The European Timber Regulation21/03/2013
The European Timber Regulation: In March 2013, Europe imposes administrative obligations to companies trading timber and paper products.
Content and objective of the regulation
On 3rd March 2013, the European Timber Regulation (EU-TR) comes into effect in the entire European Union. The EU-TR is a European ordinance (995/2012) which imposes administrative commitments to all companies that are dealing with timber, timber products and paper. One may immediately think of lumberjacks or timber importers, but also enterprises selling or buying wooden packaging or furniture have to fulfill certain liabilities.
The aim is to monitor the origin of timber and timber products in the EU by obliging traceability in all stages of the supply chain. This way, Europe wants to curb unregulated logging and counteract the import of illegally cut timber.
Two types of actors in the supply chain, two different obligations
One has to distinct 2 different types of actors in the timber and paper chain: operators and traders. This contrast is very important in the regulation, since the commitments for the two types are different.
1) Operators are all companies bringing wood on the European market for the first time. This can either be by import from outside the European Union or via logging in one of the Member States. A Belgian lumberjack cutting timber in Belgium or France or a Belgian timber importer who buys his trunks in Russia or Indonesia is an operator.
2) Traders are all companies purchasing timber from operators or others traders and further selling it. A furniture factory purchasing wood from a Belgian sawmill thus is a trader. The sawmill on its turn is a trader as well, because it gets all its timber from a purchasing agent. Since the timber had already been brought on the European market by that agent, the sawmill does not act as operator.
Operators have to draw up a document, containing a “due diligence” assessment, a kind of risk management. In the best way possible, the operator has to judge if the supplied wood is chopped in a legal way. They have to keep a record of each lot that was delivered. The due diligence can be performed by the company itself, and there are no specific guidelines of the criteria by which a lot and supplier have to be judged. The administration can also be outsourced to a certified third party. The record can be consulted at any time by the national authorized bodies.
Traders only have to keep a list of all timber, cardboard or paper suppliers. This way, the origin of each piece of timber can be traced further up in the supply chain.
Products subject to the regulation
The regulation concerns all timber and paper products, although exceptions exist. Return goods are for instance not subject to the regulation, as well as toys or crayons. On the link below, you find more information about the different categories of goods. In the supply chain, packaging fulfills a major function, because it also has a protective and preserving function during storage and transport. Timber and cardboard are used often as packaging material, and can also be liable to the EU-TR regulation. They can, not have to, because there is a contrast: packaging such as crates or boxes which are bought by a company in order to pack their goods, is subject to the regulation. If a chemical plant purchases full truck loads of wooden crates to pack its products on its site, it acts as a trader.
Packaging of other products (packing) is not liable to the regulation. This is “packaging material used exclusively to support, protect or carry another product”. When a company purchases steel drums which are delivered on wooden pallets, the EU-TR does not cover these pallets. The aim was not to by the wooden pallet, but the drums which are carried by the pallet.
Whoever wants a succinct overview of the regulation, can take a look on the website:
The url guides you to a document which also contains a list of products which are subject to the regulations and products which are not.