• European Union Timber Regulation (EUTR) Guide For Importers

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    European Union Timber Regulation

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    Timber and certain wooden products imported to the European Union must comply with the European Union Timber Regulation (EUTR). This regulation’s primary objective is to ensure that timber and some wooden products don’t originate from illegally logged forests.

    In this guide, we explain what EUTR means in practice, in terms of covered product categories, supply chain monitoring, and documentation.

    What is the European Union Timber Regulation (EUTR)?

    Regulation (EU) No 995/2010 is known as the European Union Regulation (EUTR). EUTR lays down the obligations of operators and traders who place timber and timber products within the EU market for the first time.

    The EUTR prohibits the activities of placing illegally harvested timber and timber products onto the EU market. It requires that operators, including importers, manufacturers, retailers, and traders, exercise due diligence to ensure the legality of timber and timber products.

    You can learn more about the regulation on the EU official website.

    European Union Timber Regulation (EUTR) Product List

    The EUTR provides a list of products that are subject to its supervision and regulation. Due to the sheer number of regulated products, the EUTR does not list the individual kind of products. Instead, the covered products are identified based on the Combined Nomenclature (CN) – which is used by the customs to classify goods and products when entering the EU market.

    Below are some examples of products of different categories for which EUTR applies. They cover wooden furniture, construction materials, decors, packaging materials, pulp, and buildings:

    a. CN code 9403 30 – Wooden furniture of a kind used in offices

    b. CN code 9403 40 – Wooden furniture of a kind used in the kitchen

    c. CN code 9403 50 00 – Wooden furniture of a kind used in the bedroom

    d. CN code 9403 60 – Other wooden furniture

    e. CN code 9406 00 20 – Prefabricated buildings

    f. CN code 4410 – Particle board, oriented strand board

    g. CN code 4411 – Fibreboard

    h. CN code 4412 – Plywood, veneered panels, and similar laminated wood

    i. CN code 4414 00 – Wooden frames for paintings, photographs, mirrors, or similar objects

    j. CN code 4415 – Packing cases, boxes, and similar products that are placed on the market as products in their own right, rather than as packaging for another product. Also, if the packaging gives a product its essential character it is covered: e.g. decorative gift boxes.

    European Union Timber Regulation (EUTR) Exemptions

    Some wooden products are excluded by the EUTR, such as:

    a. Wooden products made with wasted or recycled wood

    b. Packing material used only for supporting, protecting, or carrying other products (e.g. a wooden packaging used to carry goods)

    In addition, wooden products that are not included by the CN codes specified in the Annex of the EUTR are also exempted. For example:

    • CN code 9401 – Seats
    • CN Code 9403 80 00 – Furniture of other materials, including cane, osier, bamboo, or similar materials
    • CN code 9404 – Mattress supports
    • CN Code 4901 – Printed books

    Documentation Requirements

    In this section, we introduce the documentation required by the EUTR when placing timber and timber products in the EU market.

    Wood Species Description

    The EUTR does not describe the specific wood species that are under its supervision. Instead, the EUTR Annex states that the regulation applies to:

    “Timber and timber products as classified in the Combined Nomenclature set out in Annex to Council Regulation (EEC) No 2658/87”

    Since the products described in the Annex can be made from timbers of different species, such as white pines, fir, or cedar, we may infer that the EUTR applies to a broad species of woods.

    Certificate

    According to the Due Diligence Systems (DDS) set up by the EUTR, operators of timber and timber products should take action to verify the legality of these products. This means that they must ensure that the timbers or timber products do not come from illegal loggers and comply with the relevant requirements in every loop within the chain of custody.

    The Due Diligence Systems specifies that a certificate might be required to demonstrate the legality of the products. Such certificates are issued via relevant third-party-verified schemes, such as CITES, FLEGT, or FSC.

    Other Supporting Documents

    In order to provide access to the relevant information, the EUTR Guidance lists documents or other information that could indicate compliance, as well as the traceability of timber and timber products, including the following:

    • Receipts
    • Audit reports
    • Environmental clearance certificates
    • Environmental impact assessments
    • Environmental audit reports
    • Social responsibility agreements
    • Contracts
    • Banknotes
    • Trade notes
    • Import licenses
    • Export licenses

    Risk Assessment

    The risk assessment is a crucial procedure when exercising the Due Diligence System. When conducting a risk assessment, operators should take into account the following information as the criteria:

    • Assurance of compliance with applicable legislation
    • Prevalence of illegal harvesting of specific tree species
    • Prevalence of illegal harvesting or practices in the country of harvest

    Existing Systems

    As already said, the EUTR requires operators of timber and timber products, such as importers and manufacturers, to exercise the Due Diligence System (DDS) when placing timber or timber products on the EU market.

    This means that operators of timber and timber products must spare efforts to verify the legality of these products, e.g., whether the source of the timber is legit, the harvesting methods are compliant with the relevant standards, and other factors within the chain of custody.

    The methods to exercise due diligence are described in Article 6 of the EUTR. Since it’s not viable or realistic for SMEs to implement their own monitoring systems, they can use third-party verification schemes to facilitate the implementation of DDS.

    Examples

    The services of the third-party verification body include:

    • Timber source verification
    • Risk assessment
    • Processes and procedures review
    • Product assurance of compliance with applicable legislation
    • Auditing

    Forest Stewardship Council (FSC)

    Forest Stewardship Council (FSC) is an international, non-governmental organization that engages in deploying sustainable forest management systems. FSC developed its unique forest certification and product labeling system that helps consumers to identify legally sourced timber and timber products, including wooden products and paper.

    According to the information disclosed on FSC’s official website, FSC pursues to ensure its certification aligns with the EUTR requirements, including helping companies to practice due diligence and chain of custody supervision.

    Even though having an FSC certification does not guarantee full compliance with EUTR, it can still be used as an indicator to demonstrate that the products meet requirements and have been certified by a widely recognized scheme in the industry.

    Convention on International Trade in Endangered Species (CITES)

    The Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) is a multilateral treaty to protect endangered plants and animals. CITES is implemented in the European Union under a common framework.

    The EUTR specifies that if the timber and timber products specified in Annex A, B, or C of the CITES are compliant with the CITES requirements, then such products are considered to be compliant with the EUTR legal harvesting requirements.

    Forest Law Enforcement, Governance and Trade (FLEGT)

    The Forest Law Enforcement, Governance and Trade, short for FLEGT, is a worldwide scheme that advocates for the anti-illegal logging of trees and sustainable development and management of forests.

    The EU’s FLEGT Action Plan was initiated in 2003, which established actionable measures and provisions targeted on timber exporting and importing countries to reduce illegal logging.

    The EUTR states that, if the timber products listed in Annexes II and III of the FLEGT Regulation originated in partner countries listed in Annex I of the regulation, then such products are considered to be compliant with the harvesting requirements of the EUTR.

    Programme for the Endorsement of Forest Certification (PEFC)

    The Programme for the Endorsement of Forest Certification (PEFC) is a non-profit and non-governmental global forest certification system. The aim of this scheme is to promote sustainable forest management through independent third-party certification. Companies and brand owners can apply for the PFEC certification for their products if applicable to prove that their products comply with the PFEC standards.

    According to the profile of PFEC, its Chain of Custody Certification is aligned with the EUTR regulatory requirements. Importers and manufacturers of timber products in the EU can consult PFEC to enquire more information on the certification scheme.

    Sustainable Forestry Initiative (SFI)

    The Sustainable Forestry Initiative (SFI) is an independent, non-profit organization that provides a management system throughout the chain of custody of wooden products. The SFI aims to take action against the illegal logging scenarios around the globe and protect forests and precious wood species.

    The SFI provides a third-party verified chain of custody supervision, auditing, and certification services align with the EUTR requirements. Even though an SFI certification is not proof of full EUTR compliance, having an SFI certification helps to demonstrate that the timber products meet EUTR requirements.

    Origine et Légalité des Bois (OLB)

    The OLB system, short for Origine et Légalité des Bois in French, which means Timber Origin and Legality, is a forest certification system that was developed by Bureau Veritas to verify the legality of the timber and timber products.

    According to the introduction from Bureau Veritas, this system has been applied in Central and West African countries and Asia.

    Even though the OLB system has a comparatively short history, it represents an option for importers and manufacturers who are looking to certify their timber and timber products.

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