The European Union Timber Regulation (EUTR) coming into force on the March 3 2013 will reduce the global problem of illegal logging by subjecting users of timber and timber products to new legal requirements.
But what does this mean in practice? Is the EUTR a burden, or is it something that should be welcomed?
“Traders” (those purchasing timber products that are already on the EU market) will now need to maintain records identifying the operator the product was purchased from whilst, as reported on The Manufacturer’s website, a new legal responsibility will be placed on operators (those placing timber products on the European market for the first time) to ensure that the timber products they place on the market are from legally harvested sources. Operators can achieve this through the implementation of a capable due diligence system.
A capable due diligence system will have three components – access to information, risk assessment and the mitigation of any risk identified. It might be helpful to imagine establishing a two stage process.
The first stage, access to information, would quickly establish, through the provision of timber legality certification or information on the type or origin of product, the level of compliance with the country of origin’s applicable legislation or likelihood of illegal sourcing. The majority of this information is readily promoted by responsible suppliers and will enable the business to determine if a timber source is low risk.
Following this, the risk assessment procedure through risk mitigation would deal with timber sources that are not proven to be low risk at the information stage – risk mitigation can include sourcing additional information that demonstrates low risk (either from the supplier or an independent source) or choosing to switch supply to a demonstrable low risk source.
Ahead of the introduction of the EUTR the smart operator will be looking to work with suppliers that can demonstrate low risk at the information stage. Certification will play a key part, operators can look for third party schemes such as FSC or PEFC – schemes such as these are likely to provide a level of assurance that the covered product is low risk.
However, such certification does not replace the need for a due diligence system as operators will still need to be able to demonstrate that the product sourced is covered by the given certification and that the third-party organisation is capable of such assurance.
Alternatively, operators can look for certification at the national level which demonstrates that the certified timber product has been sourced in accordance with the laws of the country of origin. Timber producing nations are rapidly developing legality of origin schemes to support their timber industries. As an example, Indonesia has developed the SVLK scheme, and it is SVLK certification that operators sourcing from Indonesia will need to look for.
The EUTR is to be welcomed. By closing the single market to illegal timber, the EUTR will reduce the problem of illegal logging. It will also enable fair competition for legal products. What then for operators? Smart operators will now be minimising the impact of the EUTR by working with suppliers that can readily demonstrate compliance with country of origin applicable legislation.