Following the Brexit agreement, the UK government has confirmed the practical implications of the UK Timber Regulation replacing and replicating the EU Timber Regulation for British, Northern Irish and EU/EEA businesses.
British businesses importing from the EU need to carry out timber due diligence:
British businesses who import certain timber & timber products from the EU/EEA are now considered operators – first placers of timber into Great Britain. Previously, as they were purchasing products already placed in the EU market they would have been ‘traders’ with limited responsibilities (maintain records of suppliers and clients for 5 years). As operators under the UK Timber Regulation (UKTR) British businesses have to implement due diligence systems to confirm the timber is legally harvested.
These are the same due diligence requirements businesses have had for products purchased from the rest of the world since 2013 (FLEGT and CITES permit timber do not require due diligence). However, since a considerable proportion of timber purchased by UK businesses is from within the EEA, this will represent a significant change for many in UK industry.
The core pillars of due diligence are 1) information gathering 2) risk assessment 3) risk mitigation. For more information on how to implement due diligence see here.
Find out which timber products are covered here.
European importers of British products need to carry out timber due diligence:
British exporters to the EU/EEA need to provide supply chain documentation to their clients so that they can perform due diligence on the legality of the timber. Britain is now a ‘third country’ to the EU, therefore European buyers (now also defined as operators) need to perform due diligence on their products from Britain as they would on products from the rest of the world. Information including country of harvest and production, species, certification status, and suppliers information is all needed to ensure a product can be risk assessed.
No change for Northern Irish businesses importing and exporting to and from the EU/EEA:
Due to the Brexit deal between the UK and EU, the EUTR still applies in Northern Ireland. Products traded between Northern Ireland and the EU/EEA are considered within the single market with no due diligence requirements. Businesses should maintain records of their timber purchases and sales for five years.
Northern Irish businesses need to perform timber due diligence on British products:
Due to the above arrangement, Northern Irish businesses must apply the EUTR due diligence rules on applicable timber products purchased from Great Britain. Timber carrying FLEGT license and CITES import permits are considered legal and do not require due diligence.
British businesses importing timber products from Northern Ireland do NOT need to perform due diligence under the UKTR:
The UK authorities have defined British businesses who buy timber already placed on the Northern Irish market to be traders, rather than operators.
Only operators have the full due diligence requirements under the scope of the UKTR.
Need help with the changes?
These changes represent a new burden for many businesses trading with the EU, in addition to the rules of origin requirements.
For more information on how to manage your timber legality for the EU and UK Timber Regulations please feel free to talk to one of our experts. We can also offer free demonstrations of our proven compliance solution on RADIX Tree.