The EU Timber Regulations (EUTR) came into force in the UK on 3rd March 2013. These rules minimise the risk of illegal timber being sold by making it a criminal offence to place illegally logged timber and timber products on the European Market.
In this guide, we will explore the UK timber industry and what steps joinery companies should take to comply with the EUTR and the benefits of doing so.
Where does our timber come from?
The UK timber industry is huge – on the whole it’s worth around £7.6 billion. We import around 80 per cent of the timber we use, while the other 20 per cent of raw material is home-grown.
The majority of commercially available home-grown timber is fast-growing softwood, which is ideal for decking, outdoor furniture and pallet making. Whereas high quality softwoods come in from Northern Europe and North America.
These high-quality building materials are commonly used in things like making window frames, staircases, floors, roofs and doors.
Alternatively, hardwood timber comes from all around the world. It can be grown natural or on a plantation and has a wide variety of uses. Unlike softwood, hardwood is generally used for making good quality furniture.
According to the UK government’s Timber Procurement Policy (TPP) legal sources are defined as: “harvested in accordance with the applicable legislation in the country of harvest”. This means legality is always legality of the country of origin.
Illegal logging is the harvesting, transporting, processing, buying or selling of timber in violation of national laws. This includes harvesting wood from protected areas, exporting threatened plant/tree species and falsifying official documents.
It’s important to take a stand against illegal logging, because it not only harms the environment and local communities, but also damages the companies that are already operating responsibly within the boundaries of these laws.
New approach to due diligence
Under the regulations, there are two sets of responsibilities depending on whether you are classed as an ‘Operator’ or a ‘Trader’.
Companies that bring in material outside of the EU must develop a ‘due-diligence system’. This process is based around getting information together, risk-assessing the information you have and then working out a risk mitigation strategy to prevent illegal timber arriving into the EU market.
Parties like importers, retailers, manufacturers that directly import wood-based products and Forest Managers that supply from an EU-based forests have a responsibility to carry out this due diligence to demonstrate that they have not brought illegal timber onto the EU market.
If you do not comply with the EU regulation then, you may be subject to:
- Seizing of the timber
- The suspension of authorisation to trade
Enforcement agencies are appointed by individual member states and is up to them to regulate. These fines are applicable to the operator (the first placer of imported timber on to the EU market).
If you’re buying it from the first placer, then you’ll be classified as a trader, so you need to keep a record of where you have sourced from and where you sold to. This is the only legislated requirement for companies buying from within the EU from an operator.
You will not be required to carry out due diligence processes or asking for evidence if you are not importing directly.
What operators can do to comply with the regulation
The operator should have a clear understanding of what species of wood you are buying, where it is harvested and the issues around the quantity of what they are buying. When they have this information, the next step is the risk assessment, to assess the likelihood of timber coming from an illegal source. If this is high then they must then mitigate that risk. We’ve shown you step-by-step below:
The Three S’s of a Risk Assessment
Source: Consider where you source your product – ask if the country of origin has a known problem with illegal logging (e.g. is it a well-known country where illegal logging carries on?).
Species: Some trees are more likely to be illegally logged than others, depending on their availability and value. For example, if they are a rare species and of relatively higher value, there could be a commercial imperative for illegal logging to go on.
Secondary Information: The final bit of the risk assessment is to find out if any other information can be provided from your supplier, such as documents that can back up the information to the origin of the raw material. These could be things like The Forest Law Enforcement, Governance and Trade (FLEGT) licences, third party certification documents or harvesting permits.
Chain of Custody Certification
The Chain of Custody Certification (COC) is a system that ensures that the origin of a product is traceable along its supply chain. So how does it work?
Every step along the line has to have a COC certification. Each point in the process is independently audited by third-party organisations to make sure that when raw material is brought into a company, it’s identified, recorded and known to be certified. We’ve put together a list below of what needs to be certified in the COC process:
- The forest (which grows the timber)
- The sawmill (which rough saws the timber)
- The secondary processor (which buys the lumber and shapes it into moulded timber)
- The Merchant (which buys and stocks the moulded timber)
- The joiner (which makes the door/windows/ etc.)
In the timber industry, the Chain of Custody Certification is most recognised through the Forest Stewardship Council (FSC) and the Programme for the Endorsement of Forest Certification (PEFC), which are timber industry standards with widespread recognition. If a product is certified by FSC or PEFC, you can pretty much guarantee that the timber is not only legal, it also comes from well-managed forests. However, they do not necessarily give you a green light for EUTR compliance, but they do represent excellent due-diligence information.
To sum up
Proving something is legal is the first step to timber sustainability. It makes good business sense to source sustainable products, so that timber is available to companies in the long term. Also, ensuring that we buy wood from certified forests can help to tackle the global problem of deforestation and ensures that those forests have been sustainably managed.
Ultimately, what you need to know about the regulation is that it all it comes down to purchasing. Whether you are a small company without a legal team or a really large company, at the end of the day it comes down to ’who is purchasing?’, ‘what is being purchased?’ and knowing what to ask for, underlined in the risk assessment, prior to placing your timber order.
Have you had any experience or come across some challenges regarding the timber regulations? If so, be sure to send us a tweet – we always love to hear what you have to say!
And if you’ve got any questions about timber regulations or want some more information then please don’t hesitate to get in touch with International Timber today.
Images used courtesy of Wikimedia common and deallawire.com