EU legislation will reduce the risk of using illegally-logged timber but you should remain alert
The incoming EU Timber Regulation is designed to reduce illegally logged timber products entering the EU market. It will affect the way timber is purchased and specified so architects should understand what it is and how it works.
Although timber logging has a relatively small impact on overall global deforestation (other forest-based commodities such as biofuels, soy, palm oil and beef have greater impacts), it plays a significant role in the dynamics of forest clearance practices by these other commodities, especially if logging for timber is illegal.
Nearly 10 years ago the EU responded to the illegal timber trade (estimated to supply 3-5% of UK timber imports), with the European-wide Forest Legality, Enforcement, Governance and Trade (FLEGT) action plan. On the demand side, the EU has fomulated the European Timber Regulation – or EUTR – to prohibit illegal timber entering the EU market.
Keep it legal
From 3 March 2013, Regulation (EU) No 995/201 legally obliges all those placing timber or timber products on the European market for the first time (known as 'operators') to carry out due diligence on these supplies to minimise the risk that they are from illegal sources – or face criminal prosecution.
Companies not placing products on the EU Market for the first time (known as 'traders') must ensure they have systems in place to trace timber purchases to sales to allow instigation of any criminal proceedings.
A watchful eye
It is very unlikely that the EUTR will have any major implications for your own business. Your main concern should be your or your client’s commercial risks of having illegal timber enter into project supply chains, especially for a high profile project such as the Olympics. Therefore it is advisable for specifiers/contractors to do some light touch due diligence themselves on the supply chain.
Check that you and your client’s timber suppliers know and understand the EUTR, and are preparing for it. In particular you can check whether your timber supplier has the required due diligence system in place, and its robustness (see box).
Where possible, specify and purchase wood from certified sources, particularly FSC and PEFC timber. Certified timber already comes through a supply chain with effective controls that minimise the risk of getting illegal timber, and uses sustainably managed forests.
If timber cannot be supplied as FSC or PEFC, ask suppliers for timber that has been verified legal either as FLEGT, which is government approved (not available on the market until at least March 2013), or through recognised third party schemes such as OLB, TLTV, Certisource, Rainforest Alliance Smartwood VLC and SCS LegalHarvest.
Finally, if the product you have specified cannot be supplied through any of the risk managed schemes above, talk to your supplier about their risk assessment and mitigation procedures. Products bought from non-risk managed sources should have evidence to show that the timber you are about to buy is at low risk of being illegal. Evidence could be general (such as credible NGO, government or industry reports, such as the TTF’s own country guides) or more specific documentation (such as export documentation, logging permits from producer countries, your suppliers' own third or second party assessment of the source).
The EUTR is seen as a positive step, within the timber trade, toward de-risking timber supply chains and eradicating the trade in illegal timber in the EU.
Anand Punja is sustainability manager at the Timber Trade Federation. He is speaking on the EUTR at Timber Expo on Tuesday 25th September. For more information see www.timber-expo.co.uk
EUTR IN DETAIL
> ttf.co.uk – a trade perspective on EUTR
> cpet.org.uk – the UK government’s EUTR portal, including information from previous and upcoming stakeholder meetings held at DEFRA.
> http://tinyurl.com/cldx9jw – the European Commission’s official page for communicating information and updates regarding EUTR.
> illegal-logging.info – Chatham House site providing general information on illegal logging
Members of the Timber Trade Federation (TTF) voted in 2008 to have a mandatory requirement in the TTF’s Code of Conduct to undertake due diligence. During the first year (2010) two companies did not comply and were removed from TTF membership. An off-the-shelf due diligence system – the Responsible Purchasing Policy – has been developed by the TTF since 2003 and includes third party verification.