EU Timber Regulation: Overview of a Due Diligence System

EU Timber Regulation: Overview of a Due Diligence System

Members of the EUTR Timber Working Group

EU Timber Regulation: Overview of a Due Diligence System

contents



1

Document overview



1.1 1.2

2

Scope



2.1 2.2

3

Designing a due diligence system

Background Content

Which products? Who is responsible?

3.1

Information Gathering – Step 1 3.1.1 Method: how to collect and store information 3.1.2 Source: mapping retail supply chains 3.1.3 Frequency: when to gather timber data 3.1.4 Data: types of data to collect

3.2

Risk Assessment – Step 2 3.2.1 Risk Criteria

3.3

Risk Mitigation – Step 3 3.3.1 Categories 3.3.2 Verification activities 3.3.3 Testing and alternative sources

4

Overview of Due Diligence



4.1 4.2

5

Glossary

6

Annex A

Summary of steps for Due Diligence Summary: Examples of how the system might work

EU Timber Regulation: Overview of a Due Diligence System

EU Timber Regulation: Overview of a Due Diligence System

1. Document overview 1.1 Background The European Union’s Timber Regulation (‘EUTR’)1, will apply from 3rd March 2013, and will make it an offence to place illegally harvested timber or timber products onto the EU market for the first time. It will require operators placing imported and domestically produced timber on the internal EU market to implement a Due Diligence (DD) system in order to mitigate the risk of illegally harvested timber or timber products entering the supply chain. This due diligence system must include: • information about the supply of timber products • risk assessment to determine the risk of illegality • a procedure to mitigate the risk of illegality (if necessary) Whilst the final EU implementing regulation will be published in June 2012, the long lead times for purchasing dictate that retailers need to have a sourcing approach that provides evidence of compliance with the regulation by early 2012.

1.2 Content To better understand requirements under the EUTR, several members of the British Retail Consortium’s (BRC) Timber Working Group (herein referred to as the Timber Group2) developed this document to provide an overview of key elements in the EUTR and to suggest a possible approach to DD. Content was generated by the Timber Group during two workshop sessions facilitated by Acona Partners LLP3, and based on a collective interpretation of EUTR requirements, based on information available at the time of publication (April 2012). Additional input was provided by Rachel Butler, Advisor to the International Timber Trade Federation. Please note that irrespective of this collective understanding, it is the obligation of each individual retailer to implement their own DD system and to verify that their system demonstrates compliance with the EUTR. While a number of retailers may already have existing ethical sourcing policies and processes in place, these systems may need to be adapted or upgraded to meet new regulatory requirements. In other cases, retailers may need to develop an entirely new or different system. In either circumstance, if the retailer does not possess the internal knowledge required to ensure compliance, external expertise may need to be sought. The BRC and BRC members fully support the aims of the EUTR to reduce the trade in illegally harvested timber and hope this regulation will help to strengthen existing efforts.

1 http://ec.europa.eu/environment/forests/timber_regulation.htm 2 Members of BRC’s Timber Group are: Asda, Debenhams, HRG, John Lewis, M&S, Next, Sainsbury’s, Waitrose and WH Smith. 3 Acona Partners LLP. Available http://acona.co.uk/. Acona generated all figures in this document and developed the first draft on which this guidance is based.

EU Timber Regulation: Overview of a Due Diligence System



EU Timber Regulation: Overview of a Due Diligence System

2. Scope Due diligence is not a new concept for retailers but for many, knowledge of timber and timber product sourcing may not be as well understood as well as other product lines. Using the following section as guidance, determine which products are ‘in’ scope and then separate into product groupings, such as furniture, paper products etc. If possible, incorporate these product groupings into existing stock control or DD systems, adapting as necessary.

2.1 Which products? What the regulation says: Article 1: Subject matter ‘This Regulation lays down the obligations of operators who place timber and timber products on the internal market’ The Regulations cover timber, timber composite and paper products listed in Annex 1 of the EUTR. This Annex is based on custom import codes and harmonised according to Combined Nomenclature or CN codes. It sets out a defined (but complicated) list of products that are in or out of scope of EUTR. CATEGORIES IN SCOPE Products which contain timber e.g. solid wood, wood composite (mdf, particleboard, etc.) or paper listed in Annex 1 Goods for the purpose of processing or for sale to consumers or non-commercial consumers Goods not for resale: use within retailers own business, such as store fixtures and fittings, construction timber, paper carrier bags, till rolls and printer paper etc. Packaging imported in its own right, rather than surrounding a product

CATEGORIES OUT OF SCOPE Products which contain timber e.g. solid wood, wood composite (mdf, particleboard etc) or paper NOT listed in Annex 1 Non-tree species such as grasses and rattan Retail and transit packaging surrounding products, where the packaging is used to support, protect or carry a product By-products from a manufacturing process

Recycled and recovered products made from material previously placed on the market To clarify which of your products are covered, please refer to Annex 1 of the regulation. Retailers may also want to consult the reference resources noted below. REFERENCE RESOURCE: ANNEX 1 TO THE EUTR RETAILER RESPONSE To help simplify the product list, the Timber Group has drawn together a list of products that they understand to be within the scope of the regulation (and those that are not) in a separate document entitled ‘Annex to the EUTR Retailer Response’. Please note that it is not comprehensive and retailers are advised to refer to Annex 1 of the regulation as well as the HMRC. REFERENCE RESOURCE: HMRC If you have specific questions or want more detail, contact the HMRC Classification Helpline on 01702 366077 or email the following: [email protected]. 

EU Timber Regulation: Overview of a Due Diligence System

EU Timber Regulation: Overview of a Due Diligence System

2.2 Who is responsible? What the regulation says: Article 1: Subject matter ‘This Regulation lays down the obligations of operators who place timber and timber products on the internal market for the first time, as well as the obligations of traders.’ The regulation identifies different obligations of companies depending on whether they are considered operators or traders. Retailers can be an operator or trader (or both). A key defining factor is whether the retailer is ‘first placer’. Whilst the definition of ‘placing…on the internal market for the first time’ has yet to be clarified, until official guidance is available, the Timber Group has tried to interpret the regulation and has taken the following view: • •

• •

Placing on market refers to taking ownership of a product for the purpose of distribution or internal use (such as in-store fittings, own construction timber, and paper bags, till rolls and printer paper etc). Operator: For imported products, the organisation that has legal ownership for timber on entry to the EU is the first placer. In such cases, the retailer acts as the legal importer of these products (often referred to as direct import or FOB products) and are obligated to implement a due diligence process. An organisation is also an operator if placing domestically produced products (i.e. those produced within the EU) for distribution, internal use or sale on the EU market for the first time. Trader: Products imported under legal ownership of another organisation (often referred to as domestic or landed products), are the responsibility of the importer/transporter. Products can switch between landed and FOB over the buying cycle and/or be produced by multiple suppliers. Retailers may therefore choose to collect data and apply due diligence for all products in their ranges. However, from a legal perspective only direct import/FOB products and domesticically produced goods placed on the EU market for the first time would be ‘in scope’ of the EUTR.

Summary of Operators vs. Traders OPERATORS

TRADERS

Role of organisation/ company

Place timber or timber products onto the EU market for the first time.

Buy or sell timber or timber products already placed on (or imported into) the internal market (i.e. within the EU).

Examples of typical product categories or names Requirements under EUTR

Products imported into the EU (such as ‘direct import’ products or FOB). To operate a due diligence process for these products.

Typically termed ‘domestic’ products. NB: to qualify, products must already be placed on the internal market by another organisation. To record from whom products were purchased (often the operator) and to whom they were sold. Only applies where product is sold to another trader (not to the end consumer).

Includes information gathering, risk assessment and risk mitigation.

Information must be held for five years and be presented to regulating authorities if required.

EU Timber Regulation: Overview of a Due Diligence System



EU Timber Regulation: Overview of a Due Diligence System

3. Designing a due diligence system A retailer will have different obligations under the EUTR depending on whether they are acting as an operator or a trader. Therefore, for every timber and timber product purchased, the retailer will need to determine where the legal responsibility lies and whether a due diligence system is required. What the regulation says: Preamble (17) The due diligence system includes three elements inherent to risk management: • access to information, • risk assessment, and • mitigation of the risk identified. If required, a due diligence system needs to follow these three steps:

1. Information gathering – a range of supplier and product information, country of harvest and forest source data is collected.



2. Risk Assessment – the information gathered is assessed against a risk criteria.



3. Risk Mitigation – the process of managing high risk souces to ensure that there is no illegal timber in the supply chain.

If the retailer has determined it is necessary to set up a DD system, it may choose to set up its own system or use one provided by a monitoring organisation (MO). An MO is a private entity that develops and maintains a DD system, making it available for use by an operator. All MOs must be legally established within the EU and approved by the competent authority. A retailer may also elect to use external expertise to develop practical tools and advise on various aspects of the DD system. Examples include supplier questionnaires, how to define (and assess) species risk, greater understanding of product supply chains and how to assess/interpret evidence of mitigation.



EU Timber Regulation: Overview of a Due Diligence System

EU Timber Regulation: Overview of a Due Diligence System

Below is a schematic outline of requirements as an operator or trader.

What is your responsibility? Are you the importer of a product containing wood or paper into the EU?

Import SAW MILL YES You are the ‘Operator’ and need to do the following: N.B. products that fall under this category tend to be termed FOB or Direct Import Products.

No You are the ‘Trader’ and need to manage a traceability system and collect the following:

N.B. products that fall under this category tend to be termed landed or domestic products.

1. Information Gathering (p.8-12): Forest source details of all of the wood/paper components – tree species and country of harvest of each.

1. Who the products were bought from (p.5): the operator .

2. Risk Assessment (p.12-16): Assess each individual forest source for species and country risk.

2. To whom they were sold (p.5): if it were onto another trader.

3. Secure proof of sources a) Proof of supply of forest source material b) Proof of use in product. 4. Risk Mitigation (p.18-20): where a potential risk is found additional risk mitigation is required. 5. Unmitigated high risk sources (p.20): look for an alternative source and go to step 1 above.

6. Re-check forest sources (p.10): repeated once a year unless there is a change in specification or new product.

For some products, retailers may act as an operator and will therefore be legally liable to operate a DD process. Even if not legally obliged to do so, however, retailers operating as a trader may elect to implement a DD system due to potential risk of brand/reputational damage and risk tolerance. The rest of the guide will provide an overview of DD from the perspective of an operator. It will outline some possible (and pragmatic) approaches to DD based on current understanding of the requirements.

EU Timber Regulation: Overview of a Due Diligence System



EU Timber Regulation: Overview of a Due Diligence System

3.1 Information Gathering – Step 1 For retailers implementing a DD system, sufficient product information is required in order to effectively assess risk. However, external expertise may also be required to help develop the tools needed to gather information as well as to help store and manage data. If a retailer decides to use external support, it is strongly advised to contract organisations that have experience in understanding the forest product sectors. What the regulation says: Article 6: Due diligence systems 1.The due diligence system referred to in Article 4(2) shall contain the following elements: (a) Measures and procedures providing access to the following information concerning the operator’s supply of timber or timber products placed on the market: - Description, including the trade name and type of product as well as the common name of tree species and, where applicable, its full scientific name, - Country of harvest, and where applicable: (i) sub-national region where the timber was harvested; and (ii) concession of harvest, - Quantity (expressed in volume, weight or number of units), - Documents or other information indicating compliance of those timber and timber products with the applicable legislation

3.1.1 Method: How to collect and store information Information can be gathered about the supply chain using a variety of methods including: site visits, email/ web communication, supplier and/or product questionnaires, audit reports etc. Using an excel spreadsheet or web-based online system, retailers can collect this data and then store it for all timber/paper products back through to forest source. It may be possible for retailers to use existing systems but sufficient capacity is needed to accommodate document uploads and to store complex supply chain information. Contact a service provider or internal/ external consultation for service advice.

3.1.2 Source: Mapping retail supply chains Information needs to be gathered for all timber/paper products in your supply chain. Mapping the supply chain is a useful exercise to help identify contact points and types of information required to adequately trace the product. Since retail supply chains vary in their complexity, this approach needs to be flexible. For example, solid timber products have relatively simple supply chains in contrast to products made of paper or composite timber types (MDF or particle board). Such complex supply chains have larger numbers of processors in a supply chain, which increases the challenge and time required to trace all back to forest source.



EU Timber Regulation: Overview of a Due Diligence System

EU Timber Regulation: Overview of a Due Diligence System

Below are three examples for different products containing paper or wood mapped from forest source to product delivery: • Solid Wood Door: example of a relatively simple supply chain for solid wood product • Notebook: example of a more complex supply chain for a multipart paper product • Bookcase: example of a complex supply chain for a typical composite product (MDF or Chipboard with laminate veneer)

Solid Wood Door Direct TIMBER MERCHANT

SAW MILL

WOOD DOOR MANUFACTURER

or

RETAILER

AGENT

Notebook PULPMILL

Direct

PULPMILL PAPERMILL

PAPER MERCHANT

PAPER

MERCHANT

NOTEBOOK MAKER

or

RETAILER

PULPMILL AGENT

PULPMILL

Bookcase PAPER/SAW MILL/CONVERTER

Solids

Direct MATERIAL PROCESSORS

Veneer

MANUFACTURER

or

SUB CONTRACTORS

AGENT

RETAILER

Composites

Laminatedfoil

EU Timber Regulation: Overview of a Due Diligence System



EU Timber Regulation: Overview of a Due Diligence System

3.1.3 Frequency: when to gather timber data Typically, there are two different points in a buying cycle when data should be collected: a) when a new supplier (or new product) is selected and b) as part of the annual update or review process.

a) New (or existing) products with a new supplier Ideally, information should be gathered before the order for the product is placed. Where this is not possible, risk assessment and risk mitigation should take place before the product is shipped. Please be aware that some products may already be ‘on the water’ when the regulation comes into effect in March 2013 and before your due diligence system is in operation. In such circumstances when official guidance is not available, retailers will likely have to demonstrate adequate procedures and evidence is in place. One approach is to follow the DD steps outlined in this guide and/or consult with an external expert for best practice.

b)

Existing products with the same supplier

Retailers may import and sell the same product throughout the year. If the specifications of the product do not change then it is reasonable to assume that the forest sources remain the same. In these cases, suppliers should be contacted on an annual basis to re-confirm source details. Suppliers should also sign a declaration that ‘any supplier who intends to change the forest sources of their product should notify the buyer immediately and supply information for approval’. If product specifications change, the supplier should be contacted and asked to send new forest source information. Tip: For products with multiple components (particularly paper) it is helpful to gather the specific component brand names.This brand name should be the original name as allocated by the component manufacturer such as the paper mill. Merchants often rebrand components and this proves problematic when tracing a product down a supply chain and identifying its forest sources. Brand name information is not required for the due diligence system; however, by building up a library of component brand names and their forest sources you will be able to automatically risk assess the brand if used elsewhere in your supply chain.

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EU Timber Regulation: Overview of a Due Diligence System

EU Timber Regulation: Overview of a Due Diligence System

3.1.4 Data: Types of data to collect For all timber/paper products, basic information needs to be collected from all points identified in the supply chain. Below is a list of commonly collected data to start you on the process. Please note that the list is not inclusive and should be revised following the release of the EC/Defra guidelines. It is also important to note that evidence may be provided in another language. If translated, it should be done by a third party (credible) source or internal staff fluent in the language to verify content.

a)

Trade Name

The trade description of the product (or the name it is sold under), e.g. Maple Range 3 Tier Bookcase. As products can come from multiple suppliers the trade name may also include SKU, product or catalogue numbers that link individual products to individual suppliers.

b)

Type of Product

A product description e.g. a Notebook.

c)

Common name of tree species, and where applicable, its full scientific name

As tree species can fall under multiple common names but the full scientific name should always be sought. Retailers should also list any common name if given. This is particularly important as certain tree species are considered to be under threat and are therefore considered to be high risk (see Section 3.2.1c).

d)

Country of harvest, and where applicable i) sub-national region and ii) concession of harvest



The due diligence system is a risk based system. Therefore, we are interpreting ‘where applicable’ to mean that harvesting details beyond the national level should only be required when a high risk source has been identified (see Section 3.2.1d). In the case of potentially high risk sources, these should be independently verified as legal, thereby mitigating that risk. In such cases, no further sub-national region or concession of harvest data is required.

e)

Quantity

Our understanding is that the obligation will be for products bought rather than products sold. As a minimum, the quantity should be measured by the number of units bought/imported. Quantity measurement may also include the weight of the timber component within the product.

EU Timber Regulation: Overview of a Due Diligence System

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EU Timber Regulation: Overview of a Due Diligence System

f)

Documentation

Documentation should provide evidence of compliance with the regulation. It is typically used to support claims of forest source and to provide evidence of use in product. Documentation may consist of supplier invoices or separate supplier declarations that confirm tree species and country of harvest for timber used in the wood or components bought by the manufacturer/supplier and sold to the retailer. Where the product has been certified, a copy of the licence or certification number may be provided along invoice evidence to trace back to the last in-tact chain of custody. In the absence of certification, verification of legal compliance can be used. There are a number of available schemes but they should have a COC traceability system in place and invoice evidence tracing back to last intact COC. Whilst a supplier may have a COC number, this does not mean that they are supplying certified material. In order to confirm certified material is received, details should be provided in the same way as low risk sources (e.g. via a supplier declaration or invoice evidence). Tip: Broken Chain of Custody: This can happen when one link in the supply chain is not certified and so is unable to pass on material as being certified. In these cases, a supply chain audit trail should be established, with invoice evidence up to the last certified COC holder in the supply chain.

3.2 Risk Assessment – Step 2 Using the information gathered in Step 1, the data collated for each product must then be Risk Assessed. The Risk Assessment process should identify if any forest sources and particular tree species used in the supply chain are at risk of coming from illegal sources. To categorise risk, a flowchart or decision tree could be applied to all products. The majority of your timber/timber products will likely be: • Certified • Verified legal • Low risk species/low risk country • Low risk species/high risk country Less likely are products containing high risk species but if you have assigned high risk to a species, gather additional information (ideally third party independent evidence) and identify risk mitigation activities required. Where you have multiple species, you will need to provide information for each species and supplier. The final product will then be judged based on the lowest common denominator.

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EU Timber Regulation: Overview of a Due Diligence System

EU Timber Regulation: Overview of a Due Diligence System

3.2.1 Risk Criteria This section covers criteria that may be used when choosing risk indicators, though this list is not exhaustive. All operators must develop a risk assessment tool encompassing the below sections and document their procedures. What the regulation says: Article 6: Due diligence systems 1.The due diligence system referred to in Article 4(2) shall contain the following elements: (b) risk assessment procedures enabling the operator to analyse and evaluate the risk of illegally harvested timber or timber products derived from such timber being placed on the market. Such procedures shall take into account the information set out in point (a) as well as relevant risk assessment criteria, including: • assurance of compliance with applicable legislation, which may include certification or other third-party verified schemes which cover compliance with applicable legislation, • prevalence of illegal harvesting of specific tree species, • prevalence of illegal harvesting or practices in the country of harvest and/or sub-national region where the timber was harvested, including consideration of the prevalence of armed conflict, • sanctions imposed by the UN Security Council or the Council of the European Union on timber imports or exports, • complexitsupply chain of timber and timber products.

a) Assurance of compliance with applicable legislation Applicable legislation refers to the forest legislation in the country of harvest. It is the role of the Operator is to assess whether the forest law is being implemented. The box below lists those forest laws relevant to the regulation. What the regulation says: Article 2: Definitions (h) ‘applicable legislation’ means the legislation in force in the country of harvest covering the following matters: • rights to harvest timber within legally gazetted boundaries • payments for harvest rights and timber including duties related to timber harvesting • timber harvesting, including the environmental and forest legislation including forest management and biodiversity conservation, where directly related to timber harvesting, and • trade and customs, in so far as the forest sector is concerned.

EU Timber Regulation: Overview of a Due Diligence System

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EU Timber Regulation: Overview of a Due Diligence System

b)

Certification or other third-party verified schemes

Only FLEGT licenced timber and timber with a CITES permit is an automatic “green lane” but certification and other third-party verified schemes may help to provide evidence of legality or proof of due diligence (further information in section 3.3 on risk mitigation). Note: acceptance of certification and third-party schemes is at the discretion of the operator and does not remove liability from the operator. The operator should verify quality and credibility of any third party system being used on a regular basis.

c) Illegal harvesting of tree species For a specific tree species to be deemed illegally harvested or traded, it must be protected under local or national law or its trade regulated under an international or EU specific agreement. • The Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) is a specialist UN agency which maintains international agreements between governments on the protection of threatened animal and plant species. The species covered by CITES are listed in the CITES Appendices according to the degree of protection they need. • In the EU the CITES convention is implemented through the Wildlife Trade Regulations . Species listed under the EU Wildlife Trade Regulations in their appendices A, B, C, and D must, by law, be traded with various permits, certificates and notifications. The requirements vary depending upon the level of threat of each species. • For a full list of species, refer to those listed under the EU Wildlife Trade Regulations website. RESOURCE REFERENCE: CITES Appendices for Tree species at risk Appendix I includes species threatened with extinction. Trade in specimens of these species is permitted only in exceptional circumstances. Appendix II includes species not necessarily threatened with extinction, but in which trade must be controlled in order to avoid utilization incompatible with their survival. Appendix III contains species that are protected in at least one country, which has asked other CITES Parties for assistance in controlling the trade. Changes to Appendix III follow a distinct procedure from changes to Appendices I and II, as each party is entitled to make unilateral amendments to it. www.cites.org/eng/resources/species.html RESOURCE REFERENCE:The International Union for Conservation of Nature (IUCN) for Tree Species at Risk The IUCN assesses the conservation status of species, including tree species, and ranks them from those of least concern to extinct with a range between including vulnerable and endangered. This list also provides some indication of the threats to species such as pollution, geographical events, wood or pulp plantations, logging and wood harvesting. This can help to identify the threats to specific species posed by materials in a particular product, as well as to highlight those species that are under threat but which may not have yet made it on to the CITES lists.

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EU Timber Regulation: Overview of a Due Diligence System

EU Timber Regulation: Overview of a Due Diligence System

d) Illegal harvesting or practices in the country of harvest and/or sub- national region Illegal harvesting is defined at a national level and set out in national forest laws so indicators to assess illegal harvesting practices should be at the national level only. Any indicator used should be current and from a well-recognised independent source. It is notoriously difficult to define illegal harvesting risk at country level. Country reports on the subject indicate wide variations in levels of illegal logging (as a percentage of total logging). REFERENCE RESOURCE: RISK OF ILLEGAL LOGGING A recent report by Chatham House, the International Affairs Think Tank, used a variety of indicators to assess the incidence of illegal logging, though this was restricted to five producer and two consumer countries: • Media coverage – domestic and international reports on illegal logging • Government policy – enforcement, policy assessment • Private sector policy – the presence of forest certification and verification schemes • Levels of illegal logging and associated trade – wood-balance estimates which, in their simplest form, compare the legal supply of timber (officially permitted logging and legal imports) with actual Against each of the above indicators, the research also sought expert perceptions of the situation. www.illegal-logging.info/uploads/CHillegalloggingpaperwebready1.pdf REFERENCE RESOURCE: FOREST RISK AT SUB-REGIONAL LEVEL WWF has developed The Global 200 eco-regions, which shows areas within a country that have an exceptional level of biodiversity, such as high species richness. This information can help retailers to understand the sensitive forest areas at a sub-region level. www.worldwildlife.org/science/ecoregions/global200.html

e)

Consideration of the prevalence of armed conflict

Natural resources such as timber and minerals can used to fund armed groups in conflict areas around the world. For more information on conflict timber or conflict minerals, check sources such as Global Witness.

f)

Sanctions

The EU and the US have imposed sanctions on Myanmar, which were extended in 2007 to prohibit the import of all timber products and other materials. No other sanctions are currently in place. For updates on sanctions, refer to sources such as the UN Sanctions Committee or EU External Action website.

EU Timber Regulation: Overview of a Due Diligence System

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EU Timber Regulation: Overview of a Due Diligence System

g) Complexity of the supply chain of timber and timber products Although the focus of risk assessment is on the country of harvest, there may be additional risks relating to complex supply chains, most notably for products that include composite or paper products. For such complex supply chains there are numerous links in the supply chain from forest through to final production of the end product and this means it can be harder to trace the forest sources back to the country of harvest. In such cases operators might wish to apply the same level of mitigation as they would for a high risk country of harvest.

Summary of indicators for risk categories Indicator Category Governance

Change in forest cover

Country specific information

Expert Knowledge

16

Issue

Possible Source

How well are local laws implemented within a country?

Transparency International’s Corruption Perception Index (CPI) which measures the perceived levels of public sector corruption in 178 countries, ranked from 1-178. http://www. transparency.org/policy_research/surveys_indices/cpi/2010 Statistics from the UN Food and Agriculture Organisation’s State of the World’s Forest Report. http://www.fao.org/ docrep/009/a0773e/a0773e00.HTM

Is a particular country seeing a change in forest cover, particularly natural forest cover? What is the current geo-political situation? What are main resources extracted and are there any problems associated with production and trade? Retailers may also rely on their own expertise and knowledge, both inhouse and through specialist external advisors.

EU Timber Regulation: Overview of a Due Diligence System

Illegal logging reports from Chatham House and from WWF’s Global Forest Trade Network (see reference resources above) provide some information on a country level; Global Witness for country conflict; UN for sanctions

A number of organisations and consulting companies are developing risk assessment tools to help you in this process. One example is the Country Forest Risk Assessment Tool an open source document available at http://acona.co.uk/ industryclubs.html developed by Acona Partners LLP.

EU Timber Regulation: Overview of a Due Diligence System

3.3 Risk Mitigation – Step 3 The Risk Assessment process in Step 2 will generate risk ratings. Risk should be defined by categorising in line with the regulation, species and country of origin, mitigation measures in place, supply chain control and what evidence is required. Different risk ratings will be subject to different risk mitigation processes, consisting of a set of measures and procedures that are adequate and proportionate to minimise that risk. What the regulation says: Article 6: Due diligence systems C. Except where the risk identified in course of the risk assessment procedures referred to in point (b) is negligible, risk mitigation procedures which consist of a set of measures and procedures that are adequate and proportionate to minimise effectively that risk and which may include requiring additional information or documents and/or requiring third party verification.

3.3.1 Risk Categories a) No risk mitigation: negligible risk Risk is considered negligible where the risk assessment in Step 2 demonstrates legal compliance of all components of a supply. At present, products of negligible risk are only FLEGT licenced timber and timber with a CITES permit. However, only VPA licenced timber that comes direct from the producer country (or another VPA country) into the EU will be able to maintain its licence. If VPA timber passes through other producer countries that are not VPA, a full risk assessment and mitigation process will be necessary. Forest Law Enforcement Governance and Trade (FLEGT) As part of the EU FLEGT action plan, a number of Voluntary Partnership Agreements (VPAs) have been signed between the EU and participating timber producing countries. The VPAs put in place systems to license timber and timber products as being legal, which means that products with a FLEGT licence will meet the EUTR requirements and will be considered negligible risk. Therefore, it will not have to go through a mitigation process. Where a VPA exists, importers will need to have FLEGT licences to import the timber products listed in the Annex to the Regulation. At the time of publication VPAs have been agreed with Ghana, the Republic of Cameron, and the Republic of Congo. For updates on VPAs, check: www.euflegt.efi.int/portal ; and ec.europa. eu/environment/forests/illegal_logging.htm The EU FLEGT Regulation entered into force on 20th February 2012 but it will not be effective until the first VPA country is listed on the Annex to the Regulation (expected end 2012). Defra’s Animal Health & Veterinary Laboratories Agency (AHVLA) will be the designated Competent Authority for implementing the FLEGT licensing system in the UK. Please refer to the legislation for more detailed information: http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:277:0023:0029:EN: PDF

EU Timber Regulation: Overview of a Due Diligence System

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EU Timber Regulation: Overview of a Due Diligence System

b)

Risk mitigation: Low and high risk

For manufacturers using forest sources from low risk countries of harvest, basic information including evidence that the products are sourced from these areas is required (please see details listed in Table below). However, if a source is low risk but with a longer and more complex supply chain, companies may decide to employ more rigorous risk mitigation activities, such as by using third party verification. For any manufacturer using forest sources from high risk countries of harvest, more thorough risk mitigation needs to be employed to ensure that the timber is from legal sources and that the information provided is a true and fair reflection of that being supplied.

Examples of risk mitigation based on species and country risk RISK LOW

COUNTRY RISK (origin, manufacture, and/or transit)

HIGH

SPECIES RISK LOW HIGH • Basic information* • Basic information - Ex. Western Red Cedar • Risk mitigation for species - North America - map supply chain and determine complexity/risk, approved management plans, confirmation of supply chain procedures, supplier policies • •

Basic information Risk mitigation for country - to regional level if different, approved management plans, confirmation of supply chain procedures

• • • •

Basic information Risk mitigation for species and country Third party certification, additional legality documents Change supplier

* Basic information to be collected (and verified) as outlined in 3.1.4. It may include: trade name, type of product, common name, scientific name, country of harvest, quantity and supporting documentation.

Tip: Recycled material, although out of scope, may also go through a low risk mitigation process in order to ensure that the material is received as recycled. In addition, few products are made from fully recycled material and any virgin content within a recycled product should be identified and put throuh a risk assessment and risk mitigation procedure.

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EU Timber Regulation: Overview of a Due Diligence System

EU Timber Regulation: Overview of a Due Diligence System

3.3.2 Risk Mitigation: Verification Activities a)

First party: Own Staff Verification

Retailers who have staff with expertise in forestry issues and retail supply chains may undertake their own verification by auditing the supplier and its sources. These auditors must have a detailed reporting mechanism in place to be able to ensure that the supplier meets all elements of the regulation.

b)

Second party: Supplier Verification

Suppliers may also have an assessment programme for their own supply chain. However, as there is no guarantee that the assessors have the required skills or experience to conduct the supplier assessments, it is generally considered to be less credible than those that are verified independently. Therefore, information obtained via the supplier’s assessment programme may require further investigation to verify legal compliance.

c)

Third party: Independent Verification and/or certification

In addition to requirements for further information or documentation, risk mitigation may also include third party verification. Members may choose to appoint an organisation to carry out third party verification by undertaking a detailed audit and review of the supplier and its sources. Auditors must be able to assess sources against each of the legislative components required under the regulation. Certification bodies: FSC and PEFC FSC (www.fsc.org/index.html) and PEFC (www.pefc.co.uk/) are the two main bodies covering third party forest certification globally. Both FSC and PEFC are currently undergoing revisions to their standard to ensure they meet all tenets of the regulation.

Function Forest management units are measured against a set of sustainability criteria and a chain of custody (COC) system that allows certified forest sources to pass through the supply chain to the end user.

Third parties who verify suppliers must, as a minimum, be able to prove legality against the principles outlined in Article 2, paragraph h of the regulation. While many organisations/schemes currently meet many of the due diligence requirements for risk mitigation, at the time of issue none of the standards appeared to meet all requirements of the regulation and are therefore currently not an acceptable proxy for negligible risk (or as stand-alone risk mitigation in its own right).

EU Timber Regulation: Overview of a Due Diligence System

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EU Timber Regulation: Overview of a Due Diligence System

The table below lists a number of certifications and standard systems used globally. However, the list it is not exhaustive and other schemes that meet the regulation requirements may also be used. To obtain an update on schemes best able to verify compliance with the regulation, contact each website for more information. You may also wish to contact organisations such as TFT (www.tft-forests.org/ttap) or membership associations like Timber Trade Federation (www.ttf.co.uk) for additional help.

Overview of some common certifications/standards Example of certification Rainforest Alliance Smartwood Verification of Legal Compliance (SW VLC) SGS Timber Legality & Traceability Verification (TLTV) Verification of Legal Compliance (VLC) Bureau Veritas Origine et Légalité des Bois (BV OBL) Certisource - Legality Verification System SCS Legal Harvest Verification (SCS LHV)

Status: Check website for update www.rainforest-alliance.org/forestry/verification/ legal www.forestry.sgs.com/timber-legality-traceabilityverification-tltv.htm www.bureauveritas.com/wps/wcm/connect/bv_com/ group/services+sheet/service_sheet_14483 www.certisource.co.uk/ www.scscertified.com/nrc/legalharvest.php



d)

Fibre Analysis

For some high risk sources, members may choose to undertake forensic fibre analysis to provide an additional level of assurance. There are a number of testing houses globally that are able to provide this service. Through a number of tests, they are able to identify specific tree species from which the product is made. These can be compared against the information provided to confirm its validity. Fibre testing is not able to detail the country of harvest and so can be used only as a tool to verify information and not as a replacement for data collection and analysis.

e) Alternative sources In cases where none of the above mitigation procedures are available, an alternative forest source and/or supplier should be sought and subjected to the same risk assessment and risk mitigation procedure.

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EU Timber Regulation: Overview of a Due Diligence System

EU Timber Regulation: Overview of a Due Diligence System

4 Overview of Due Diligence 4.1 Summary of steps for Due Diligence INFORMATION GATHERING: Examples of Types of Data (and possible sources) Possible types of information Supplier details (per component/product) Product description

Examples of data

Possible sources of information

May include: address, contact details, relationship history Product name, SKU number

Supplier

Component description

Tree species (per component), Scientific name, common name, synonyms

Supply chain (Names and location of producing paper, sawmill, agent, supplier, and/or manufacturer)

Country of origin (per component) Quantity of each component in the product

Brand names as used by producing mill of any papers. Country and where required sub-national and concession of harvest. Per cent, units, SKU

Retailer contract or internal systems

Invoice, Supplier declaration

Manufacturer

RISK ASSESSMENT: Risk by species and country of origin/manufacturing Types of risk

Examples of data

Possible sources of information

Species risk (per component) Country of origin risk (per component)

May depend on: extinct/ threatened May depend on: conflict/sanctions, perception of corruption, change in forest cover, VPA, reported incidences of illegal practices, evidence of forestry legislation

IUCN red list, CITES, NGO campaigns

Country of manufacturing risk (per product)

May also include country of transit

Overall Risk

Product of species and country risk, AND supply chain complexity

News, third party information (possible sites include global forestry registry NEPCON, EIA, ELDIS, Transparency International, Global Witness etc.), FAO data on forest cover, News, third party information, previous audit reports, certification status, supplier engagement (track record, performance) Retailer specific weightings and risk tolerance

EU Timber Regulation: Overview of a Due Diligence System

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EU Timber Regulation: Overview of a Due Diligence System

RISK MITIGATION: Examples of Possible Mitigation Types of mitigation First party verification of legal origin (per component)

Second party verification (per product or component) Third party audits/ certification of source (per product)

Possible methods (and examples of data) Supplier declaration (including date, signature of senior manager, methods of verification); supporting documentation (harvest licence, land tenure agreement, approved management plans, payment of taxes etc.) Code of conduct assessment, follow up audit, verification of supplier declaration and supporting documentation Audit report (including number assigned)

Third party assessment of first party evidence

Possible sources of information Suppliers (on site or remote)

Retailer, agent (on site or remote)

Third party (on site); check credibility of system/auditor through independent source like CPET *see box on third parties Third party

Desktop verification of supplier declaration and supporting documentation Supply chain verification of Chain of custody audit reference, Third party product to source invoice/proof of purchase (per component from last point of intact certification to final product). Re-source raw materials/ n/a n/a component/ product

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EU Timber Regulation: Overview of a Due Diligence System

EU Timber Regulation: Overview of a Due Diligence System

4.2 Summary: Examples of how the system might work Using steps outlined in Section 3, the following examples show how DD systems can be applied to specific products as outline in 3.12.

Example 1: Non-Complex Low Risk Supply Chain This is a non-complex supply chain. The forest sources are not high risk species and from a low risk country of harvest. None of the links in the supply chain are certified. The solid wood door is sourced Direct (FOB) and the retailer is considered to be the Operator.

Solid Wood Door

Step 1. Information Request Step 1. Information Provided

LOW RISK

SAW MILL

TIMBER MERCHANT

WOOD DOOR MANUFACTURER

Sourced Direct

Step 3. Risk Mitigation required As the tree species and the country of harvest is low risk, a low risk mitigation process is required. Information required includes: 1. Proof of supply of forest material: Evidence showing that the manufacturer has purchased timber material from the timber merchant. This may be included on a supplier invoice or on a separate document. It should include detail of the tree species and country of origin of the timber used in the wood or components bought. 2. Proof of use in product: The manufacturer should then provide evidence, in the form of a declaration on an invoice or other documentation, that this material was used in the wooden door supplied to the retailer. Confirmation of tree species and country of harvest are also necessary on this documentation.

AGENT

In each of the examples products are sourced direct or FOB and so retailers take on the role of operators and are required to go through the Due Diligence process outlined above. If it is a ‘domestic product’ / landed by a UK agent , retailers take on the role of trader and are required to manage a traceability system which allows them to identify who products were bought from (the operator) and to whom they were sold – if it were onto another trader.

RETAILER

Step 2. Risk Assessment

Outcome: low risk sources

EU Timber Regulation: Overview of a Due Diligence System

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EU Timber Regulation: Overview of a Due Diligence System

Notebook

Example2:HighriskcomplexsupplychainwithbrokenCOC:Thisisacomplexsupplychainwith multiplemanufacturinglinks.Itincludesamixofhighandlowriskforestsources.Thehighrisk forestsourcesarecertifiedtoFSCandPEFCbutthechainofcustody(COC)isbrokenasthesecond papermerchanthasnocertification. Step1.InformationRequest Step1.InformationProvided Step2.RiskAssessment

LOWRISK

PULPMILL

Outcome:lowandhighrisksourceswithbrokenchainofcustody.

+ COC LOWRISK

PAPERMILL

PULPMILL

+ COC HIGHRISK

PULPMILL

HIGHRISK

PULPMILL

No COC PAPER MERCHANT

PAPER MERCHANT

NOTEBOOK MAKER

Sourced Direct

RETAILER

Step3.RiskMitigationRequired:Amixedapproachisnecessary: a. ForLowRiskSources: Alowriskapproachproviding 1.proofofsupplyofforestmaterialand 2.proofofuseinproduct.(thesameasthesolidwooddoorexample) b. ForHighRiskSources:Thirdpartycertificationisneeded. ThePEFCchainofcustodyisbroken.So,theinformationneededisasfollows: 1.thesameinformationrequiredforthelowrisksources, 2.AdditionalinvoiceevidencetracingthetimbermaterialbacktolastinͲtactchainof custodyforthePEFCsources(i.e.PaperMill). Invoiceorotherdocumentaryevidencethatincludesspeciesandcountryoforigin informationtoshowthatthePEFCmaterial(althoughnolongercertified)hasbeen passedontothenextstepinthesupplychainisnecessary.

Bookcase

Example3:FullyCertifiedComplexSupplyChain:Thisisacomplexsupplychainwithmultiple manufacturinglinks.Itincludesamixofhighandlowriskforestsources.Allforestsourcesare certifiedtoFSCandthereisanintactchainofcustody(COC)sothattheproductcanbecertified.It issuppliedFOBviaanagent– theretailerisconsideredtobetheoperator. Step1.InformationRequest Step1.InformationProvided

SUB CONTRACTORS

PAPER/SAW MILL/CONVERTER

COC

Solids HIGHRISK & LOWRISK

COC

COC

MATERIAL PROCESSORS

COC

COC

Veneer

COC

RETAILER

MANUFACTURER COC

FOB AGENT

Composites

Laminatedfoil Step3.RiskMitigationrequired Ͳ Asassessmentshowshighrisksources,thefollowingisrequired: 1.ThirdPartyCertificationͲ Asthecountryofharvestortreespeciesishighriskcertificationisrequired. IntheexampleFSCisusedhoweverPEFCorotherverificationoflegalorigincouldalsobeused. 2.Proofofsupplyofforestmaterial:Invoiceorotherevidenceshowingthemanufacturerisbuyingthe certifiedmaterialfromitssuppliersandinformationonthetreespeciesandcountryofharvestare required. 3.Proofofuseinproduct:Evidence(invoiceorother)thatthemanufacturerisusingthesesourcesinthe productssuppliedtotheretailer– includingdetailsofspeciesandcountryofharvest.

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EU Timber Regulation: Overview of a Due Diligence System

Step2.RiskAssessment

Outcome:therearelow andhighrisksources.

EU Timber Regulation: Overview of a Due Diligence System

5 Glossary BRC: British Retail Consortium Certification: The process by which forest units can measure themselves against a set of criteria to prove that they are managing the forest in a legal and/or sustainable manner. Chain of Custody (COC): A system of identifying the movement of certified material through a supply chain. It requires a robust management system at each stage in the supply chain to show the movement of material through the production process and onto the next stage in the supply chain. Common name: Referring to a tree species, the common name is attributed to a tree species by a local community and this and can be linked to a scientific name. There may be multiple common names for one tree species (or one common name for multiple species) depending on the location in the world. Complex supply chains: Supply chains in which there are numerous links in the supply chain from forest through to final production of the end product. Concession of harvest: A given area of forested land that has been allocated by the government of that country to a timber company. Country of harvest: The country in which a tree is grown and harvested for commercial use. EUTR: European Union Timber Regulation. FSC: The Forest Stewardship Council, an international certification body that certifies forests against a set of legality and sustainability criteria and certifies each stage in the supply chain against a chain of custody standard. Products that hold an in-tact chain of custody can be labelled as FSC certified. Direct import products: Products supplied directly from a manufacturer to a retailer. Domestic products: Products that are supplied via an EU-based agent who has taken responsibility for importing the given product into the EU. Due Diligence System: An approach to identify and mitigate the risk of illegal logging in the supply chain. FLEGT Action Plan: The Forest Law Enforcement, Governance and Trade (FLEGT) Action Plan sets out a range of measures available to the EU and its Member States to tackle illegal logging in the world’s forests. FOB: Free On Board. The buyer of the goods takes ownership once they have been loaded on to the cargo ship at the port of loading, and the responsibility for the freight, any insurance, the off-loading at the port of arrival and the clearing of customs at the port is the buyer’s responsibility. Illegal sources: Any tree species cut down in contravention of the laws in that country. Applicable laws include; a) the rights to harvest timber within legally gazetted boundaries, b) the payments for harvest rights and duties related to timber harvesting, c) environmental and forest legislation including forest management and biodiversity conservation relating to timber harvesting, and d) trade and customs relating to the timber.

EU Timber Regulation: Overview of a Due Diligence System

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EU Timber Regulation: Overview of a Due Diligence System

Illegal harvesting: See ‘illegal sources’. Landed products: Those where the supplier of the goods is responsible for the freight, any insurance, the discharge of the product at the arrival port, and the clearing of customs. The Timber Group: Refers to members of the BRC’s Timber Working Group that contributed to this document. Timber material: The forest species and country of harvest of a timber or timber product. Manufacturer: The last convertor in the supply chain who brings various components together into a final product to be supplied either directly or via an agent to a retailer. Monitoring organisation: A private entity (company, association) that develops and maintains a DD system, making it available for use by an operator. All MOs must be legally established within the EU and approved by the competent authority. Operators: Organisations that place timber or timber products on the EU market for the first time – products that fall under the operator responsibility are typically termed ‘direct import’ products. Operators are required to operate a due diligence process for these products. PEFC: The Programme for the Endorsement of Forest Certification is an international certification body that certifies national forest standards against a set of legality and sustainability criteria. Each stage in the supply chain is then certified against a chain of custody standard. Products that hold an intact chain of custody can be labelled as PEFC certified. Product specifications: Properties vary by retailer but might include the technical properties of the product (size, weight, dimensions), its look and feel, safety requirements, and sometimes the raw materials that should be used in the product. These specifications guide the supplier as to the product being produced. Quantity: For the purpose of the legislation this shall be measured as number of units imported. Scientific name: Referring to a tree species, the scientific name is an internationally recognised name given to a specific species of plant or animal and allows international identification of the same species. It often has many common names by which it is referred. Traders: An organisation that sells or buys on the internal market (i.e. within the EU) timber or timber products already placed on the internal market. Products that fall under trader responsibility are typically termed domestic products. Traders are required to manage a traceability system which allows them to identify who products were bought from (the operator) and to whom they were sold – if onto another trader. This information should be held for five years and be presented to regulating authorities if required. Trade Name: The trade description of the product (i.e. the name it is sold under). Type of Product: A product description (e.g. a notebook). Verification of Legal Compliance: A number of schemes are available to provide verification of legal compliance which simply verifies that forest sources have been harvested in accordance with applicable legislation in the country of harvest. 26

EU Timber Regulation: Overview of a Due Diligence System

EU Timber Regulation: Overview of a Due Diligence System

VPA: Voluntary Partnership Agreement’s are part of the FLEGT Action Plan and are agreements that have been signed between the EU and participating producer countries. These agreements put in place systems to license timber and timber products as being legal. This timber meets the EUTR requirements.

6 Annex A Below is a list of commercial timber species imported into the UK (by common name/scientific name) (Source: Rachel Butler, International Timber Trade Federation).

This list is provided as a reference tool for commonly imported timber species but is not comprehensive and does not include possible sources for paper and packaging. Please consult additional resources for tree species not listed. Trade Name

Botanical Name Natural Forest Hardwood

Origin

African Mahogany

Khaya species

West & Southern Africa

African Walnut

Lovoa trichilioides

West, Central, Southern Africa

Afrormosia*

Pericopsis elata

West Africa

Afzelia

Afzelia Africana

West Africa

Agba

Gossweilerodendron balsamiferum

Nigeria

Ako, Antiaris

Antiaris Africana

West, Central, East, Southern Africa

Alder, Common/Black

Alnus glutinosa

Europe

American Ash

Fraxinus species

North America

Amescla

Protium species

South America

Andiroba

Carapa guianensis

South America , West Indies

Angelim

Hymmenolobium species

South America

Angelim.Vermelho

Dinizia excelsa

Brazil, Guyana

Antiaris, Ako

Antiaris Africana

West, Central, East, Southern Africa

Ash, European

Fraxinus excelsior

Europe

Aspen, Canadian

Populus tremuloides

North America

Aspen, European

Populus tremula

Europe

Badi, Opepe

Nauclea diderrichii

West Africa

Balau, Selangan Batu

Shorea species

South East Asia

Balsa

Ochroma lagopus

South America

Bangkirai

Shorea laevifolia

Indonesia

Basswood

Tilia americana

North America

Beech, American

Fagus grandifolia

North America

Beech, European

Fagus sylvatica

Europe

Bintangor

Calophyllum species

Indonesia, Papua New Guinea

Binuang

Octomeles sumatrana

Indonesia

Birch

Betula species

China, North America

Birch, European

Betula pubescens

Europe, Russia

Cabreúva

Myroxylon species

Central , America Brazil

Cambara

Erisma uncinatum

Brazil

Cedar, South American, Spanish,

Cedrela odorata

South & Central America

Cedrinho

Erisma or Scleronema species

South America

EU Timber Regulation: Overview of a Due Diligence System

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EU Timber Regulation: Overview of a Due Diligence System

28

Cedrorana

Cedrelinga species

Brazil

Celtis

Celtis species

West, Central, East Africa

Chengal

Neobalanocarpus / Balanocarpus heimii

Indonesia, Malaysia, Thailand

Cherry, American

Prunus serotina

North America

Cherry, European

Prunus avium

Europe

Cumaru

Dipterix odorata

South & Central America

Cupiúba

Goupia glabra

South America

Curapixa

Anadenanthera macrocarpa

South America

Ebony

Diospyros species

West Africa

Edinam, Gedu Nohor, Kalungi, Tiama

Entandrophragma angolense

West, Central, East Africa

Ekki

Lophira alata

West Africa

Elm, American

Ulmus americana

North America

Elm, European

Ulnus species

Europe

Elm, White

Ulmus americana

North America

Emeri, Idigbo

Terminalia ivorensis

West, Central Africa

Faveira

Pterodon species

South America

Framire, Afara

Terminalia superba

West Africa

Fromager, Ceiba

Ceiba pentandra

West Africa

Gaboon, Okoume

Aucoumea klaineana

West Africa

Garapeira

Apuleia species

South America

Garrote, Tatajuba

Bagassa guianensis

South & Central America

Gedu Nohor, Edinam, Kalungi, Tiama

Entandrophragma angolense

West, Central, East Africa

Greenheart

Ocotea rodiaei

Guyana

Guarea

Guarea cedrata & G. thompsonii

West Africa

Gum, Sweet

Liquidambar styraciflua

North America

Hickory

Carya sp

North America

Horse Chestnut

Aesculus hippocastanum

Europe

Idigbo, Emeri

Terminalia ivorensis

West, Central Africa

Ipês

Tabebuia species

Brazil

Iroko

Melicia excelsa

West, Central, Southern Africa

Itaúba

Mezilarus itauba

South America

Jarrah

Eucalyptus marginata

Australia

Jatobá

Hymenaea species

South America

Jelutong

Dyera costulata

South East Asia

Kalungi, Edinam, Gedu Nohor, Tiama

Entandrophragma angolense

West, Central, East Africa

Kapur

Dryobalanops species

South East Asia

Karri

Eucalyptus diversicolor

Australia

Kempas

Koompassia malaccencis

South East Asia

Keruing

Dipterocarpus species

India, Sri Lanka, South East Asia

Khaya

Khaya species

West & Southern Africa

Koto

Pterygota bequaertii & P.macrocarpa

West Africa

Larch

Larix decidua L.europaea

Europe

Lauan, Red

Shorea species principally S. pauciflora

Philippines

Lauan, White

Shorea species

Philippines

Lignum Vitae*

Guaiacum sanctum / Guaiacum officinale

Central America

Lime, American

Tilia americana

North America

Lime, European

Tilia species

Europe

Louro Vermelho

Sextonia species

South America

EU Timber Regulation: Overview of a Due Diligence System

EU Timber Regulation: Overview of a Due Diligence System

Maçaranduba

Manilkara huberi

South America

Maho

Sterculia pruriens

South America

Mahogany, Brazilian, Central American*

Swietenia macrophylla

South America

Makore

Tieghemella heckelii

West Africa

Maple, Hard or ‘Rock’

Acer saccharum

North America

Maple, Soft

Acer saccharinum

North America

Marupá

Simaruba amara

South America

Massaranduba

Manilkara bidentata

South America

Meranti, Dark Red

Shorea species principally S. pauciflora

South East Asia

Meranti, Light Red Asia

Shorea species

South East Asia

Meranti,Yellow

Shorea species

South East Asia

Merawan

Hopea species

South East Asia

Merbau

Intsia palembanica & Intsia bijuga

South East Asia, south west Pacific islands

Mersawa

Anisoptera species

South East Asia

Muiracatiara

Astronium species

South & Central America

Niangon

Heritiera utilis

West Africa

Nyatoh

Palaquium species

South East Asia

Oak

Quercus species

China

Oak, American Red

Quercus rubra and Quercus falcata

North America

Oak, American White

Quercus alba and Quercus prinus

North America

Oak, European

Quercus robur and Quercus petraea

Europe

Oak, Japanese

Quercus mongolica

Japan

Oak, Tasmanian

Eucalyptus Regnans, Eucalyptus Obliqua, Eucalyptus Delegatensis

Tasmania

Obeche, Wawa, Samba

Triplochiton scleroxylon

West Africa

Okoume, Gaboon

Aucoumea klaineana

West Africa

Opepe, Badi

Nauclea diderrichii

West Africa

Padauk

Pterocarpus Indicus

South East Asia

Paricá

Schizolobium amazonicum

South America

Peroba

Aspidosperma species

South America

Piquiá

Caryocar species

South America

Plane, European

Platanus hybrida

Europe

Poplar

Populus species

Europe, China

Poplar,Yellow, Tulipwood

Liriodendron tulipifera

North America

Purpleheart, Roxinho

Peltogyne species

South & Central America

Ramin*

Gonystylus species

South East Asia

Rimas

Duabanga moluccana

Indonesia

Roxinho, Purpleheart

Peltogyne species

South & Central America

Samba, Obeche, Wawa

Triplochiton scleroxylon

West Africa

Sapele

Entandrophragma cylindricum

West Africa

Seraya, Dark Red

Shorea species principally S. pauciflora

South East Asia

Seraya, Light Red

Shorea species

South East Asia

Seraya,Yellow

Shorea species

South East Asia

Sipo, Utile

Entandrophragma utile

West Africa

Sucupira Vermelha

Diplotropis species

South America

Sumaúma

Ceiba species

South America

Sweet Chestnut

Castanea sativa

Europe

Sycamore

Acer pseudoplatanus

Europe

EU Timber Regulation: Overview of a Due Diligence System

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EU Timber Regulation: Overview of a Due Diligence System

30

Tatajuba, Garrote

Bagassa guianensis

Central & South America

Tauari

Couratari species

South America

Teak

Tectona grandis

India, South East Asia

Tiama, Gedu Nohor, Edinam, Kalungi, Tiama

Entandrophragma angolense

West, Central, East West Africa

Tulipwood,Yellow poplar

Liriodendron tulipifera

North America

Utile, Sipo

Entandrophragma utile

West Africa

Vene False.teak, African Rosewood

Pterocarpus erinaceus

West Africa

Virola

Virola and Dialyanthera species

South America

Walnut, African

Lovoa trichilioides

West Africa

Walnut, American

Juglans nigra

Eastern USA and Canada

Walnut, European

Juglans regia

Europe

Wawa, Samba, Obeche

Triplochiton scleroxylon

West Africa

Wenge

Millettia stuhlmannii

Central & Southern West Africa

Willow

Salix species

Europe, Western Asia

Trade Name

Botanical Name Natural Forest Softwood

Origin

Cedar, Western Red

Thuja plicata

North America

Cedar,Yellow

Chameacyparis nootkatensis

North America

Douglas Fir

Pseudotsuga menziesii

North America

Fir

Abies species

China, Europe

Fir, Silver

Abies alba

Europe

Hemlock, Western

Tsuga heterophylla

North America

Larch

Larix species

China

Larch, European

Larix decidua L.europaea

Europe

Larch, Siberian

Larix decidua L.europaea

Europe

Pine

Pinus species

China

Pine

Pinus sylvestris

Europe

Pine, Caribbean/Pitch

Pinus caribaea

British Honduras

Pine, Eastern White

Pinus strobus

North America

Pine, Lodgepole

Pinus contorta

North America

Pine, Maritime

Pinus pinaster

Europe

Pine, Parana

Araucaria angustifolia A. brasiliana

Brazil

Pine, Quebec Yellow

Pinus strobus

North America

Pine, Scots

Pinus sylvestris

Europe

Pine, Southern Yellow

Pinus palustris, P. eliotti

North America

Pine,Yellow

Pinus palustris

North America

Redwood

Pinus sylvestris

Europe

Spruce

Picea abies P.excelsa

Europe

Spruce Silver

Picea Sitchensis

North America

Spruce, European

Picea abies P.excelsa

Europe

Spruce, Sitka

Picea sitchensis

Europe

Whitewood

Picea abies P.excelsa

Europe

Yew

Taxus baccata

Europe

EU Timber Regulation: Overview of a Due Diligence System

EU Timber Regulation: Overview of a Due Diligence System

Trade Name

Botanical Name Plantation

Origin

Acacia

Acacia species

South America

Acacia mangium

Acacia mangium

Australia, Malaysia

African mahogany

Khaya species

West Africa

Araucaria

Araucaria species

Malaysia

Araucaria

Araucaria angustifolia

South America

Broadleaved Tea tree

Melaleuca quinquenervia

Indonesia

Cedar

Cedrela species

China

Cedrella*

Cedrela odorata

West Africa

China Fir

Cunninghamia lanceolata

China, Taiwan,Vietnam

Eucalyptus

Eucalyptus species

South America

Eucalyptus

Eucalyptus grandis, deglupta, other species

South East Asia

Falcata

Albazia Falcata

Indonesia

Fir

Abies species

China

Gmelina

Gmelina arborea

Asia, West Africa

Kamarere

Eucalyptus deglupta

South East Asia

Larch

Larix species

Europe

Larch, Japanese

Larix Kaempferi L. leptolepis

UK

Moluccan albizia

Falcataria moluccana

South East Asia

Ofram

Terminalia superba

West Africa

Parica

Schizolobium amazonicum

South America

Paulownia

Paulownia

China

Peacock plume

Paraserianthes falcataria

Malaysia

Pine

Pinus species

Europe, South America

Pine

Pinus merkusii, P. caribaea other species

South East Asia

Pine, Parana

Araucaria angustifolia A. brasiliana

South America

Pine

Radiata Pinus radiata, P.insignis

Oceania

Poplar

Populus

China, Europe

Rubberwood

Hevea brasiliensis

Malaysia, South America, West Africa

Spruce

Picea species

Europe

Teak

Tectona grandis

India, South East Asia, South America, West Africa

© British Retail Consortium. The information contained in this publication is for general guidance and information only. You should neither act, nor refrain from action, on the basis of any such information. Whilst the BRC endeavours to ensure that the information in this publication is accurate, the BRC shall not be liable for any damages (including without limitation, damages for loss of business or loss of profits) arising in contract, tort or otherwise from this publication or any information contained in it, or from any action or decision taken as a result of reading this publication or any such information. Concept/Design: Composite Photograph: Printed:

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EU Timber Regulation: Overview of a Due Diligence System

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For further information please contact: Catherine Pazderka British Retail Consortium 21 Dartmouth Street London, SW1H 9BP 020 7854 8956 [email protected]

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