This note is to advise members that the EU Timber Regulation (EUTR), which will ban illegal timber from being placed on EU the market, will come into force from 3rd March 2013. The Regulation requires companies ‘first placing’ timber or timber products on the market to undertake a credible and robust due diligence process to risk assess that the timber is not potentially from an illegal source. Where risk is identified mitigating measures should be implemented.
Companies further up the supply chain must have access to records to allow any timber to be traced to the person it was bought from and sold to (unless a consumer). Others, including house builders, are advised to review their operations to assess whether they are “first placing” any timber or timber products on the market. In practice this will in all likelihood be the case only if you are importing products from outside the EU. Full risk assessment of the product must then take place. In all other cases house builders are advised to ensure that where the sale of the house is not to an end user, traceability records are kept.
The Timber Trade Federation has a FAQ guide to the EUTR on its website http://www.ttf.co.uk/Environment/EUTR_FAQs.aspx. They also make the important point that although the legal risk to house builders from this piece of law may in general be low, any high profile company needs to assess the reputational risk to its business and react accordingly. The TTF point out that this is criminal not civil law.
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