Supply Chain Safety Measures

As talks surrounding the Brexit trade deal continue it is worth remembering that things will change at the start of 2021. The timber supply chain must look to continue to secure legality in supply chains and employ suitable ‘due diligence’.

rom 1 Jan 2021, all UK businesses importing timber from Timber Regulation. Users of the tool will be provided with the essentials F the EU/EEA and outside will be classified as Operators and are required to carry out due diligence under the of due diligence and gain knowledge of: UK’s timber legislation, and vice versa under the well- • Common high-risk factors to avoid understood EU Timber Regulation. • What/ how to report due diligence actions and outcomes

The latest advice from the Foreign Commonwealth & Development • Country case studies (e.g. China) + factory checklist Office (FCDO is when importing legally harvested timber, you’ll need to carry • Useful contacts and references. out due diligence and use a due diligence checklist to make sure you gather information on the timber – its species, quantity, supplier, country of harvest This tool has been developed by TTF with support from the and how it complies with relevant laws, assess the risk of timber being illegal Soil Association as part of a FCDO-funded project. This tool will be by applying the legal criteria and mitigate any identified risk, by getting more continuously reviewed and updated. “With this free, interactive tool, information or taking further actions to confirm the timber is legal. timber firms in the UK are gaining a fantastic new resource to undertake

If the timber has a Convention on International Trade in Endangered and report due diligence,” said David Hopkins, TTF CEO. Species (CITES) import permit, the UK will recognise it as ‘legally “This is particularly important for those firms which may find themselves harvested’ and you will not need to carry out due diligence on this timber. facing an expanded set of obligations as we shift from EU Timber You’ll still need to carry out due diligence to confirm the timber is legally Regulation to UK Timber Regulation. harvested if you’re: “As the UK exits the EU Single Market, businesses importing into the • A business importing from non-EU or EEA countries confirming that the timber product placed on the UK market has been  • A UK producer placing timber on the market for the first time • Carrying out internal UK trade. As UK companies prepare for conducting due

To help its members and industry as a diligence for timber products imported from the whole, the Timber Trade Federation (TTF) EU mainland, this toolkit is aimed to also help new has launched a due diligence toolkit to help Operators to get on board and ensure that they have companies importing and exporting timber and timber products better understand, conduct the minimum tools to deliver the requirements. and report due diligence under the EU/UK UK from the European Economic Area will need to carry out due diligence

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legally harvested to meet the UK Timber Regulations. This will be a change for many members, with Europe still supplying the majority of all UK timber imports. It will be important all our members ensure they have a due diligence system in place to identify areas of potential risk where illegal timber may enter the supply chain.

“These due diligence changes will not be onerous for members embracing our world leading Responsible Purchasing Policy (RPP) system, and with this tool, members will find the process of understanding, conducting, and reporting under RPP to be simpler, and more straightforward. All TTF members are subject to our mandatory RPP, which helps ensure that purchasers buying from TTF members receive timber that you can trust.”

Legislation to tackle illegal logging under the EU Timber Regulation has been in place since 2013 and will continue through the UK Timber Regulation. One of the ultimate objectives of these timber regulations is to ensure companies take responsibility for their own actions. Business  EUROPEAN PRESSURES

MEPs recently called on the European Commission to put forward rules to stop ‘EU-driven global deforestation’ through mandatory due diligence for companies placing products on the EU market, saying:

“Currently, there is no EU legislation prohibiting products that contribute to the destruction of forests from being placed on the European market and consumers do not know whether or not the products they buy contribute to deforestation.” The Environment, Public

Health and Food Safety Committee adopted a report in October calling on the Commission to present an EU legal framework to halt and reverse EU-driven global deforestation. MEPs say that voluntary initiatives, third-party certification and labels have so far failed to halt deforestation worldwide.

They have called for a new EU legal framework based on mandatory due diligence, reporting, disclosure and third need to actively look into the sources of their timber to make their own assessments and show that they have done so. “There is a misconception that due diligence equates to paperwork such as permits,” says TTF sustainability manager Xiao Ma. “While it is true, compared with non-tangible information, such as industry insight and supplier engagement activities, paperwork is the most presentable type of input and output, but it is not the full package of due diligence. “Paperwork, whether permits or customs slips, are much easier to be passed around, understood by, and presented as evidence. However, it is only when supported by checks and follow up actions to which round out the reasoning by a firm that a product represents a ‘negligible’ risk conclusion, paperwork can be deemed as evidence of due diligence. “This can be a challenge for many SMEs who often do not have the capacity of time, human capital, or technical expertise and may rely on paperwork as the ultimate evidence of their actions. To make this work, companies required to exercise due diligence will also need the support from industry stakeholders including independent NGOs and forest monitors. This is not only about exchange of information on risks but to support the ‘translation’ of risks into actionable and sustainable mitigation measures on the ground.

“The toolkit serves as a guidance for conducting due diligence and aims to encourage companies examine their own existing procedure to ensure key criteria, risk factors, stakeholder information, and mitigation actions are not being missed during their process. It also aspires to encourage better reporting of companies on the full range of their input and actions taken, beyond just paperwork. As UK companies prepare for conducting due diligence for timber products imported from the EU mainland, this toolkit is aimed to also help new Operators to get on board and ensure that they

More at  www.ttf.co.uk/members/due-diligence-toolkit

have the minimum tools to deliver the requirements.” party participation requirements. Penalties should be introduced for companies that place products on the EU market derived from commodities that endanger forests and ecosystems. All operators on the EU market must ensure that their products can be traced to be able to identify their origin and ensure the rules are enforced. MEPs state that such an EU legal framework should also be extended to include high-carbon stock and biodiversityrich ecosystems other than forests, such as marine and coastal ecosystems, wetlands, peatlands or savannahs, to avoid pressure being shifted onto these landscapes. The Commission should also provide binding definitions of what constitutes deforestation and forest degradation. This underlined how EU trade and investment policy should include binding and enforceable sustainable development chapters that fully respect international commitments.