Comment from Siti Mustapha

1. By definition, rubber tree or Hevea brasiliensis qualifies as a common cultivar as it (a) Has been developed through selective breeding or other means for specific morphological or physiological characteristics; and (b) Is a species or hybrid that is cultivated on a commercial scale; and (c) Is not listed as endangered or a species of conservation concern. Malaysia has had over a century history of growing rubber trees, mainly cultivated for the production of latex. Rubber tree is harvested after 25 years when it is not economically viable for latex production, and the trees are replanted. The wood waste were burnt in the past, but in recent decades had been given a new lease of life and became a new material for the production of wooden products such as mouldings, furniture, medium-density fibreboards (MDF) and particle boards. Over 80% of wooden furniture manufacturing in Malaysia is made of Rubberwood while a majority of MDF production in the country is 100% made of Rubberwood. Both export of wooden furniture and MDF to US amounted to USD580 in 2009. 2. Notwithstanding the above, we note that there may be practical ramifications on the implementation of the exemption of such (tree) species from the provisions of the Act. Potential implications are yet to be understood and we maintain reservation on this matter and wish that there will be future opportunities to review the definition once the full effects of the provisions are realised. 3. We welcome the supplement guidance that will be developed and appreciate that it will be a living document that will be reviewed from time to time and therefore provides opportunities to review the definition once the full effects of the provisions are realised.