Seed Supply Chain in Malaysia & what we have learned so far
Journey of Native Tree Seeds to Restoration
Site preparation & Planting
Seed Survey
Preparing restoration sites and planting to establish new forests.
Identifying and selecting seed sources in�natural forests.
Tree Census and Monitoring
Nursery Care and Management
Seed Collection
Ensuring the survival and growth through ongoing care.
Growing seeds into�seedlings in�nurseries, preparing�them for planting.
Gathering seeds from selected sources, ensuring genetic diversity and quality.
Carbon credit
Biodiversity
Ecosystem services
Restoration Planning & Species Selection
Identify restoration objective and select suitable species
Agroforestry
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Translation and�Transcription
Ethical Clearance and�Consent
Clearance obtained from�Bioversity International’s Internal Review Board.�Consent forms collected from�all participants
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State Actors, Non-state�actors, Indigenous People and Local Communities (IPLC), 30% women participation
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Interviews are recorded�and transcribed, also�translated to English
Interviews and Focus Group Discussions
Selection of Participants
November�2024 -�June 2025.
Quantitative &�Qualitative analysis
Prepare�Questionnaires
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Baseline Data�Analysis
Core process of�survey design
Baseline Interview Process
FGDs at TRCRC or kampung; interviews at stakeholder offices/nurseries
Distribution of Respondents by Gender & Group�
Perception of Project (Questionnaire A)
Capacity assessment (Questionnaire B)
Stakeholders interviewed: ~ 95 male and 49 female respondents from 10 federal/state agencies, 15 civil society/private organizations, and IPLC from 13 villages across Perak, Selangor and Sabah.
10 State/
Federal Actors
Male - 6�Female - 4
14 Civil Society/�Private Sector
Male - 9�Female - 5
46 IPLC
Male - 28�Female - 18
10 State/
Federal�Actors
Male - 10�Female - 0
13 Civil Society/�Private Sector
Male - 9�Female - 4
51 IPLC
Male - 33�Female - 18
Interview Session and FGD with IPLC from RPS Air Banun and Royal Belum
Interview Session and FGD with IPLC from KAPOK, Kinabatangan, Sabah
Interview Session and FGD with KAPOK & KOPEL at Kinabatangan, Sabah
Project Introduction and Engagement with State Actors
Jabatan Perhutanan Semenanjung Malaysia (JPSM)
Pejabat Tapak Semaian Mantin, Jabatan Perhutanan Negeri Sembilan
Pusat Perolehan Biji dan Bahan Tanaman, Lentang, Pahang
Pejabat Hutan Daerah Hulu Perak (Gerik)
Jabatan Perhutanan Negeri Perak (JPNPk)
Jabatan Kemajuan Orang Asli (JAKOA)
Project Preview and Focus Group Discussion with Non-State Actors
Result: Perception of Project
Themes
How much do the goals of Seed to Tree directly support with your organization’s activities?
61-89% of respondents stating that the goals support their own objectives much or very much. Goal 3 aligned especially well with many stakeholders’ own objectives.
Figure 1. Extent to which stakeholders see that the goals of the Seed to Tree project support their own organization’s activities. The project goals are numbered 1 to 3. Results are based on interviews with 20 stakeholders.
GOAL 2. Improve the availability of quality seed and seedlings for native tree species
GOAL 1. Improve restoration actors’ capacity to select site-adapted tree species that meet project-specific restoration objectives
GOAL 3. Improve the participation of local communities and indigenous peoples/Orang Asli in seed and seedling supply chains
Perceptions of Role of Native Tree Species
Native species play a crucial role in forest restoration, particularly because they are originally found in the area and are naturally adapted to their specific habitats.”
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To provide more food options for wildlife in area you want to rehabilitate. Why not exotic? Because they mess up our food ecosystem.”
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Forest�Restoration
Biodiversity�Support
Habitat�Connectivity
Human- wildlife�Conflict�Reduction
Ecosystem Health
Stakeholders overall has similar perceptions of the role of native tree species.
Challenges related to Native Tree and Seed Quality
Lack of Knowledge, expertise and reference data - species selection, generic quality assessment
The work that we are referencing always is done in like 1970.”
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Lack of technological tools
Lack of manpower capacity and IPLCs involvement in sourcing seeds
you don't really know if you've done your right job until 100 years plus... we just don't know what the effect our actions will be. You don't have the data, and you probably won't.”
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Inconsistent seed supply and quality
Funders’ preference and expectation
Limited Market Access to IPLCs
Trust and Cultural Differences: Gaining and maintaining trust
there's not much literature out there, and we don't have the expertise to select these specific species to achieve the goal.”
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Challenges related to Native Tree and Seed Quality
Lack of Knowledge, expertise and reference data - species selection, generic quality assessment
They recognize the need to improve their methods, particularly in germination techniques and seedling management.”
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Lack of technological tools
Lack of manpower capacity and IPLCs involvement in sourcing seeds
'the seedlings are not good quality because the nurseries themselves don't have the knowledge when it comes to rebagging or pruning, what is the best practies. These sorts of practices they usually give to foreign workers..”
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Inconsistent seed supply and quality
Funders’ preference and expectation
Limited Market Access to IPLCs
Trust and Cultural Differences: Gaining and maintaining trust
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'there are some people who are working on things like a QR code system to track where the seeds are coming from..’’
Challenges related to Native Tree and Seed Quality
Lack of Knowledge, expertise and reference data - species selection, generic quality assessment
we face a lot of insecurity with the tree supplies.”
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Lack of technological tools
Lack of manpower capacity and IPLCs involvement in sourcing seeds
'We just have to take what we can, basically, opportunities, without following the stringent, proper protocol to ensure that good quality...”
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Inconsistent seed supply and quality
Funders’ preference and expectation
Limited Market Access to IPLCs
Trust and Cultural Differences: Gaining and maintaining trust
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Sourcing seeds is a challenge, e.g. want to plant Mangifera, but local community don’t know when it is available, when it’s fruiting..’’
Challenges related to Native Tree and Seed Quality
Lack of Knowledge, expertise and reference data - species selection, generic quality assessment
One of the main challenges identified is the difficulty in attracting the interest of villagers, as most are focused on earning a daily income and show little interest in volunteer-based activities.”
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Lack of technological tools
Lack of manpower capacity and IPLCs involvement in sourcing seeds
Orang Asli participation. They do want to participate, but when they do it, there are no buyers… When there are no buyers, their motivation to find and collect seeds to sow will decrease.”
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Inconsistent seed supply and quality
Funders’ preference and expectation
Limited Market Access to IPLCs
Trust and Cultural Differences: Gaining and maintaining trust
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hiring workers remains a challenge due to financial constraints.”
Challenges related to Native Tree and Seed Quality
Lack of Knowledge, expertise and reference data - species selection, generic quality assessment
Problem with natives plant is that they are not beautiful. There are no flowers. Innovation on vegetation is not cost effective, we just import.”
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Lack of technological tools
Lack of manpower capacity and IPLCs involvement in sourcing seeds
We propose (the choice of species) to them (the management), but then some native, no flowers. So what they wanted is some flowers or anything. So you might not get the same goals as the management.”
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Inconsistent seed supply and quality
Funders’ preference and expectation
Limited Market Access to IPLCs
Trust and Cultural Differences: Gaining and maintaining trust
Sometimes our funders like to ask us, “Why are they dying? Why are they not lasting?” How do we answer you?
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Challenges related to Native Tree and Seed Quality
Lack of Knowledge, expertise and reference data - species selection, generic quality assessment
The buyers don't give (money) directly to the Orang Asli, they have a process, where they have to work with a registered entity. So it became an issue, a lack of trust..”
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Lack of technological tools
Lack of manpower capacity and IPLCs involvement in sourcing seeds
they (IPLCs) have to go through our supplier, and we have no direct market with them… Unless we get direct contact with the Orang Asli, then surely we can get things for cheaper.”
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Inconsistent seed supply and quality
Funders’ preference and expectation
Limited Market Access to IPLCs
Trust and Cultural Differences: Gaining and maintaining trust
Challenges related to Native Tree and Seed Quality
Lack of Knowledge, expertise and reference data - species selection, generic quality assessment
the only way to gain trust is to spend at least one year, hanging out, chilling, not even talking about the project, just hanging out, sharing some cigarettes… So honestly, you have to slow down to their pace. You cannot expect them to speed up to your urban pace.”
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Lack of technological tools
Lack of manpower capacity and IPLCs involvement in sourcing seeds
They don’t see it the way we do. So we send the Orang Asli kids to school because we pay for their fee. But then sometimes they go, sometimes they don’t go. Sometimes their priorities are different as well, right? Maybe their priorities are different from ours..”
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Inconsistent seed supply and quality
Funders’ preference and expectation
Limited Market Access to IPLCs
Trust and Cultural Differences: Gaining and maintaining trust
Aspects of Improvement from the Interviews
Recommendations
Centralised database of native tree species and seed sources
Training modules & SOP on restoration practices
Improve data collection on tree suitability and resilience
Strengthen governance (policy, guidelines, rules and regulation) to enable seeds & seedlings buying and selling
Business model i.e. seed buy-back guarantee program
Result: Restoration Stakeholders’ Capacity Assessment
Four Themes
High use of native species:
Factors influencing species selection:
State | Dipterocarpaceae | Non-Dipterocarpaceae | |
Perak | Dipterocarpus sp. Hopea sp. Shorea parvifolia Shorea spp. | Aquilaria malaccensis Artocarpus integer var. silvestris Artocarpus kemando Artocarpus lanceifolius Artocarpus odoratissimus Baccaurea macrocarpa Baccaurea parviflora Barringtonia macrostachya Canarium spp. Durio sp. Dysoxylum cauliflorum Endocomia canarioides | Intsia sp. Knema hookeriana Koompassia excelsa Madhuca kingiana Myristica elliptica Myristica sp. Parkia speciosa Pometia pinnata Scaphium linearicarpum Scaphium longiflorum Spondias dulcis Styrax benzoin Syzygium spp. Terminalia sp. Xerospermum noronhianum |
Summary of species raised by IPLC in Perak (RPS Air Banun)
State | Dipterocarpaceae | Non-Dipterocarpaceae | ||
Selangor | Dipterocarpus cornutus Dipterocarpus oblongifolius Dipterocarpus stellatus Dryobalanops aromatica Dryobalanops sp. Hopea odorata Hopea subalata Shorea acuminata Shorea bracteolata Shorea leprosula Neobalanocarpus heimii | Agathis borneensis�Aglaia simplicifolia Alstonia angustiloba Alstonia sp. Aquilaria sp. Artocarpus rigidus Artocarpus sp. Baccaurea lanceolata Baccaurea motleyana�Baccaurea sp. Bouea sp. Calophyllum inophyllum Calophyllum teysmannii | Callerya sp. Castanopsis sp. Cinnamomum sp. Cratoxylum cochinchinense Cratoxylum formosum Cynometra sp. Dillenia sumatrana Elateriospermum tapos Endospermum sp. Intsia sp. Mesua ferrea Nephelium sp. Ochanostachys amentacea�Palaquium gutta Parkia speciosa | Pometia pinnata Sandoricum koetjape Saraca indica Scorodocarpus borneensis Sindora spp. Sindora wallichii Sterculia spp. Syzygium myrtifolium Syzygium napiforme Syzygium polyanthum Syzygium ridleyi Syzygium sp. |
Summary of species raised by IPLC in Selangor (Kemensah, Bt. Lagong, Sg. Buloh)
State | Non-Dipterocarpaceae |
Sabah | Alstonia sp. Dillenia excelsa Dillenia reticulata Dyera costulata Mallotus muticus Neolamarckia cadamba Neonauclea bernardoi Octomeles sumatrana Pterospermum elongatum Terminalia catappa Terminalia copelandii |
Summary of species raised by IPLC in Kinabatangan, Sabah
Pan Borneo highway’s construction has made it harder to collect (IPLC, Sabah)
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When my grandfather took me to the forest, every tree had fruit. But now, we have to select. We don’t even know why, maybe because of the weather. Some trees that used to bear fruit don’t anymore. (IPLC, Perak)
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Collecting species that are not in demand will not lead to purchases and would only waste effort. Therefore, collection is typically focused on species with market value. (IPLC, Sabah)
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Challenges in Species Diversity and Seed Quality (SA, NSA and IPLC)
Now, because of logging, rambutans have started to disappear. Even the figs are running out. Because of logging. They’re still there, but they’re much further in. (IPLC)
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One year, a kilo of winged seeds was around 700-plus, and another year, it was nearly 1,000—meaning the seeds were getting smaller and smaller. (SA)
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You can't generalize this... one year, could be 50-100 (species), another year could be 20, if we get really lucky, we'd have like, more than 200. (NSA)
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Criteria for seed sources and parent trees
Criteria for Seed and Wildling Sources��Opportunistic (n=10)
Easy to access (n=3)
Near restoration site (2)�Match local conditions (1)
Not degraded (1)
�Seed and wildling quality (2)�Health of mother trees (2)
�Genetic diversity�Growth characteristics
The more species collected, the less the pests’ responses to the tree, and it will further increase the resistance of each tree. Based on this theory, best to have more mother trees from different species for the nursery. The more genetic or material, the better it is. The best will survive.
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We use any available sources. As long as there are seeds, we will just collect all that is available.
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Seedling survival
Weather (flooding, dry spells)
Lack of water / Excess water
Wild animal damage
Survival lower in open areas
‘The rain has caused some trees to fall on the planting plots at the restoration area. Uncertain weather leads to unpredictable things happening on the ground, especially in semi-degraded areas. There were also animal disturbances in one of the plots with dense planting.’
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‘For hill areas, Meranti Tembaga is not that resilient. It needs shade. Other species on the hill, like Meranti Sarang Punai and Meranti Temak Nipis, all survived.’
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SEEDLINGS PRODUCTION VOLUME BY IPLC �(PAST 12 MONTHS)�
Ranged from approximately 350 to 10,000 seedlings per group.
Gendered division of labour in seed and seedling supply chains among IPLC
"We women don’t know how to go into the forest. But if it’s the men, it’s okay. The men go to the forest. We don't know the tree names."�(Female IPLC FGD)
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Factors: safety concerns, childcare and household duties, lack of knowledge, lack of confidence, perceived or actual bias against women
Aspects of Improvement from the Interviews
Recommendations
Centralised database of native tree species and seed sources
Training modules & SOP on restoration practices
Improve data collection on tree suitability and resilience
Strengthen governance (policy, guidelines, rules and regulation) to enable seeds & seedlings buying and selling
Business model i.e. seed buy-back guarantee program
Plant Care and Maintenance
Lack of Buyers
Plant Growth
Market Acceptance
Wild Animal Disturbance
Weed Problems
Weather-
related constraints
Insect Infestation
Lack of Planting Materials and Fertiliser
Water Availability
Urban Development
CHALLENGES � faced by the IPLC in raising seedlings
Production Costs and Profit
Operational
Environmental
Market
External Factors
Pricing
Key Feedback
“Sometimes buyers provide cash advance in time of needs.”
“(The buyer) requests specific species but rejects them after we plant.”
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Key Feedback
“...Sometimes there is late payment and can be unpredictable.”
“Can make money, but it is not stable. The price is not suitable for living...”�
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Key Feedback
"The income can be higher; this is our primary income source."
"RM1 is not fair… There’s a lot of work at home and with the seedlings too."
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Jobs and incomes of IPLCs
Own or family labor (hours)
Materials (RM)
Transport (RM)
60 hrs/month (seed collection), 8 hrs/day (seedling work) (Sabah)
IPLC expenses and labor in the last 12 months
Licenses (RM)
Seed and seedling suppliers: restoration implementers
Suppliers of tree seeds and seedlings as reported by state and non-state restoration actors (n=14).
Factors Influencing Seed and Seedling Supplier Selection
Problems sourcing from IPLCs
‘’Is the state, or any states agreeable to this kind of buyback scheme? Do they allow this kind of buyback scheme? We have a national policy on social forestry. Where is that going? I don't know. Do you have the process or not? Is that process recognized by JPSM, the states?
�Are they part of the players in this kind of buyback? Whether they have the capacity to buy back or want to buy back? Or even if they don't have the capacity, do they allow buyback because those seedlings are coming from the forest? So the process and the policy and the consent all that, is it in place first?"
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Policy and Regulation gaps in Seed Value Chain
4 August 2025
Policy and Regulation Gaps: Background
Gaps
IPLC Accessibility to collect and sell Seeds and Seedlings
Fair or Standardised Pricing for Seeds and Seedlings
Policy / Guideline
Legal-binding Act
Protected Areas like State Park and National Park
Forest Reserves
Disclaimer:
This discussion or presentation is not intended to address Indigenous Community Land Rights in Peninsular Malaysia. While we acknowledge the land rights issues faced by Indigenous communities, our focus is on discussing the best strategies to position Indigenous Peoples and Local Communities (IPLCs) in the forest restoration supply chain within the framework of existing laws and regulations.
ICCFS Seedlings Buyback Guideline
Akta Perhutanan 1984 (PEMAKAIAN) 1985 Pindaan Kaedah-kaedah Hutan Perak
Akta Perhutanan 1984
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Policy and Regulation: Background
Provides legal authority for forest regulation, including licensing and royalties
Provides the legal framework for land classification, ownership, and administration in Peninsular Malaysia.
Provides legal protection and administrative structure for the welfare, land rights, and autonomy of Orang Asli communities in Peninsular Malaysia.
National Forestry Act 1984
National Land Code 1965
Aboriginal Peoples Act 1954
Promotes legal framework, fair pricing, FPIC, and benefit-sharing in social forestry program
IC-CFS Seedlings Buyback Guideline
Act / Akta
Policy / Dasar
Seksyen 14: Segala hasil hutan adalah harta Pihak Berkuasa Negeri.
Segala hasil hutan yang berada, terletak, tumbuh atau berasal dalam Hutan Simpanan Kekal atau Tanah Kerajaan hendaklah menjadi harta Pihak Berkuasa Negeri kecuali di mana hak ke atas hasil hutan itu telah dilupus secara khusus mengikut peruntukan-peruntukan Akta ini atau mana-mana undang-undang bertulis lain.
Seksyen 15 (1): Larangan mengambil hasil hutan dari Hutan Simpanan Kekal atau Tanah Kerajaan melainkan jika dilesen, dan sebagainya.
SEKSYEN DI BAWAH AKTA 313 BERKAITAN HASIL HUTAN BUKAN KAYU
Seksyen 16: Kuasa untuk mengeluarkan lesen, permit penggunaan, dsb., dengan cara tender, perjanjian, dsb.
Seksyen 16 Sesuatu kebenaran:
National Forestry Act 1984 / Akta Perhutanan Negara 1984
National Forestry Act 1984 / Akta Perhutanan Negara 1984
(NON-TIMBER FOREST PRODUCT, NTFP)
LESEN KECIL (Seksyen 28)
Map Purchase Fee - RM50.00 per plot
Hasil Kecil Hutan Renewal Fee - RM100
Hasil Kecil Hutan Application Fee - RM500
Other Forest Products Premium - RM40/100�ha/yea
Renewal Fees (NTFP license expired every 6 months)
Application Fees
Licensing�Fees and�Premiums
Premiums
Map Purchase
Royalti
Seksyen 61: Royalti hendaklah kena dibayar mengikut kadar sebagaimana disiarkan dalam Warta oleh Pihak Berkuasa Negeri.
Licensing Fees and Premiums in Malaysia
(Lesen Kecil – Borang 3)
Comparison of Land Classifications under Federal Act and State Legislation
Law | Land Classification / Title | Community Recognition | Remarks |
National Land Code 1965 (Kanun Tanah Negara) | 1. Alienated Land (private title) 2. Reserved Land (e.g. forest, public purposes) 3. State Land (open/unallocated) | ❌ No direct recognition of community customary land ✅ Transfer Of Limit (TOL) possible but temporary | Communities have no land security unless land is alienated or gazetted as reserve. |
National Forestry Act 1984 (Akta Perhutanan Negara 1984 – Akta 313) | Hutan Simpan Kekal (HSK): Protection Forest, Productive Forest, Amenity/Recreational, Research/Education, Wildlife, Virgin Jungle Reserve (VJR) | ❌ No category for Community Forest or Social Forestry Area | All HSK land is state-controlled. Community access requires permit (e.g. Borang 3), unless waived. |
Aboriginal Peoples Act 1954 (Akta Orang Asli 1954 – Akta 134) | 1. Aboriginal Area (Seksyen 6) 2. Aboriginal Reserve (Seksyen 7) | ✅ Yes – formal recognition of Orang Asli occupancy and exclusive use | Tenure is non-permanent, non-transferable, and can be revoked or degazetted by the State Authority. |
Wildlife Conservation Act 2010 (Akta Pemuliharaan Hidupan Liar 2010 – Akta 716) | 1. Totally Protected Areas (TPA) 2. Wildlife Sanctuaries 3. Protected Areas (by regulations) | ❌ No formal recognition of indigenous or community rights | Access and use of resources in protected areas are generally restricted unless permitted. Violation can result in prosecution. |
State Parks Corporation Enactment (Perak) 2001 (Enakmen Perbadanan Taman Negeri Perak 2001) | State Parks under jurisdiction of State Parks Corporation (e.g. Royal Belum State Park) | ❌ No direct recognition of Orang Asli customary rights, but community engagement allowed by policy or discretion | Activities such as harvesting or entering may require special permits. Indigenous presence may be acknowledged but not legally secured. |
Item | Price |
Seedlings <1m | RM6.00/pokok |
Seedlings 1–3m | RM100.00/pokok |
Seedlings >3m | RM200.00/pokok |
Seeds (Dipterocarp) | RM500.00/kg |
Seeds (Non-Dipterocarp) | RM300.00/kg |
Pindaan Jadual Keempat
ENAKMEN AKTA PERHUTANAN NEGARA 1984
(PEMAKAIAN) 1985 Pindaan Kaedah-kaedah Hutan Perak
To update the royalty rates and official pricing of various Hasil Hutan (forest produce), especially Hasil Hutan Kecil,
National Forestry Act 1984 / Akta Perhutanan Negara 1984
Category | Subcategory | Height | Price Range (RM) | Remarks |
Forest Timber Trees | Light-demanding species | 1 – 1.5 meters | RM12 – RM15 | Dipterocarps |
| Shade-tolerant species | 1 – 1.5 meters | RM12 – RM35 | Non-Dipterocarps |
Rare Fruit Trees | – | 1 – 1.5 meters | RM15 – RM35 | – |
All Categories | If physical quality is poor | – | Up to 50% reduction | Poor stem size, weak root growth, uneven canopy |
Improving Connectivity in the Central Forest Spine (IC-CFS) Seedlings Buyback Guideline
3.2.7 Pricing of seedlings
Issue Long Term TOLs
Provides clear, sustainable rights for�non-Reserve communities, enhancing livelihood and social security.
NLC - Sections 62–68 allow short-term land use under a TOL, which can be issued for nurseries, community planting, or seed storage areas on state land.
Expand Aboriginal Reserves
Recognizing and expanding reserves offers�legal exclusivity but requires formal�gazetting and is revocable.
States can use Section 62 of the National Land Code 1965 to gazette Rizab Orang Asli for public purposes or issue private land titles for operation of community forest nurseries or seed source zones.
How to enhance legal protection for community forest nurseries and seed source zones?
Include in State Forestry Planning
Formal inclusion ensures protection similar�to Act 134 Section 7, integrating Social�Forestry Program into state plans.
Social Forestry Program
Improving Connectivity in the Central Forest Spine (IC-CFS) Seedlings Buyback Guideline
Forestry And Humans: Bridging The Gap Through Social Forestry
The guideline is developed in line with the four thrusts (core areas) of social forestry based on the Malaysian Social Forestry Strategic Plan 2021-2025.
Under Thrust 1: Policy, Legislation and Governance focused on land use and communities, there’s a mentioned aspect of legality and commitments on provide clear directive in the guidelines on how communities can obtain permits.
3.2.3.1 Registration of nursery
Social Forestry Program
Improving Connectivity in the Central Forest Spine (IC-CFS) Seedlings Buyback Guideline
3.2.3.2 Permits
Regulate sustainable harvest of resources under special nursery program
Add to Social�Forestry
Unprotected�Community�Area
Include�Indigenous�Settlement Area
Register community co-operative under Social Forestry Program
Establish livelihoods program in Aboriginal Reserves
Risk of losing�access
Secure access to�Seed resources
Incorporating Community Reserves or Area into State Forestry Planning via Social Forestry Program
Challenge / Gap | Explanation | Recommendation |
No standardized SOP for seed/seedling buyback | Current practices rely on short-term projects (e.g. IC-CFS), with no legal mechanism for Forestry to procure from communities | Develop and adopt a national SOP under JPSM for seed/seedling procurement involving communities |
Seedling prices are inconsistent and undervalued | Communities receive RM2–RM3/pokok (from interviews) while IC-CFS and Kaedah Perak 2021 list prices at RM12–RM200 | Implement a tiered market-based pricing system, referencing IC-CFS and Kaedah-kaedah Hutan rates. Establish market-based pricing study. |
Lack of licensing / permit structure for seeds and seedlings | Communities still require Borang 3 and Lesen Kecil under Akta 313, even for low-risk activities like seedling sales.
| Issue a special permit or permit exemption under social forestry program with state forestry department or other agencies to grant nursery community special access within regulated areas. |
Policy and Legal Gaps