Evaluating the current state of EU Timber Regulation (EUTR) implementation just a year after it came into effect, it is impossible to come to definitive verdicts on its impact.

In most countries, the national Competent Authorities (CAs) responsible for monitoring and enforcing the Regulation are still building their understanding of the timber sector. Consequently, it is not being administered as thoroughly as ultimately it should be.

Despite the fact that we are still early in the process, however, I have come to some preliminary conclusions.

One is that, while checking timber legality is a new task for CAs, and they need time to establish and internalise procedures, we must ensure that they are all operating equally effectively to guarantee uniform enforcement of the EUTR across all 28 member states. Inadequate implementation in just one could undermine the whole Regulation. It has been suggested that it could result in redirection of timber flows from traditional harbours of entry to ports where the EUTR is less rigorously policed. There is no evidence of that happening yet. But we must remain vigilant and emphasise repeatedly that it must be applied to the same high standard everywhere to successfully combat the illegal timber trade.

I have also been critical of the EU for slow processing of applications from would-be Monitoring Organisations (MOs), bodies that can establish EUTR-aligned due diligence systems (DD) and help timber companies operate them. They could fulfil a valuable role, but so far just two out of almost 30 have been dealt with and approved.

Recently I and representatives of Dutch and German timber federations, both of which operate the ETTF’s DD system, visited EU-officials responsible for MO applications. They confirmed the DD itself was robust, but that application delays were caused by concerns over MOs’ capacity to do the job. However, they also said they were assigning more consultants to deal with their own capacity issues and said all pending MO applications would be processed this year.

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