The substance of such certification is also a concern. Without any chain-ofcustody tracking, there is no clear link between the products a company sells and its forest management system. Products themselves are not certified, and consumers can have no assurance that their purchases support sustainable forestry. The emphasis on continual improvement risks being interpreted far too nominally. And critics have also argued that, because of the administrative bureaucracy required for compliance, the CSA system favours large companies over smaller operators (von Mirbach, 1997).