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Above left: Indonesia is a BMRC member, with Cameroon, Ghana, Liberia, the Republic of the Congo and Guyana Above right: The BMRC will endorse and promote members’ National Sustainable Forestry Systems PHOTO: IMM


As such, it is hardly a surprise that neither the private sector nor the European Commission seemed ready in time to implement the regulation. A delay was therefore inevitable.


As the leading trade body representing timber importers and global supply chains in the UK, Timber Development UK (TDUK) has run regular workshops to bring members up to speed. Many of these have run in conjunction with importers and processors of other commodities which will be affected by the EUDR – supermarkets and other retail firms.


It was surprising to our members to see how little preparation many of the other sectors had done. The timber industry has been conducting due diligence for many years, so most of the EUDR compliance will not require a huge sea change in business compliance. But, for much of the agricultural sector there is a steep learning curve to climb.


Having said that, there are still complications for our sector. Stipulating that all timber firms must obtain verified geo-location data showing that each plot of land is within “a single real-estate property” is nigh on impossible for many smaller, non- industrial forest businesses across the world, giving an even greater market advantage to the bigger players.


It is this point that has caused such headaches for American hardwoods, for example, which have an exemplary record on sustainable management and harvesting with negligible risks and demonstrable proof of forest growth, but which are owned by a network of very small landowners and growers. They are now working on their own system to be compliant with the EUDR, but


this will take time and would not have been ready for the initial implementation date. The real question that has to be asked, however, is whether the EUDR will really have the impact that the European Commission and the NGOs claim for it, particularly in tropical regions. The new regulation doesn’t contain a credible mechanism for improving or investing in the governance systems of producer countries in order to regulate the vast majority of forest-risk commodities which are not destined for the European markets.


It is these areas, outside of the larger certified corporate concessions, which really need help to improve their operations and meet the standards required for international exports and lower the risk rating of the entire country. Previously, under the FLEGT Action plan, of which EUTR was a part, the Voluntary Partnership Agreements (VPAs) formed a legally binding commitment between the EU and producer country to create a credible timber legality assurance system, underpinned by forest management verification and monitoring for all timber production within the country, regardless of where that timber was being sold. The VPAs have been heavily criticised, but they achieved good results in improving traceability, transparency and governance in a lot of timber producing countries regardless of whether they achieved FLEGT licensing.


The EUDR originally contained a similar mechanism for partnership under EUDR Article 30. This was meant to develop a comprehensive framework for all EU countries and involve the full participation


of stakeholders including civil society, indigenous peoples, local communities, women and small holders.


On publication of the delay though, this whole section was watered down so it now only focuses on technical and development co-operation.


It contained no detail of how any bilateral partnerships between producer countries and the EU could take place. There is no onus on the EU to do anything, and no reciprocal responsibility mentioned. Yet, it is this investment in national governance systems, along with long-term responsibility towards trading partners, that would make all the difference to forest landscapes, aligning legal compliance in-country with the needs of the EUDR in Europe.


That’s why initiatives such as the Broader


Market Recognition Coalition (BMRC) – www.forestgovernance.org – are so important. They realise that if we want to tackle national level deforestation, we need robust national governance systems in place and ways to recognise them in the marketplace. It’s in all our interests to maintain the forest, tropical and temperate, as a key climate change mitigator and reserve of biodiversity, as well as an invaluable timber resource. To achieve that, it’s not enough that consumer countries just shut the door on forest products they decide don’t come up to their standards. All, consumer and producer countries alike, must play their part in establishment of effective, workable forest governance frameworks that assure legality and sustainability internationally. Until that happens, for all the lofty rhetoric, I fear the EUDR will create a lot of sound and fury while signifying very little. ■


www.ttjonline.com | November/December 2024 | TTJ


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