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September 12, 2022

Compliance with the European Union Timber Regulations (EUTR)

The EUTR was implemented in March 2013 to “prohibit the activities of placing illegally harvested timber and timber products onto the EU market.” It obliges importers of timber and timber products to the EU to exercise “due diligence” to ensure the legality of the timber and timber products.

The Due Diligence Systems (DDS) stipulates that operators (importers, manufacturers, retailers, traders, etc.) of timber and timber products must ensure that such products are not illegally harvested. This must be verified by checking the full chain of custody from the forest of harvest to the final consumer. Third-party certifications such as PEFC and FSC are certainly very helpful in the DDS process, even though such certifications do not automatically attest the compliance with the EUTR.

In my opinion, this is a flaw of the EUTR.  Both certification bodies, PEFC and FSC, have adapted their processes in line with the EUTR’s DDS. Consequently, it would be of tremendous help if both certificates had been accepted as sufficient DDS in complying with the EUTR.

A bad and sad example is Indonesia’s SLVK certificate. Since its inception, the demand for PEFC- and FSC-certified material from Indonesia dropped since all Indonesian -made export products automatically complied with the EUTR requirements under their national SLVK (FLEGT) scheme. Rest assured, this has resulted in increased illegal harvesting in Indonesia.

Not providing a specific list of required documents to comply with their DDS is another weakness of the EUTR system. In not doing so, it remains open to the individual interpretation of each operator. In our daily business, we encounter significant differences in the documentation demand between, e.g., the UK and the Netherlands.

Sourcing from around the world, we want to ensure that all our purchases comply with the EUTR even though most of our timber is destined for Southeast Asia and only parts of it will be transformed to be exported to the EU. Regularly, we face problems obtaining the full set of chain-of-custody documents from our suppliers. This includes harvesting licenses, forest removal passes, and transport-related documents. For example, most US hardwood forests are privately owned, and sawmills obtain logs from many locations. This involves different landowners, logging companies and transport companies, which makes it very hard to obtain the documents of a particular consignment of hardwood timber.

Many Malaysian forests are controlled by the State Governments who implemented strict policies, and many sawmills will obtain their logs from different States and forest concessions.

We even face similar problems when sourcing soft- and hardwoods from Europe. One would imagine the EU has implemented similar strict rules to ensure the timber is not illegally harvested. Regretfully this is not the case. The EU authorities leave this to the individual EU member countries to control – or not.

Many of our suppliers are hesitant to provide the full information on their supply chain as they fear this might affect future business.

Overall, timber certification from the forest to the end user is not easy. Still, one would have hope that after almost nine years, compliance is a “no-brainer”. All of us in the timber industry support the efforts to stop illegal harvesting and provide DDS at any time, not just because of the EUTR. Regretfully this is not the case. It will probably take many more years before we reach zero illegal trade, but it might be too late by that time.

Posted in Blog