• The EU Timber Regulation came into force in the UK on 3rd March 2013. It bans illegal timber in the EU and requires those companies that place wood or wood products on the EU market for the first time to assess the risk that those products may have come from an illegal source and act to mitigate any identified risks. This is known as due diligence and, like all due diligence, it must happen before you buy the product. It has to be undertaken even if the product is certified.
• The law states that you must keep a record of the supplier, the product species, where it comes from, and the amount bought. You must also record your risk assessment on the product, based on the evidence you have collected.
• In determining the level of risk you must use credible information about the country of origin, the supplier, the product and any other sources of information. You should not place an order for a product until you have been through this process and taken any necessary measures to minimise your risk from the product. You should also record what action you are taking to reduce your risk going forward.
• If you are buying product that is already in the EU and on which due diligence has taken place you need to keep records from whom you bought the product from and to whom you sold it. This helps the enforcement authority to trace illegal products up and down the suply chain and take them off the market if needed.
• We also recommend an independent auditor assesses what you have done and how you have done it.
The TTF has developed a business tool that enables companies to comply with the legislation. It is called the RPP or Responsible Purchasing Policy. It is compulsory for TTF members to use the RPP or an equivalent system in their businesses. The TTF provides this due-diligence tool free as a benefit of membership.
It is important to note that even timber products purchased before the 3rd March 2013 deadline will be caught by the legislation if they are delivered after that date. This means that you should be conducting risk assessment NOW given lead times for some products.