Location: WA
Related projects: Biodiversity Conservation Act, Save Our Sandalwood,
The key issue
Since the 1840s the unsustainable exploitation of WA's beautiful, aromatic native sandalwood (Santalum spicatum) has been relentless and it continues today, although at much smaller volumes because the species has been wiped out across much of its original range. The species was listed as 'vulnerable' on the IUCN's Red List in 2021.
Over the past 25 years, the main exploiter of native sandalwood has been the Forest Products Commission (FPC). The FPC's wild take accounts for over 90% of the government-approved quota, set at 2,500 tonnes per annum (tpa), with up to 1,250 tpa of ‘green’ sandalwood coming from the uprooting of whole live trees. This equates to around 35,000 irreplaceable mature/old growth sandalwood trees destroyed each year.
The DBCA is now in the process of reviewing the Sandalwood Order (2015), which facilitates this exploitation by setting out the quota for how much sandalwood can be harvested (taken) each year. The order will be in effect until 31 December 2026.
The DBCA's review of the Sandalwood Order (2015) is open for public comment until 17 August 2026. After almost 200 years of destruction it is time to prioritise conservation over exploitation.
CCWA Position
- An ecologically sustainable, substantial reduction in the annual wild-take quota of WA sandalwood
- Traditional Owner enterprises to be licensed to take and use wild sandalwood and ensure regeneration on their lands
- The removal of the Forest Products Commission as the main recipient of DBCA-issued licences to take/supply sandalwood under the Biodiversity Conservation Act.
- McLellan. R., (2023). Thesis: Australian sandalwood is going extinct in the wild.
- Gowland, K. (2021). Santalum spicatum. The IUCN Red List of Threatened Species
- The Trees that were Nature's Gift. Irene Cunningham. (Out of print)
- DBCA (2026) Review of the Sandalwood (Limitation of Removal of Sandalwood) Order (No. 2) 2015. Download HERE
Make a Submission
The submission guide below will take you through what to expect from the online form and provides suggestions on how to ensure your submission can help bring sandalwood back from the brink.
Start the DBCA Online Submission Form
Check out the DBCA downloads list to learn more about the review process, download the draft review, and find out more about sandalwood in WA.
The responses provided in this guide are suggested answers that reflect Conservation Council of WA's position. You are welcome to use, adapt, or build on these responses in your own submission. You do not need to use the suggested wording, and we encourage you to submit your own views and experiences where relevant.
If you would like your submission to align with CCWA's position on the future of sandalwood, you can use the suggested responses provided throughout this guide.
Section 1) About the submitter
1) Name:
Your name
2) Name of organisation:
Conservation Council of WA / Your affiliated organisation / Leave blank
3) Email or postal address:
Your postal/email address
4) Postcode:
Your postcode
5) Would you like your submission to be anonymous?
Select desired option
6) How would you like your submission to be categorised?
Individual (NB: Unless submitting on behalf of an organisation)
7) What is your current involvement with wild sandalwood?
Conservation
8) What best describes your interest in sandalwood?
Conservation
9–10) Previous submission information to DBCA:
If you have previously made a submission on this topic to DBCA, please provide details here (if you would like the content of that submission to be considered).
Section 2) Your view on the draft recommendations
11) Do you support the draft recommendations as currently worded in the Draft Review Report?
Some support, but not all
12) Are there any recommendations that you would like to make specific comment on?
(Note that Sections 3–6 allow for comments on certain recommendations and these have therefore not been included in the template response below.)
Recommendation 2) I support this recommendation, but believe the proposed reform should go further. The regulatory distinction that gives the FPC an advantage over other operators should be removed entirely. The review acknowledges that FPC's take under the Forest Products Act is currently not legally constrained by the Sandalwood Order, despite FPC having access to up to 80% of the total removal limit. The review itself recognises that this is inconsistent with the intent of the Order. The regulatory framework should apply consistently to all commercial operators. In addition, Schedule 6, item 8 of the Environmental Protection Act 1986 should be removed so that sandalwood clearing undertaken under an FPC production contract is no longer exempt from the usual clearing approval framework. The FPC should not have a regulatory advantage over other operators or be able to commercially exploit wild sandalwood without equivalent environmental safeguards.
Recommendation 3) I do not support this recommendation as currently framed. A formal arrangement between DBCA and FPC may improve regulatory consistency, but it does not address the fundamental conflict created by FPC's role as both a government-owned commercial operator and the dominant harvester of a species in serious decline. The review acknowledges that FPC currently has access to up to 80% of the total Sandalwood Order removal limit. I do not believe the appropriate response is to formalise or strengthen this arrangement. Instead, the end of the current Sandalwood Order in 2026 should be used as an opportunity for FPC to exit the commercial wild sandalwood industry. DBCA should instead develop a management framework directly with Traditional Owners, Native Title holders and Aboriginal organisations, with strong independent oversight and a focus on conservation, restoration and sustainable Traditional Owner-led enterprises. (See Sections 6-8 for more details)
Recommendation 14) I do not support a 10-year Sandalwood Order in its proposed form. While I recognise that the annual harvest limits can be adjusted during the life of the Order, the review itself acknowledges that shorter durations are generally preferable where there are significant knowledge gaps, uncertainty and potential industry transitions. All three apply to wild sandalwood. Given the uncertainty around population condition, regeneration and recruitment, a shorter Order with mandatory independent reviews would provide a stronger opportunity to reassess whether harvesting remains sustainable and to respond to new evidence. A 10-year Order should not be used to provide certainty for continued commercial exploitation at the expense of conservation.
Recommendation 17) I support increased opportunities for Aboriginal people to access and benefit from wild sandalwood. However, I do not support the recommendation to retain a large commercial wild harvest to achieve this objective. The proposed allocation of 500 tonnes through BC regulation 67 licences should not be treated as a guaranteed entitlement or a basis for maintaining the current level of wild harvest. The overall quantity of wild sandalwood available for commercial harvest should be substantially reduced, with commercial wild take restricted to Traditional Owners exercising their rights and developing sustainable, First Nations-led enterprises. The allocation available to Aboriginal people should increase as the FPC exits the industry, rather than simply redistributing a declining resource while continuing the current level of exploitation. Aboriginal-led conservation, regeneration and caring-for-Country activities should also receive direct government funding and should not depend on continued commercial harvesting of living wild sandalwood.
Section 3) Annual take limits
13) Do you agree with the proposed recommended annual limit for sandalwood harvesting (of 750 tonnes for living [green] trees and 1,250 tonnes for dead sandalwood) that considers any proposed harvest should be sustainable and needs to include an appropriate level of seeding and monitoring?
No
14) Why or why not? What factors do you think are most important to ensure a suitable harvest limit?
I support that any proposed harvest should be sustainable, but do not agree that the proposed harvest limit of 750 tonnes per year for living [green] sandalwood has been demonstrated to be so. The overall wild sandalwood harvest limit should be drastically reduced, with no commercial wild take permitted other than by Traditional Owners. Traditional Owners should be supported to develop sustainable, First Nations-led sandalwood enterprises and to benefit from the resource on Country. This should not be used to justify continued large-scale commercial harvesting by the FPC or other non-Traditional Owner operators.
The review itself recognises that removing mature living trees can affect sandalwood's breeding system, genetic diversity, regeneration and habitat. It also identifies a serious risk of long-term decline if regeneration is not restored. The review's risk assessment found that the highest-ranked option for ecological sustainability was harvesting dead wood only, while scenarios with less living-tree harvest and a greater proportion of dead wood also performed better. The proposed 750 tonne limit appears to be a compromise between conservation and economic and social objectives, rather than the option that provides the best outcome for sandalwood's long-term survival. The review also acknowledges significant data limitations and knowledge gaps, including uncertainty around the current and future condition of sandalwood populations and the economic and social value of both harvesting and retaining wild sandalwood populations. Given the species' decline, slow growth, significant knowledge gaps and uncertainty in the available data, the precautionary principle should be applied.
The most important factors in determining a suitable harvest limit are: 1) the long-term health and persistence of wild sandalwood populations, rather than maintaining the maximum level of commercial take that modelling suggests may be possible, 2) the rate and success of natural regeneration and recruitment, including whether sufficient young sandalwood is successfully progressing into larger size classes to replace mature trees being lost, 3) the retention of mature, seed-bearing trees needed to support pollination, genetic diversity and future regeneration, the cumulative impact of removing living and dead sandalwood, recognising that dead wood also has ecological functions and should not automatically be treated as an independent or unlimited resource, 4) regional differences in population structure, regeneration, threatening processes and climate conditions, with harvest limits adjusted accordingly rather than relying on a single statewide limit, 5) the quality and reliability of population data and modelling, with uncertainty treated as a reason for greater caution, 6) the impacts of climate change and other threatening processes, including grazing and other factors that may limit regeneration and recruitment, transparent, independent and ongoing monitoring of harvested and unharvested populations, including population size, age and size structure, mortality, regeneration and recruitment, 7) clear and enforceable triggers for reducing or suspending harvest if monitoring identifies declining populations or inadequate regeneration, 8) a requirement for regeneration and restoration to be additional to, rather than dependent upon, continued commercial harvesting as conservation actions should not rely on the continued removal of living trees to generate the funds needed to conserve the species and 8) a transition towards plantation resources and reduced reliance on wild take, while supporting First Nations-led opportunities to participate in and benefit from a sustainable sandalwood industry.
I support that strong, transparent and independent monitoring should be required, with clear triggers to reduce or stop harvesting if populations or regeneration decline. However, I do not agree with the proposed recommended annual limit for sandalwood harvesting, as outlined by the review.
Section 4) Rollover of unused quantities
15) Should up to 50% of unused sandalwood quantities be able to be carried over to the next year?
No
16) What benefits or risks do you see with this approach?
The purpose of a maximum annual harvest limit should be to limit the pressure placed on wild sandalwood populations in any one year and to ensure that harvesting is consistent with the ecological conditions of the species and its habitat. Allowing up to 50% of an unused allocation to be carried over could enable substantially more sandalwood to be harvested in a subsequent year. This could increase harvesting pressure at a time when populations may already be under additional stress from drought, climate change, fire, grazing and other threatening processes. It could also result in more mature living trees being removed from the landscape than would otherwise occur under a strict annual limit. If environmental conditions are unsuitable for harvesting in a particular year, the appropriate response should be to reduce or suspend harvesting, not to create an incentive to make up the difference in a subsequent year. The fact that sandalwood harvesting is subject to seasonal access constraints and operational challenges should not outweigh the need to protect a slow-growing, long-lived species that is already in serious decline.
A strict annual limit also provides a clearer basis for monitoring the relationship between the amount harvested and the condition of wild sandalwood populations. This is particularly important if the new Order is intended to operate adaptively and respond to new information about population condition, regeneration and threatening processes. The proposed annual limit should therefore be treated as a maximum, not a target or an entitlement. Any unused allocation should remain unharvested and should not be carried forward.
Section 5) Minimum size for harvest of living sandalwood trees
17) Do you have any ideas or suggestions for changing this regulation?
I do not support any changes to this regulation that would facilitate the continued take of living wild sandalwood other than demonstrably sustainable harvesting by Traditional Owners. Sandalwood is a slow-growing, long-lived species in serious decline, with inadequate regeneration and recruitment across much of its range. Mature living trees are essential for seed production, pollination, genetic diversity and future regeneration and should be retained in the landscape. I recognise that the review has identified a technical inconsistency between the over-bark and under-bark measurements and that further research may be needed to address this. However, any amendment to the regulation should not be used to justify or facilitate the continued harvesting of living wild sandalwood. And if the regulation is amended, it should ensure that the change does not result in smaller living trees becoming available for harvest.
18) What do you think should be considered when making this decision?
The minimum size regulation should not be considered in isolation from the wider question of whether living wild sandalwood should be harvested at all. Given the species' threatened status, historic over-exploitation, slow growth, poor regeneration and ongoing threats from climate change, grazing, fire and habitat loss, the priority should be to phase out commercial harvesting of living wild sandalwood and transition the industry towards plantation resources and sustainable First Nations-led enterprises, while protecting and restoring wild populations.
Section 6) Traditional Owner harvest planning
19) How can DBCA better engage with Aboriginal representative bodies/corporations to better plan for sustainable harvesting of sandalwood?
DBCA should engage with Aboriginal representative bodies, Native Title holders, Traditional Owner corporations and Aboriginal businesses as genuine partners in sandalwood management, rather than simply consulting them about the allocation of commercial harvest quotas. However, this cannot be achieved while the Forest Products Commission (FPC) remains the dominant commercial harvester and a government-backed competitor in the wild sandalwood industry. The continued role of the FPC is a significant barrier to the development of a more equitable and sustainable Aboriginal-led sandalwood industry. The FPC is a government-owned commercial entity with a commercial interest in maintaining access to and selling wild sandalwood. Its role is fundamentally different from that of Traditional Owners and Aboriginal organisations seeking to care for Country, exercise Native Title rights and develop sustainable, locally based enterprises. The end of the current Sandalwood Order in 2026 provides an opportunity to change this model. The FPC should exit the sandalwood industry at the end of 2026. DBCA should instead work directly with Traditional Owners, Native Title holders, RNTBCs, Aboriginal representative bodies and Aboriginal corporations to develop a new management framework that prioritises conservation and Aboriginal leadership.
This should include: 1) Ending FPC's role as a commercial harvester of wild sandalwood after 2026, rather than continuing to allocate the majority of the available resource to a government-owned commercial entity, 2) Ensuring that the departure of FPC is not conflated with the end of Aboriginal participation in the industry. Aboriginal-led sandalwood enterprises can and should continue to develop independently of FPC, 3) Moving towards direct relationships between DBCA and relevant Aboriginal organisations, rather than relying on FPC as an intermediary or provider of Aboriginal employment and contracting opportunities, 4) Ensuring that Aboriginal organisations have a genuine role in decision-making, not simply consultation after key decisions have already been made, including decisions about where and whether harvesting occurs, 5) Supporting Aboriginal-led population inventories and monitoring, including localised assessments of sandalwood population structure, regeneration and recruitment, 6) Supporting Aboriginal-led regeneration and restoration programs, including seeding, feral animal control, fire management and other activities that address barriers to sandalwood recruitment, 7) Providing direct, long-term government funding for Aboriginal-led conservation and caring-for-Country programs, rather than requiring conservation and regeneration to be funded through continued commercial harvesting of wild sandalwood, 8) Ensuring equitable access to technical expertise, data and resources so Aboriginal organisations can develop their own sustainable management and business plans, 9) Supporting Aboriginal-owned and Aboriginal-led businesses to develop sustainable sandalwood enterprises based increasingly on plantation-grown sandalwood and other renewable resources, rather than relying on the continued extraction of declining wild populations
While the review identifies real economic and employment benefits associated with the current sandalwood industry, including benefits to some Aboriginal communities, these benefits should not be used to justify the continuation of the current FPC-dominated model. The State can support Aboriginal employment, economic development and caring for Country without requiring Aboriginal businesses to participate in or depend upon an unsustainable level of wild sandalwood extraction. The transition away from FPC should be seen as an opportunity to increase, rather than reduce, Aboriginal involvement in sandalwood.
Section 7) Improving engagement
20) What do you think DBCA could do to improve how it engages with the public, Aboriginal people, and stakeholders in future sandalwood-related consultations or reviews?
DBCA should ensure that future sandalwood consultations are transparent, genuinely independent and capable of influencing the final outcome. The current review process raises concerns about the extent to which the public consultation process can meaningfully influence decision-making when the Forest Products Commission (FPC), the dominant commercial harvester of wild sandalwood, has been closely involved in the development of the proposed management arrangements. FPC has a direct commercial interest in the outcome of the review and should not have a privileged role in determining the future management of the resource it commercially exploits. Future reviews should clearly separate the roles of the regulator, commercial operators and stakeholders with an interest in the resource. All stakeholders should have equitable access to the evidence, modelling, assumptions and data underpinning proposed harvest limits and management arrangements. Where information is contested, the competing evidence and views should be transparently presented in the consultation materials.
Section 8) Additional information
21) Is there anything else that you would like to be included in the final version of reports for the review of the Sandalwood Order?
The final review should explicitly consider the future role of the Forest Products Commission (FPC) and recommend that it exit the sandalwood industry at the end of the current Sandalwood Order in 2026. The draft review acknowledges that FPC's take under the Forest Products Act is not legally constrained by the Sandalwood Order and that this is inconsistent with the intent of the Order. It also acknowledges that most wild sandalwood harvesting currently occurs outside the direct control of the Biodiversity Conservation Act.
As a government-owned commercial entity with an interest in maintaining access to the resource, its role creates an inherent conflict with the need to protect and restore a species in serious decline and listed as threatened on the IUCN Red List. The FPC was established to support the development of the forest products industry and facilitate long-term private sector investment. WA now has a significant and growing plantation sandalwood industry, alongside established and emerging Aboriginal-owned and Aboriginal-led businesses. The continued dominance of a government-owned commercial operator is therefore no longer necessary and constrains the development of a more diverse, equitable and sustainable industry. The final review should therefore explicitly consider whether the FPC should continue to have a role in the commercial exploitation of wild sandalwood at all, rather than assuming that its future role is to be maintained through improved regulation or coordination with DBCA.
The final reports should also recognise that seeding programs cannot be assumed to compensate for the ongoing removal of mature, slow-growing trees. The conservation value of retaining mature trees, the long timeframes required for recruitment to maturity, and uncertainty about long-term regeneration outcomes must be central to decisions about future wild harvest.
The end of the current Sandalwood Order provides an important opportunity to transition away from FPC-led exploitation of wild sandalwood, prioritise conservation and Aboriginal stewardship, and support a more diverse industry based increasingly on plantation resources and Aboriginal-led enterprises.
22 - 23) Option to include 2 attachments to be considered as part of your submission
Leave blank
24) Is there anything else you would like to mention?
Leave blank
Section 9) Follow up
25) If we need to clarify any details about your submission, please indicate your preferred method of contact.
Select desired response
26) Phone number:
Provide if selected in Question 25
27) Email:
Provide if selected in Question 25
28) Would you like to be kept informed of future sandalwood matters?
Yes / No