29 January 2025

If a tree falls in a forest and no one hears it…

This either sounds like the start of a joke or prosaic saying, but maybe the answer should be “that may be the sound of illegal de-forestation”.

The UK Timber Regulation aims to close the market to uncontrolled/illegal flows of timber and timber products by ensuring that the UK imports timber harvested in compliance with the laws of the country of origin. To demonstrate compliance with the UK Timber Regulation, a company needs to ensure high-quality execution of the requirements of the Regulation, including the implementation and monitoring of the due diligence system.

Importing operators, which, from January 2021 is the person placing the timber or timber product on the GB market, must gather information from the supply chain to ensure the timber has not been illegally harvested, including a full due diligence process.

A full due diligence documented process tracing the timber back to stump and includes:

This can either be done in-house, or by using a recognised monitoring organisation, but it is important to recognise that the depth of supporting evidence required varies with risk, depending on factors such as the complexity of the supply chain, species risk, country risk and the nature of the project.

Following recent high-profile prosecutions it should be noted that in addition to traditional high-risk or sanctioned areas such as Myanmar, Brazil, Peru or the Democratic Republic of Congo, there are now risks presented by timber or timber products that are from more recently sanctioned countries such as Russia.

It has been confirmed by the OPSS (The Office for Product Safety and Standards), that following the devastating earthquakes in Turkey, some Turkish and Kazakh firms are using Russian raw materials to make birch ply for sale in Europe; these sales are in clear breach of the EU and UK Timber Regulations.

Birch plywood products comprise sheets of wood, and are mainly used in the construction, packaging, marine and furniture sectors. Russian producers are trying to find alternative channels to sell their goods, particularly since July 2022, when imports of birch plywood from Russia were banned following the February 2022 start of Russia’s war of aggression against Ukraine.

There is also significant attention being paid to timber products sold from China, the second largest exporter of furniture to the UK after Sweden, that may have their original material source in Russia. Again this is Larch and Birch-based products.

A link to the OPSS Timber Regulation due diligence tool can be found HERE.

British Marine members can get more information and guidance by emailing technical@britishmamine.co.uk