This document explains our obligations to meet the requirements of the EU Timber regulation (EUTR) which came into force on 03rd March 2013.
Who is affected?
The Regulation divides those who deal in timber and timber products into two categories: Operators and Traders.
Operators are those who first place timber products on the EU market and they carry the bulk of the responsibility. Tradelink act as operators when importing the goods into Europe and arrange the customs clearance.
Traders are those who buy or sell timber or timber products already on placed in the EU market and are required only to keep track of who they buy from and who they sell to for five years. This information is only needed for the period up to the last point of sale between businesses. No information is needed on sales to end consumers.
We are required to exercise Due Diligence when placing wood on the EU market. It is down to us to implement a Due Diligence system designed to minimise the chances of the wood coming from, or being made of wood which comes from, illegally harvested sources. We therefore implement a risk management system based on:
- Having access to information describing the timber and timber products, country of harvest, species, scientific name, quantity, details of the supplier and information on compliance with national legislation.
- Assessing the risk of illegal timber in his supply chain, based on the information identified above and taking into account criteria set out in the regulation.
- Having risk mitigation procedures in place that are adequate and proportionate to minimise the risk of placing illegal products on the market.
- FLEGT or CITES licenses automatically comply with EUTR requirements and 2 and 3 above are not required.
- FSC, PEFC and other credible certifications are not exempt from EUTR due diligence. These certifications can be used only to mitigate risk in the due diligence process making 2 and 3 above less complicated.
If you buy imported goods from Woodtrend we can assure you that the above Due Diligence procedures are already part of our current procedures in place today. We have been complying with other regulations such as Lacey Act in the USA for years already and we were among the first to sign up to the UK Timber Trade Federation’s Code of Conduct and Responsible Purchasing Policy in 2007. Our customers will not need to worry about due diligence but only comply with EUTR’s requirements for Traders.
If you buy timber products from us on a forward basis with FOB, CFR or CIF incoterms and arrange your own import into the EU we undertake to have done the Due Diligence required as for operators and to maintain the records for a minimum of 5 years. We will disclose such information to you upon your signature of a Non-Disclosure Agreement undertaking to use such information only in the event of a compliance audit for non-commercial purposes.
Further useful information and FAQ’s can be accessed on this website , set up by the EC and dedicated to the EUTR
I hope that this is clear but please do not hesitate to contact me if there are any questions.