Location: WA
Related projects: Biodiversity Conservation Act, Save Our Sandalwood, Back from the Brink: A Protection Agenda for Nature
The key issue
Since the 1840s the unsustainable exploitation of sacred and aromatic native sandalwood (Santalum spicatum) has been relentless in WA 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 35,000-40,000 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 mined 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 31 August 2026. After almost 200 years of destruction it is time to prioritise conservation over exploitation.
Conservation Council of WA's Position
- An ecologically sustainable, substantial reduction in the wild-take quota of WA sandalwood to 200-300 tonnes per annum
- Wild-take quotas be allocated exclusively to Traditional Owner enterprises, operating under approved management plans
- The removal of the Forest Products Commission as the recipient of any DBCA-issued licences to take/supply sandalwood under the Biodiversity Conservation Act.
- McLellan, R., (2023). The ecological implications of the loss of a keystone species: Australian sandalwood, a case study
- Gowland, K. (2021). Santalum spicatum. The IUCN Red List of Threatened Species
- Cunningham, I. (1998) The Trees that were Nature's Gift.
- DBCA (2026) Review of the Sandalwood (Limitation of Removal of Sandalwood) Order (No. 2) 2015.
- Conservation Council WA. (2026). DUTJAHN - 170 Years On: The Future of WA’s Native Sandalwood - CCWA Environment Matters
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 the Conservation Council of WA (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:
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. NB: Required question
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) All sandalwood removal should be subject to the same legal limits and environmental safeguards. The regulatory distinction that gives the FPC an advantage over other operators should be removed entirely. DBCA should not delay action to close this decade old regulatory gap.
- Recommendation 3) Do not formalise the FPC-DBCA agreement. End it. A formal agreement does not resolve the fundamental conflict of the FPC being both a government regulator/agency and the dominant commercial harvester of a declining native species. FPC should exit the wild sandalwood industry by the end of 2026. DBCA should instead develop a management framework directly with Traditional Owners.
- Recommendation 14) A 10-year Sandalwood Order is too long given the uncertainty around wild sandalwood populations. Shorter terms with mandatory independent reviews would allow the government to respond to new evidence about population condition, regeneration and threats. A 10-year Order should not be used to provide certainty for continued commercial exploitation at the expense of conservation.
- Recommendation 17) This recommendation does not support a genuine Aboriginal-led model and should be rejected as it effectively reserves most of the wild sandalwood take for FPC while limiting First Nations enterprises to a much smaller share of the resource. Aboriginal access should increase as FPC exits the industry, rather than simply redistributing a declining resource while continuing unsustainable exploitation. Aboriginal-led conservation should receive direct government funding and 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?
The proposed 750-tonne green sandalwood quota is still far too high and risk locking in continued industrial-scale mining of a slow-growing, threatened native species. The wild take should be reduced to a precautionary 200–300 tonnes per year, consistent with advice provided during the 2012 Parliamentary Inquiry into the Sandalwood Industry. Harvest limits should be based on what wild populations can sustainably withstand, not how much industry wants to take. In addition, wild take quota should be solely and exclusively allocated to First Nations enterprises, operating under approved management plans.
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 annual limit should be a genuine maximum, not a bank of sandalwood that can be carried forward and harvested later. Any unused allocation should remain unharvested and should not become an entitlement for future extraction. Rollover risks much greater pressure on wild sandalwood in a single year, particularly when populations are already stressed by drought, climate change, fire and grazing. If conditions are unsuitable for harvesting, the answer should be less harvesting, not making up the difference the following year.
Section 5) Minimum size for harvest of living sandalwood trees
17) Do you have any ideas or suggestions for changing this regulation?
Any amendment to this regulation should not be used to justify or facilitate the continued harvesting of living wild sandalwood other than demonstrably sustainable harvesting by Traditional Owners. 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 work directly with Traditional Owners, Native Title holders and Aboriginal organisations as genuine decision-makers rather than simply consult them about harvest quotas. This should include a meaningful role in decisions about where, whether and how sandalwood is harvested and managed. Any allowed wild take should be reserved for Aboriginal-owned and operated enterprises, with strong ecological safeguards, transparent licensing and demonstrable regeneration outcomes. The Dutjahn Oils joint venture has already demonstrated the potential of this model. The FPC’s continued role in the sandalwood industry is a barrier to Aboriginal leadership and FPC should exit the wild sandalwood industry at the end of 2026, allowing Aboriginal businesses to develop independently. 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 of decisions made. The current review process raises concerns about the extent to which the public consultation process can meaningfully influence decision-making when the FPC 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 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.
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 prohibit the FPC from any future role in the sandalwood industry. The FPC has been responsible for around 90% of the wild take for the past 25 years, yet its operations have not been legally constrained by the Biodiversity Conservation Act or the Sandalwood Order. This model has not demonstrated ecological sustainability and should end no later than December 2026. 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. In addition, any future wild sandalwood take should be subject to robust, enforceable and publicly transparent management plans under a reformed Biodiversity Conservation Act.
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
Thank you for making a submission!
Your voice helps show the strength of our community and adds to the power of our collective message! Please contact [email protected] (or click the link below) to notify the Nature Team that you hyave made a submission to help Save our Sandalwood.