European Union Timber Regulations (EUTR) Consultancy Services
Direct contact for questions: Richard Watkins
Mobile: 07785 930307
The European Union Timber Regulations (EUTR) came into effect in March 2013. This law is aimed at preventing the placing of illegally harvested timber and timber products onto the EU market. Penalties for violation of this law may include fines, seizure of the goods concerned and/or suspension of authorisation to trade.
Within the EUTR a set of procedures has been set out and by ensuring that these are followed, the risk of illegally harvested timber entering the EU market will be minimised. The law has three key obligations:
1.It prohibits the placing on the EU market for the first time of illegally harvested timber and products derived from such timber;
2.It requires EU companies who place timber products on the EU market for the first time (who are defined as “Operators”) to exercise ‘due diligence';
3.Once timber is on the market traders in the supply chain have an obligation to keep records of their suppliers and customers.
The regulations apply to both imported and domestically produced timber and timber products with some products exempt. Different players in the timber market have different obligations.
EUTR and Operators
Operators have the most onerous obligations. They are prohibited from placing illegally harvested timber on the market and are required to excise “due diligence” to prevent illegal timber entering the market through a due diligence system which they must regularly evaluate. This due diligence system must have the following elements:
1 Information – Specific information is required from the operator about who their suppliers and their product, such as product description, country of harvest (and sub-region if necessary), species, quantity and compliance with applicable forestry legislation.
2 Risk Assessment Procedure – This procedure must look at the product information against the relevant risk assessment criteria. First the EUTR risk assessment procedure needs to assess if the timber is at risk of being from an illegal source – so for example if the area of harvest is a high risk region or if the species is one prevalent in illegal harvesting operations. Second, the procedure needs to look at any evidence that the timber is what the supplier claims and has it actually come the region detailed. Therefore rigorous checks on the transparency and validity of the supply chain need to be carried out. If this process shows that a product has negligible risk of being illegally harvested it is deemed safe to place on the market. If the risk is non-negligible risk mitigation is required.
3 Risk mitigation procedures – The approach taken to mitigate any risk of timber being from an illegal source will vary from case to case and needs to be adequate and proportionate to minimise the risk of illegally harvested timber entering the EU market. Risk mitigation procedures in your EUTR due diligence system may involve requesting further information from the supplier or using third party verification to check validity of the supply chain and the legality of the timber. If after mitigation the risk of the product being from an illegal source is negligible the product is safe to place on the market.
How can we help?
Whether a company needs simple advice on how the laws affect them, guidance on how to amend existing processes or needs assistance in implementing a full due diligence system, EnviroSense EUTR Consultancy will have the capacity and know-how to help. We offer a range of bespoke services which include:
EUTR Training of In-House Personnel and Suppliers Briefing
EnviroSense can provide your staff with training on the EUTR requirements and brief your suppliers. Relevant personnel can be briefed on how the EUTR will affect their buying and operations and enable them to understand what information is required by the EUTR.
Development of an EUTR Due Diligence System
Roles, responsibilities and a set of procedures and measures for due diligence can be developed by EnviroSense for your company as required in the EUTR. Due diligence requires on-going monitoring of suppliers and products. We can develop a due diligence system that fits with your company.
EUTR Risk Assessment and Supply Chain Management using the Global Product Tracker
Information on your products can be uploaded by you, EnviroSense, or your suppliers onto EnviroSense’s Global Product Tracker (GPT). GPT is a supplier management tool that houses necessary records for compliance with EUTR requirements. EnviroSense can then carry out formal risk assessments of products and supply chains, providing your company with third party verified risk assessment reports recommending whether or not there is a negligible risk of illegality. A clear, easy to understand system of the supplier’s and product status is listed on GPT.
EnviroSense has over 20 years of experience working with the timber industry, assessing existing practices, preparing organisations for a range of certification schemes and providing third party verification. We are using our in-depth knowledge of timber and paper supply chains to help a range of clients – from timber merchants to supermarkets meet the challenges and opportunities presented by the EUTR.
Contact us for further information about how EnviroSense EUTR Consultancy services can help you. Informal meetings to discuss your EUTR needs can help identify potential scope, timelines and areas of focus.