At Cheshire Mouldings, our aim is to provide customers with a professional service of the highest quality – our reputation is therefore of paramount importance to us. And throughout our company’s history, our environmental policy has been at the core of what we do.
Although we already refuse to trade in timber species prohibited under CITES and support the timber certification schemes, we were aware when the EU Timber Regulation (EUTR) was announced that this would still require significant action on our behalf.
Industry benefit
We are fully supportive of the aim of the EUTR, to minimise the risk of illegally harvested timber being sourced and entering the EU supply chain. Our view is that the crackdown on illegal timber will benefit the timber industry’s image as a whole and this is something we are keen to be part of. We are very aware that illegal harvesting of timber not only has an economic impact but also, more importantly, a social impact, such as contributing to forest degradation and climate change. We hope that the EUTR requirements will act as an impetus for the global timber community to increase its efforts to remove illegal timber products from the market.
To ensure we were compliant with the EUTR and to be certain of our obligations, we instructed external lawyers Michelmores LLP to advise us on the implications it would have on our business.
Under the EUTR all companies that ‘first place’ timber and wood products on the EU market are called ‘operators’, while companies that buy from these ‘operators’ are ‘traders’.
As both an ‘operator’ and a ‘trader’ for the purposes of the EUTR, we will have to comply with obligations relating to both of these situations, the most onerous requirement being the introduction of a due diligence system.
We already had a supply chain management system in place, which was similar, but did not require a decision to be made on each supplier. Michelmores was instrumental in reviewing the proposals we received and we are now confident the system we have in place does fulfil the obligations placed on us by the EUTR.
Traceability requirement
Although there was initial work required to implement the system, the requirements have not been onerous on a daily basis.
We source material from Sweden, Finland, eastern Europe and North America and all our suppliers have provided due diligence without a hiccup.
As we are also a ‘trader’ we have an obligation of traceability. This requires us to be able to identify the operators who have supplied the timber or timber products to us and keep the information for at least five years. The EUTR is clearly a complex area of law and we are pleased to know that our approach to the EUTR is legally compliant. We are, however, keen to see the final EU guidance as there is still an element of uncertainty, despite the legislation already being upon us.
The enforcement powers proposed by Defra have certainly been an incentive to comply although, as a result of our proactive attitude to the responsible procurement of timber, we are confident that the gap to be bridged is not that wide.
We are supportive of Defra’s proposal for ‘full enforcement’ and the penalties that it has put forward (a maximum of two years’ imprisonment and/or an unlimited fine). Our stance has always been to condemn illegal logging practices and to remain informed of changes to international legislation; therefore the introduction of the EUTR, from our perspective, can only be a positive step forward.
Cheshire Mouldings at a glance
Cheshire Mouldings was founded in 1988 and now employs 60 staff at its St Helen’s base. It manufactures the complete range of stairparts and timber mouldings, as well as wooden flooring, joinery and decking accessories. It is accredited by the FSC, PEFC, TRADA and the Timber Decking Association.
- This article was co-authored by Jason Phelps, a partner and head of procurement at Michelmores LLP. It summarises complex issues and should not be relied on in relation to specific matters. Michelmores recommends that legal advice be taken on the latter. Jason Phelps can be contacted at tel: 01392 687 590, or email: jason.phelps@michelmores.com.