harm. See the ICJ case page.
- Climate advisory opinion (July 23, 2025). The court said these duties apply to all countries, treaty or not, and that a breach can carry legal responsibility. The IISD analysis explains the opinion.
The weakness is enforcement, not principle. Holding a country responsible usually means a case before the International Court of Justice, which requires that country to accept the court’s jurisdiction. Many countries do not accept it for disputes like these.
The people and companies behind the harm are easier to reach. The country where the harm happens can prosecute under its own laws, and importing countries can prosecute foreign companies whose goods enter their markets. Sunseeker is a British company, and it pleaded guilty under the U.S. Lacey Act without any treaty. What the environmental crime protocol would add is easier extradition and evidence-sharing between the countries that join.
Prevention of pollution: the same idea inside your organization
“The primary purpose of ISO 14001 is prevention of pollution.”
— Diana Lynn, President and Principal ISO Consultant, MSI
Clause 5.2 c) of ISO 14001:2026 requires top management’s environmental policy to include a commitment to protect the environment, including prevention of pollution. Clause 3.2.7 defines prevention of pollution as using processes, practices, materials or energy to avoid, reduce or control the creation, emission or discharge of any pollutant or waste. Informative Annex A.5.2 explains that the commitment aims to prevent adverse impacts through prevention of pollution and to protect the natural environment from harm.
Waste trafficking is one of the four crimes the environmental crime protocol targets, and it is pollution moved across a border. An ISO 14001-certified organization does not need a treaty to be bound to prevent that harm. Its own policy already binds it, wherever its waste, materials or suppliers end up.
U.S. Cases in 2026
Where is environmental crime being prosecuted in the United States today?
Trace. Prove. Prosecute.
Direct Answer
Without any environmental crime protocol, U.S. prosecutors already use the Lacey Act, first enacted in 1900 and expanded in 2008 to cover plants and timber taken in violation of foreign law. Four 2026 cases involve smuggled plywood, Myanmar teak in yachts, live reptiles and endangered-species remains.
The Department of Justice explains that since 2008 the Lacey Act has made it illegal to import plants and plant products harvested and exported in violation of another country’s laws. Importers of covered plant products must also file a Lacey Act declaration with USDA APHIS. Here is what enforcement looked like in 2026.
| Case (2026) | What happened | Outcome | Management-system lesson |
|---|---|---|---|
| Boise Cascade | Florida distribution center bought about $30 million of Chinese plywood that a supplier transshipped through Malaysia and declared falsely, 2018–2021 | Felony Lacey Act plea, April 27; $6,382,000 fine, five years’ probation, compliance plan | A supplier’s known history must become a record, a risk and an action |
| Sunseeker | UK yacht builder used illegally harvested Myanmar teak, in violation of British law, then sold the yachts into the U.S. | Pleaded guilty to Lacey Act violations, May 11; sentencing set for August 20 | Foreign law travels with the product, deep inside finished goods |
| Oxnard reptile ring | At least 1,700 reptiles smuggled from Mexico, Hong Kong and elsewhere over six years, deals made on social media | 65 months in prison, announced May 29 | Informal online sourcing is still sourcing |
| Massachusetts remains case | Remains of orangutans, Javan leopards and other protected species ordered from poachers in Cameroon and Indonesia | Eight months in prison and a $75,000 fine | Undeclared imports are a choice, not an oversight |
Boise Cascade: the supplier lied, the buyer still paid
This is the case every purchasing and EHS team should study. The Department of Justice fined Boise Cascade $6,382,000, twice its gross profits from the illegal wood, and required a compliance plan. It was the third federal criminal action from the same duty-evasion scheme. Analysts at Akin Gump note the plea rested on willful blindness toward the supplier’s smuggling and false declarations, even though the supplier made the false statements.
The company was not even the importer of record, as Harris Sliwoski points out. Convenient shipping terms that let a supplier handle customs did not move the responsibility off the buyer.
Sunseeker: foreign law travels with the product
In United States v. Sunseeker International, the timber was not sold as timber. It was decking inside luxury yachts. The teak was illegally harvested in Myanmar, the use violated British law, and the yachts were sold into the United States. If your organization buys finished goods that contain wood, the legality of that wood is part of your compliance picture.
Live wildlife and remains: the trade is personal and online
The Oxnard case involved Yucatán box turtles, baby crocodiles and Mexican beaded lizards bought through social media and driven across the border at El Paso. The Massachusetts case involved remains of critically endangered animals ordered from poachers abroad. These are smaller operations, but the pattern is the same: undeclared goods, foreign harvest and a buyer who chose not to ask.
“Today’s guilty plea and sentence make clear that companies that turn a blind eye to fraud in pursuit of profit will be held accountable.”
— U.S. Department of Justice, Boise Cascade announcement, April 2026
Enforcement is getting organized
At the APEC Forestry Ministerial in July 2026, the Justice Department described a TIMBER Working Group and a timber trafficking task force coordinating with an interagency interdiction board. It also cited a three-part workshop series with Indonesia. Meanwhile, The Wildlife Society has urged the U.S. Sentencing Commission to make wildlife trafficking sentencing a priority, arguing the trade still operates as “high-reward, low-risk.”
Willful Blindness
What does willful blindness mean for your management system?
See. Record. Act.
The environmental crime protocol targets traffickers, but the Lacey Act already reaches buyers, and willful blindness is how buyers get caught. Willful blindness is the legal name for a management system failure everyone recognizes. Someone saw a red flag. It never became a record, a risk, a decision or a corrective action. Procedures existed on paper, but they did not work in practice.
After 28 years and 200+ audits attended, I can tell you this pattern is rarely about bad people. It is about systems that let inconvenient facts go nowhere. When the facts concern a supplier’s legality, the cost of letting them go nowhere is now measured in felony pleas.
“Having systems, acting on what the records are reporting, and never letting anyone deny the facts is what prevents good systems from deteriorating.”
— Diana Lynn, President and Principal ISO Consultant, MSI
Supply chain red flags that should always trigger a documented review include:
- Goods routed through a third country with no clear manufacturing reason (transshipment)
- Prices well below the market for the species, grade or origin
- A supplier that cannot or will not name the species and country of harvest
- A supplier with a history of customs problems or attempts to hide origin
- Shipping terms that keep customs records out of your hands
- Sudden changes in a supplier’s sub-suppliers, routes or documents
ISO 9001:2026 now asks top management to promote quality culture and ethical behavior in Clause 5.1.1 i), and Clause 7.3 e) makes people aware of it. I explain why that reaches every department in ISO 9001:2026 ethics requirements. For a practical list of conduct to stop, see MSI’s 200 negative ethics actions and our guide to an ethical supply chain under ISO 9001.
“I have always felt that integrity is at the center of all ISO standards.”
— Diana Lynn, President and Principal ISO Consultant, MSI
ISO 14001:2026
Which ISO 14001:2026 clauses already require you to watch your supply chain?
Determine. Control. Evaluate.
Direct Answer
ISO 14001:2026 does not mention the environmental crime protocol, but its requirements already cover the ground. Clause 6.1.3 requires you to determine compliance obligations, Clause 8.1 requires you to control or influence externally provided processes, and Clause 9.1.2 requires you to evaluate compliance and take action.
ISO 14001:2026 was published April 15, 2026, and the transition deadline MSI uses is April 2029; see the ISO 2026 transition deadline guide. The table separates what the standard requires from what is only a NOTE and from MSI’s own recommendations.
| Item | Where it comes from | Status |
|---|---|---|
| Determine environmental conditions such as biodiversity and ecosystem health as issues | ISO 14001:2026, 4.1 | Requirement |
| Determine interested parties’ requirements and which become compliance obligations | ISO 14001:2026, 4.2 c) | Requirement |
| Non-legal expectations become obligations once you decide to comply | ISO 14001:2026, 4.2 NOTE 2 | NOTE (no obligation) |
| Policy commitment to protect the environment and meet compliance obligations | ISO 14001:2026, 5.2 c) and d) | Requirement |
| Protection of biodiversity and ecosystems as a specific policy commitment | ISO 14001:2026, 5.2 NOTE | NOTE (no obligation) |
| Determine, access and document compliance obligations | ISO 14001:2026, 6.1.3 | Requirement |
| Carry out changes, such as a new supplier or sourcing country, in a planned manner | ISO 14001:2026, 6.3 | Requirement |
| Control or influence externally provided processes, products or services, and define the type and extent | ISO 14001:2026, 8.1 | Requirement |
| Determine environmental requirements for procurement and communicate them to external providers | ISO 14001:2026, 8.1 b) and c) | Requirement |
| Evaluate compliance at a set frequency and maintain knowledge of compliance status | ISO 14001:2026, 9.1.2 | Requirement |
| Review changes in compliance obligations and trends in meeting them | ISO 14001:2026, 9.3.2 b) 2) and d) 3) | Requirement |
| Declare covered plant products on import | U.S. Lacey Act (USDA APHIS) | U.S. legal requirement for covered imports |
| Monitor the environmental crime protocol negotiations as an external issue | MSI recommendation | Recommended |
| Audit or verify high-risk timber, mineral and wildlife-derived suppliers | MSI recommendation | Recommended |
Clause 6.1.3: put the Lacey Act on the register
Clause 6.1.3 requires you to determine and have access to compliance obligations related to your environmental aspects, and to keep them as documented information. If you import or buy wood, paper, plant products or wildlife-derived materials, the Lacey Act and CITES belong on that register. Our guide to ISO 14001 environmental aspects shows how purchased materials connect to aspects in the first place.
Clause 8.1: define control over what you buy
Clause 8.1 requires that externally provided processes, products or services relevant to the EMS are “controlled or influenced,” with the type and extent defined. Consistent with a life cycle perspective, you must also set environmental requirements for procurement and communicate them to external providers. MSI covers this in depth in ISO 14001 externally provided processes and the ISO 14001 life cycle perspective.
Clause 9.1.2 and 9.3: evaluate, then tell leadership
Clause 9.1.2 requires a process to evaluate whether you are meeting compliance obligations, at a frequency you determine. Clause 9.3.2 then puts changes in those obligations, and trends in meeting them, in front of top management. The environmental crime protocol is exactly the kind of external change that belongs in that review. See ISO 14001:2026 management review for the inputs and outputs.
Clause 4.1 also asks you to consider environmental conditions such as biodiversity and ecosystem health. Illegal logging and mining are direct threats to both. Our articles on ISO 14001 Clause 4.1 and biodiversity under ISO 14001:2026 show how to document those issues, and your environmental policy is where the commitment starts.
“If your environmental policy says you will not harm the environment or people, then knowingly exceeding what the science has proven harmful puts you in conflict with your own policy.”
— Diana Lynn, President and Principal ISO Consultant, MSI
From the Field
Why does supply chain legality matter to me personally?
Protect. Preserve. Restore.
I once worked as a procurement agent for a utility company. Wood poles were something we bought all the time, and environmental protections for owl habitat affected our supply of them. I visited many wood pole treatment facilities. That job taught me that the environment is never abstract in a supply chain. It shows up in what you can buy, from whom and under what rules.
I grew up in Northern California among the Redwoods, Yosemite and Lake Tahoe. I still believe the cheapest protection is the harm you never cause. That idea runs through MSI’s Gross Domestic Regeneration work and our guide to ISO 14001 for utilities.
“Protect before you restore. The cheapest health benefit an organization will ever deliver is the harm it never caused to something that was already good.”
— Diana Lynn, President and Principal ISO Consultant, MSI
Having attended 200+ audits, many of them from the registrar’s side of the table, I have seen how findings arise. The organizations that do well are rarely the ones with the thickest manuals. They are the ones where a buyer who notices something odd knows exactly where to write it down, and knows someone will act. That kind of system will matter long before the environmental crime protocol takes effect. For more on building it, see climate-resilient supplier networks and MSI’s supplier management program guide.
Original Tool
How can you score whether your supply chain is being watched?
Watch. Verify. Protect.
I built the MSI Supply Chain Watch Checklist for this article to turn the environmental crime protocol news into ten questions you can answer this week. Score each item 0 (not in place), 1 (partly in place) or 2 (in place, with records to prove it).
| # | Checklist item | Clause | Evidence to look for |
|---|---|---|---|
| 1 | Compliance obligations register names the Lacey Act, CITES and import rules for every timber, plant and wildlife-derived material you buy | 6.1.3 | Register entries, owners, review dates |
| 2 | Each covered material is traced to species and country of harvest | 8.1 b) | Supplier declarations, harvest documents |
| 3 | Legality and environmental requirements appear in purchase orders and supplier agreements | 8.1 c) | PO terms, signed supplier agreements |
| 4 | The type and extent of control over each high-risk supplier is defined | 8.1 | Supplier risk tiers, control plans |
| 5 | Red flags such as transshipment or below-market prices trigger a documented review | 6.1.4, 10.2 | Review records, corrective actions |
| 6 | Supplier and route changes are approved in a planned way before use | 6.3 | Change requests, approvals |
| 7 | Compliance evaluation covers supplier-related obligations at a set frequency | 9.1.2 | Compliance evaluation results |
| 8 | Internal audits sample legality records, not just the approved supplier list | 9.2 | Audit plans, audit evidence |
| 9 | Management review receives trends in meeting compliance obligations | 9.3.2 d) 3) | Review inputs and minutes |
| 10 | Someone is assigned to watch regulatory and treaty developments, including the environmental crime protocol, and report changes | 4.1, 9.3.2 b) | Assigned owner, update log |
| Total score | Rating | What to do next |
|---|---|---|
| 16–20 | Watching | Your system works in practice. Keep the records current and re-score after each management review. |
| 10–15 | Partly watching | Blind spots exist. Close the lowest-scoring items first and schedule a planning session. |
| 0–9 | Blind spots | Treat supply chain legality as a priority risk under 6.1.4 and put it on the next management review agenda. |
Re-score when the environmental crime protocol draft text appears, since its definitions may change what counts as high risk. If you are also transitioning to the 2026 edition, pair this checklist with MSI’s free ISO Transition Risk Scorecard.
Watch List
What should you watch as the environmental crime protocol is negotiated?
Watch. Ask. Speak.
Direct Answer
Watch five things over the next two years: the committee drafting the environmental crime protocol, how it defines offenses and corporate liability, which countries ratify it, U.S. Lacey Act enforcement, and your own suppliers. Public coverage of UN meetings and Justice Department announcements make most of this easy to follow.
I am asking you to do more than read this article. Watch what happens. Treaties are shaped by the people who pay attention while they are being written, and the environmental crime protocol will be written over the next two years. Here is where to look.
- The negotiating sessions. Follow the committee through the UNODC convention bodies page, the Earth Negotiations Bulletin coverage and UN Web TV, which broadcasts many UN meetings.
- The definitions. Watch whether the environmental crime protocol covers timber products as well as logs, holds companies (not only individuals) liable, and how it treats a buyer who “should have known.” Those three choices matter most to businesses.
- The ratifications. Track which of your sourcing countries and customer countries ratify the environmental crime protocol. A ratifying customer country can change its import checks overnight.
- U.S. enforcement. Watch Justice Department environment and natural resources announcements for new Lacey Act cases, and any change to APHIS declaration requirements.
- Your own supply chain. This is the one you control. Re-score the checklist above every quarter.
And if you see something, speak up through the right channel. The U.S. Fish and Wildlife Service explains how to report wildlife crime. Inside your organization, the right channel is your corrective action process. Share this article with your purchasing, EHS and leadership teams so they are watching too.
For MSI’s proposed outline of the treaty text and how companies can have a say, read Environmental Crime Treaty: The Proven ISO 14001 Blueprint.
For a short leadership view of what ISO 14001 asks of an organization, watch the free ISO 14001 Executive Brief on MSI’s ISO Executive Decision Briefs page.
Pass It On
This is a world problem. Share it with someone who can help.
Send this article to your purchasing, EHS and leadership teams, your suppliers, and anyone who cares about forests and wildlife. The more people watching, the harder it is for environmental crime to hide in a supply chain.
Next Steps
How does ISO consulting turn watching into a working system?
Plan. Build. Sustain.
Watching the environmental crime protocol is the start. A management system makes watching routine, assigned and recorded, so nothing depends on one person noticing. That is the work of ISO consulting: building procedures that work in practice rather than on paper. Management Systems International (MSI), veteran-owned and female-owned since 1998, brings 28 years of experience, 80+ certifications supported, 200+ audits attended and 600+ professionals trained to that work.
Organizations typically report that the hardest part is not writing a supplier procedure. It is making sure the procedure catches the red flag a buyer sees on a Tuesday afternoon. MSI client experience suggests the fix is usually a few clear controls, assigned owners and a regular review, not more paperwork. Learn about MSI’s ISO 14001 consulting services, and see what ISO certification costs.
Start Here: ISO Procedure Templates That Work in Practice
Write supplier control, compliance evaluation and corrective action procedures from proven MSI templates instead of a blank page. The hub shows every template family by standard so you can start with what your system is missing.
Update Your EMS to ISO 14001:2026 in a Week
The ISO 14001:2026 Procedure Templates & Guides bundle was built to help experienced EHS managers update their ISO 14001:2015 system to 2026 in a week’s time, including compliance obligations, external provider control and compliance evaluation.
Train Auditors Who Look Past the Approved Supplier List
MSI’s ISO 14001:2026 Internal Auditing course is self-paced and meets the 16-hour training requirement. Your team learns to sample the records that show whether supplier controls actually work.
Put Compliance Trends on the Management Review Agenda
Clause 9.3 requires leadership to review changes in compliance obligations and trends in meeting them. MSI’s Management Review Toolkits give you the inputs, agenda and records ready to use.
Let MSI Audit the Suppliers You Can’t Visit
Through SureResults, MSI performs internal audits on an ongoing basis and supplier audits for clients across ISO 9001, 13485, 14001, 45001 and 7101, so high-risk sources get independent eyes.
Book a Free Planning Session
Not sure where your supply chain blind spots are? Talk with MSI for 30 minutes about your current state and the next three moves. Call 760-434-9141 or book online.
Already certified and short on time? MSI’s ISO 14001:2026 Procedure Update Service updates your existing documents, and the ISO 14001:2026 Transition course walks your team through every change. MSI also offers internal audit services; read why internal audits matter and our guide to environmental reporting requirements.
FAQ
Frequently asked questions about the environmental crime protocol
Ask. Answer. Act.
What is the environmental crime protocol?
The environmental crime protocol is a proposed additional protocol to the UN Convention against Transnational Organized Crime. It would target trafficking in wildlife and timber, illegal mining, mineral and precious-metal trafficking, and waste trafficking. Governments voted 83 to 12 on October 23, 2026, to begin negotiating it.
Is the environmental crime protocol legally binding?
Not yet. The environmental crime protocol is still to be negotiated. Once adopted, it will bind only the countries that ratify it, and each country will enforce it through its own laws, courts and customs agencies.
When will the environmental crime protocol be finished?
The environmental crime protocol is expected to be negotiated over about two years from the October 2026 vote. Ratification and entry into force would follow, so most practical effects are likely toward the end of the decade.
Does the environmental crime protocol apply to U.S. companies?
The environmental crime protocol would bind governments, not companies, and only those that ratify. The United States sought to dilute the initiative, so U.S. ratification is uncertain. U.S. companies are already bound by the Lacey Act, and customers in ratifying countries may tighten their own import checks.
Can a country that does not ratify the environmental crime protocol be held liable for environmental harm?
It is not bound by the environmental crime protocol itself, but customary international law requires every country to prevent significant environmental harm to other countries. The International Court of Justice confirmed this duty in 2010 and again in its July 2025 climate advisory opinion. Enforcing it against a country still depends on that country accepting a court’s jurisdiction.
What is the Lacey Act and who must comply?
The Lacey Act is a U.S. law first enacted in 1900. Since 2008, it has made it illegal to import, buy or sell plants and plant products, including timber, harvested in violation of another country’s laws. Anyone in the chain can be liable, and covered plant imports require a declaration filed with USDA APHIS.
How does ISO 14001 help with the risks the environmental crime protocol targets?
ISO 14001:2026 requires you to determine compliance obligations (6.1.3), control or influence externally provided processes (8.1), evaluate compliance (9.1.2) and review compliance trends in management review (9.3). Together they turn supply chain legality from a hope into a controlled, recorded process, whatever happens to the environmental crime protocol.
References
- Waisbich, Risso & Muggah (Igarapé Institute), “A rare victory for multilateralism in the fight against environmental crime,” Mongabay, October 2026
- Wildlife Conservation Society, “WCS Welcomes Landmark UN Decision to Launch Negotiations,” October 2026
- Amazon Watch, “Indigenous Peoples Secure Historic U.N. Agreement,” October 23, 2026
- The Globe and Mail, “Canada backs UN push to treat environmental crime as serious organized crime,” October 2026
- Environmental Investigation Agency via EuropaWire, “UN Crime Convention Parties Back Talks,” October 26, 2026
- Global Initiative Against Transnational Organized Crime, guidance note on a new UNTOC protocol, June 2025
- U.S. Department of Justice, Boise Cascade plea and sentencing, April 2026
- Akin Gump, “From Forest to Felony,” April 29, 2026
- Harris Sliwoski, “DDP Shipping Risks,” 2026
- U.S. Department of Justice, United States v. Sunseeker International Ltd., No. 26-CR-60078
- U.S. Department of Justice, California man sentenced to 65 months, May 2026
- E&E News, “Massachusetts man sentenced for wildlife trafficking,” April 6, 2026
- U.S. Department of Justice, remarks at the APEC Forestry Ministerial, July 28, 2026
- U.S. Department of Justice, U.S.–Indonesia timber and wildlife trafficking workshop, 2026
- The Wildlife Society, letter on sentencing for wildlife trafficking, July 24, 2026
- USDA APHIS, Lacey Act Declaration Requirements
- ISO, ISO 14001:2026 Environmental management systems
- ABC News / AP, Operation Thunder 2025 results
- CITES Secretariat
- Raman (Mongabay), “Countries take first step toward global crackdown on environmental crime,” Los Angeles Times, October 28, 2026
- Born Free, “UNTOC Takes Historic Step on Environmental Crime,” October 2026
- ISO 14050:2020, Environmental management – Vocabulary (Standards Council of Canada listing)
- ISO, Members
- Forest Policy Trade and Finance Initiative, U.S. Lacey Act
- Utrecht University, USA–Canada arbitral award: Trail Smelter case
- International Court of Justice, Pulp Mills on the River Uruguay (Argentina v. Uruguay)
- IISD, “Historic International Court of Justice Opinion Confirms States’ Climate Obligations”
- U.S. Fish and Wildlife Service, Report wildlife crime
- UNODC, UNTOC working groups
- IISD Earth Negotiations Bulletin, UNTOC COP13 coverage
About Management Systems International (MSI)
Diana Lynn is President and Principal ISO Consultant at Management Systems International (MSI), a veteran-owned, female-owned consulting firm she co-founded in 1998. With 28 years of experience including extensive AS9100 work in MSI’s early years, MSI’s track record includes 80+ certifications supported, 200+ audits attended, and 600+ professionals trained across manufacturing, technology, medical device, government, healthcare, and other regulated industries.
Today MSI implements ISO 9001, ISO 13485, ISO 14001, and ISO 45001, with an expanding focus on ISO 7101 healthcare quality.
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