70 | Feature: UKTR
SUMMARY
■ The UKTR came into force on January 1 this year
■ Due diligence now has to take place on 62% of UK timber imports
■ The process mirrors that of the EUTR
THE ABC OF UKTR A TTF webinar laid out the operation and implications of the UKTR. Mike Jeffree reports
the UKTR by operator importers, mirrors that of the EUTR. Companies have to map supply chains back to the timber’s point of origin and undertake due diligence risk assessment of illegal timber entering it at any point. Where that risk is deemed not negligible, they must take mitigation action, such as provision of additional documentation, to ensure that it is.
Above: Under UKTR all imports from the EU are subject to due diligence unless recycled or CITES certificated
“So the components and threshold of due diligence are unchanged. What has changed is that the scope of requirement to undertake due diligence under the UKTR is expanded to include the EU and supply chains running through it,” said Mr Hawkes.
Introducing the recent TTF webinar on the UK Timber Regulation (UKTR), head of technical and trade Nick Boulton made clear the scale of the change involved in the UK’s switch from the EUTR.
“Previously under the EUTR, UK timber importers had to undertake due diligence against risk of illegality on timber from outside the EU. This represents about 10% of total consumption,” he said. “Since the change to the UKTR on January 1 2021, we also have to apply due diligence to imports from EU countries, which account for 52% of UK timber consumption. Moving from due diligence on 10% of imports to 62% is a massive leap and many of the issues won’t be solved overnight and will need an ongoing process of communications.” The core part of the webinar was an explanation of the exact implications of the UKTR for UK timber plc from Adrian Hawkes, timber regulation enforcement team leader at the UK Competent Authority for the UKTR and FLEGT, the Office of Product Safety and Standards (OPSS).
He stressed that the process of due diligence, which must be undertaken under
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“So, whereas before under the EUTR, UK operators were companies which first placed timber for sale on the EU market and traders companies which bought from companies which first placed timber on the EU market, Great Britain operators are now under the UKTR companies which first place timber on the GB market. Traders are companies which buy from these GB operators.” This effectively means that, whereas companies that bought from continental- based EU suppliers were previously traders, they are now classified operators, with the obligation to undertake due diligence that entails.
Where the situation is different is Northern Ireland. This is due to the deal on the province’s status under the UK’s EU withdrawal agreement, which means it still operates under the EUTR, and the Northern Ireland Protocol, which states that no new checks should apply on trade from Northern Ireland to Great Britain, ie Scotland, Wales and England.
Four scenarios arise from this situation, said Mr Hawkes.
If timber is imported into Northern Ireland from GB, the Northern Ireland importer will be an operator under the EUTR and have to undertake due diligence. But if timber is imported from a Northern Irish supplier into
GB, due to the Northern Irish Protocol, the GB importer has no due diligence obligation. “And if timber is moving from the EU to Northern Ireland, the Northern Irish buyer is a trader as they are still covered by the EUTR [so again there is no due diligence obligation],” said Mr Hawkes.
On GB operators’ due diligence of their EU suppliers, he added, it was not sufficient to state that the supplier had already carried out due diligence under the EUTR. “The UKTR requires the operator to have access to the documentation of the due diligence system and to make that information available to the OPSS on request,” he said. “You have to satisfy yourself that there is negligible risk of illegal timber entering your supply chain back to country of harvest, or in higher risk cases back to the sub-national region or forest of harvest.” He also underlined that, under the UKTR, the EU is not regarded as a homogenous area in terms of illegality risk. So GB operators must risk assess each country and potentially regions within countries. Timber imports exempt due diligence under the UKTR are those accompanied by a CITES certificate, recycled material proven to be at the end of its previous lifecycle, and FLEGT licensed material, currently only available from Indonesia, provided it is imported direct from the latter. FLEGT-licensed material imported from the EU into the UK must undergo due diligence. ■
FURTHER INFORMATION
The TTF webinar, which included a Q&A session, is available to view at:
https://bit.ly/2TSmGYG
An OPSS guidance document to the UKTR can be downloaded at:
https://bit.ly/3gVoUhP
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