We’ve all seen the recent attacks and allegations from Greenpeace on imported Brazilian timber. They claim in their report, The Amazon’s Silent Crisis, that there is widespread laundering of illegal timber in the Amazon region and that it is finding its way to Europe.

In the UK, the NGO has focused on the Saint-Gobain Group, with allegations that it has been in receipt of this material. But it is targeting the industry Europe-wide. At the ETTF’s recent AGM, several of our member federations confirmed that Greenpeace had approached their country’s EU Timber Regulation (EUTR) Competent Authority (CA) to investigate Brazilian imports.

This timber comes with legality documentation from official Brazilian authorities, such as Ibama. However, the validity of this documentation is challenged.

We have seen something similar happening with CITESdocumentation for afrormosia imported into Belgium. Doubts were also raised about its authenticity by Greenpeace.

What is happening here reveals one of the major challenges for the due diligence that importers have to apply to all their suppliers under the EUTR. Not only do they have to gather information on the legality of the timber imported, they also have to assess the risk that this information cannot be trusted, even if it comes from official authorities in the countries of origin.

CAs in turn have to check that importers are applying proper due diligence risk assessment. But one wonders how they are going to do this as it assumes they have knowledge about the operation of the timber sector and the supplier countries’ legislation governing the industry. This involves a major learning process for bodies which often have scant resources to do their job. It inevitably opens the way to error and misjudgment, which Greenpeace, with all its knowledge of the trade and global reach, will inevitably home in on.

As I said, the first thing importers have to do is gather information on the applicable legislation in the countries of origin. Wouldn’t it be more ef_ cient and cost-effective if at least this information could be found in a central place? If we had a constantly updated data resource, Europe’s 28 CAs could also make use of it, if only to see to it that all stakeholders base their risk analysis and assessment on the same kind of information. It would be good for the timber industry, and reinforce the capabilities of the EUTR to eradicate the illegal timber trade.

The ETTF is working on this issue, but effective action requires financial assistance, for example from the EU and/or the International Tropical Timber Organisation (ITTO).

Of course, that still leaves the dif_ cult part; assessing the validity of the specific information and documentation supporting each shipment of timber to ensure it proves compliance with that relevant supplier country legislation. The industry can’t expect assistance here from the EU, ITTO or national authorities. The ETTF and our member federations can give advice but ultimately it is the ‘operator’ importer’s sole responsibility to come to the final judgment through their own due diligence process: is the risk involved negligible or not?

And if so, what kind of measures do I take to mitigate the risk?

That is how it should be. However, a central supplier country legislation information resource would provide part of the basis for making these due diligence judgments and cut the workload.

Also in this respect an important role could be played by Monitoring Organisations; the bodies authorised by the European Commission to establish due diligence systems for timber company clients and to help manage their operation for them. So it is a pity, as we’ve said before, that processing of applications from operations that want to become MOs, including some ETTF member federations, is, to put it politely, so painfully slow. Out of over 30 submitted since before the EUTR came into force in 2013, just four have been processed and approved.