FAQ

About the EUTR......

  • What is the EU Timber Regulation?

    The European Union adopted the EU Timber Regulation (EUTR) to minimise the risk of illegally harvested timber and timber products entering the EU market.

    The Regulation imposes three obligations on companies importing timber and timber products in the EU:

    1. It prohibits the placing of illegally harvested timber and products derived from illegally harvested timber on the EU market;
    2. It requires the ‘Operator‘, who first places timber or timber products on the EU market, to develop, maintain, evaluate and exercise a due diligence system (DDS);
    3. It requires the ‘Trader‘, who buy or use commercially timber already placed on the EU Market, to keep records for at least 5 years, the companies (either another Trader or an Operator) that supplied them with timber and the traders to whom they have supplied products to.Traders may choose to go beyond their EUTR legal obligations.

    The EUTR covers a wide range of timber products, including fuelwood, plywood, raw timber, sawn wood, pulp and paper, furniture, joinery, and barrels. A list of products that are included with the EUTR is available from the European Commission. Timber which carries a FLEGT license or a CITES permit is considered to comply with the EUTR.

  • What does a Due Diligence System for Operators include?

    For Operators, a DDS must include three elements:

    1. Access to information – measures and procedures providing access to information concerning the operator’s supply of timber or timber products placed on the market;
    2. Risk assessment – risk assessment procedures enabling the operator to analyse and evaluate the risk of illegally harvested timber or timber products derived from such timber being placed on the market;
    3. Mitigation of the risk identified – risk mitigation procedures which consist of a set of measures and procedures that are adequate and proportionate to effectively minimise risk identified in the risk assessment.
  • What information does an Operator need to have access to?

    The EUTR requires that Operators have access to, and maintain up-to-date information concerning the sources and suppliers of their timber and timber products. Operators must maintain such records for a period of 5 years.

    Table 1 – Access to information about sources and suppliers of the timber and timber product

    An Operator must have access to the following information about the timber in their supply chains:

    • Description, including the trade name and type of product,
    • Common name of tree species and full scientific name,
    • Country of harvest, and where applicable sub-national region and concession of harvest,
    • Quantity (expressed in volume, weight or number of units),
    • Name and address of the supplier to the operator,
    • Name and address of the trader to whom the timber and timber products have been supplied,
    • Documents or other information indicating compliance of those timber and timber products with the applicable legislation.
     

    The EUTR defines ‘applicable legislation’ as ‘the legislation in force in the country of harvest covering the following matters’

    • Rights to harvest timber within legally gazetted boundaries,
    • Payments for harvest rights and timber including duties related to timber harvesting,
    • Timber harvesting, including environmental and forest legislation including forest management and biodiversity conservation, where directly related to timber harvesting,
    • Third parties’ legal rights concerning use and tenure that are affected by timber harvesting,
    • Trade and customs, in so far as the forest sector is concerned;
  • What criteria does an Operator need to include in their risk assessment?

    The EUTR requires Operators to assess the risk of illegally harvested timber being present in their supply chain, taking into account specific criteria. Operators should carry out a risk assessment on information and documents detailed in Table 1, addressing each of the risk assessment criteria listed in Table 2:

    Table 2- Risk assessment criteria

    An Operator must include the following criteria in their risk assessment:

    • Assurance of compliance with applicable legislation or certification or other third party verified schemes which cover compliance with applicable legislation,
    • Prevalence of illegal harvesting of specific tree species,
    • Prevalence of illegal harvesting or practices in the country of harvest and/or sub-national region, where the timber was harvested, including consideration of the prevalence of armed conflict,
    • Sanctions imposed by the UN Security Council or the Council of EU on timber imports or exports,
    • Complexity of the supply chain of timber and timber products.

    Note: The list of risk assessment criteria is not exhaustive; operators may choose to add further criteria if these would help determine the likelihood that a product’s timber had been illegally harvested, or if it would help prove legal harvesting.

  • What control measures could an Operator address to mitigate risk?

    If the risk of placing illegally harvested timber on the market is not deemed to be negligible, the Operator must take action by implementing risk mitigation measures. Mitigation measures should be proportionate to the level of risk and type of risk identified and may need to be accompanied by means of verification to demonstrate its adequacy and effectiveness. It should be clearly stated how the outcome of each mitigation measure addresses the risks.

    Table 3 – Risk mitigation measures

    When an Operator identifies risk in their supply chain they can employ a range of mitigating measures. Some examples of mitigation control measures are:

    • Collect and verify additional information and supply chain documentation from suppliers and sub-suppliers;
    • Conduct field inspection to corroborate information obtained and verify actual implementation of activity on the ground at the supply unit level, supplier’s site or sub-supplier’s site;
    • Stakeholder consultation (e.g. government officials, local NGO, villagers) to obtain further evidence on implementation;
    • Training and capacity building of suppliers and sub-suppliers e.g. about EUTR and the procedure to collect, maintain and provide supply chain information;
    • Third party verification;
    • Species test to confirm origin;
    • Exclusion of high risk/non-compliant suppliers;

     

  • Where can I find out more information about the EUTR?

About Country Legality.....

About Licensing & Certification.....

  • If the product, e.g. the finished product delivered to the Operator in the EU, carries a certification logo or claim, what do I need to do?

    Products that are certified under a scheme accredited by initiatives such as FSC and PEFC have a reduced risk of containing illegal wood. However they do not automatically have a ‘Non-Negligible’ risk rating. Risk evaluation is still needed with regards to their ability to cover relevant requirements against the EUTR.

    FSC has issued an advice note which requires cooperation between FSC certificate holders within the supply chain to provide the required information under the EUTR, on request, to Operators. This includes, name of tree species (common and full scientific), the country/specific timber concession where the timber was harvested, quantity, name and address of the supplier etc. This information is not automatically known to the Operator even if the product they purchased is a certified product.

    Ref:

    https://ic.fsc.org/preview.qa-eutr-rev-november-2014.a-1517.pdf

    https://ic.fsc.org/en/our-impact/timber-legality/ensuring-compliance

    In addition, verification is needed with regard to the validity and the scope of the certificate relating to the product involved.

    For users of SURE, i.e. direct supplier to the Operator, the following steps are advised when preparing information and documents to upload on SURE for a certified product:

    Step 1 – Prepare the following documents;

    • Chain of Custody Certificate of each timber processing company and trader involved in this supply chain for this component
    • Invoice/contract/delivery notes or similar transport related documents between timber producer, timber processing company and trader;

    Note that if the product originated from high risk areas, even if the product is certified, the following documents and other mitigation measures may be requested as additional evidence to demonstrate low risk of illegality:

    • Forest Management Certificate of the timber producer;
    • If the material supplied by the timber producer is  “controlled wood” (under FSC) or “wood from non-controversial sources” (under PEFC system), the FSC CW Risk Assessment Report or PEFC DDS CoC procedures and reports;

    Step 2 – Check the documents

    • Is the certificate valid?
    • Does the product being supplied fall within the scope of the certificate (product type and species)?
    • On the invoice/contract/delivery notes between timber producers, timber processing company and trader, is the certification claims stated for the corresponding product being supplied? as well as the certification code of the seller?

    Step 3 – Create a UWS

    • Following the instruction of creating a new UWS to enter certification information for each node of the supply chain and upload corresponding documents as requested.

    Step 4 – Create a name for the Component and link the UWS to the Component

  • If the finished product does not carry a certification logo or claim, but a part of the product, e.g. wooden dowel, is made with material that is certified, what do I need to do?

    Products that are certified under a scheme accredited by initiatives such as FSC and PEFC have a reduced risk of containing illegal wood even though they do not automatically have a ‘Non-Negligible’ risk rating.

    It is highly advised for the users of SURE to declare the corresponding certification claim for each UWS of the product correctly, in order to help Operators to understand the supply chain composition and allow prioritisation of risk mitigation on high risk UWS, e.g. non certified component.

  • If the company/manufacturer/factory has a CoC certificate and is able to sell certified product, what do I need to do?

    There is common misunderstanding over the relationship between certificate holder and the certification status of their products. If a company has 3rd party certification of Chain of Custody, this does not automatically mean that all products from this company are certified.

    Users of SURE need to find out if it is the product, supplied by the company, that carries a certification logo or claim.

    If the product is confirmed to be uncertified, the Chain of Custody certificate of the company does not help to mitigate the risk. The product will be treated as an uncertified product, users of SURE will need to follow the UWS to complete the required fields and upload supporting documents.

About SURE system......

  • What is a component?

    When SURE refers to a component, it is referring to the individual parts making up a whole product, for example:

    Component name: table leg / Component type: planed or sawn hardwood

    Component name: table top / Component type: planed or sawn hardwoo

  • How can I change my contact details in SURE?

    You can edit your phone number and email address in SURE:

    1. Click on your name in the top right corner
    2. Click ‘Edit’
    3. Add or amend your details as necessary
  • How do I delete or replace a document on the Supply Chain Form?

    You can only delete a document when the Unique Wood Source is in ‘draft’ or ‘entered’.

    To do this click ‘Edit’ on the Unique Wood Source and open the Supply Chain Form. Click ‘Edit’ again. Delete the document using the red cross icon and then click ‘Save’.

    When the  status of the Unique Wood Source is ‘Used in Pre-Order’ a document cannot be deleted by the supplier. If a document needs to be deleted, the supplier should leave a comment in SURE to inform the buyer that the document is incorrect, then upload the correct document additionally.

  • Can I delete a Unique Wood Source?

    A Unique Wood Source can only be deleted if it hasn’t been used in a Pre-Order (the Unique Wood Source status must be ‘Entered’).  To delete, open the ‘Unique Wood Source’ and click ‘Delete’.

    If you don’t want to delete the whole record, but you would like to remove the supply chain details – open the record, click ‘Edit’, click on the relevant supply chain to open it and click ‘Delete’.

  • What do I do if the wood type is not in the list?

    All major wood types should be in the list. However in the event that you cannot find a suitable wood type, please contact us.

    Please don’t pick another material type, as we can’t change this later.

  • Why are buttons missing from my Pre-Order or Unique Wood Source screen?

    This might be because you are using an unsupported browser. Only Firefox, Google Chrome, Microsoft Edge or Internet Explorer v.8 are supported.

  • How do I add / change SURE users within my organisation?

    If you are using SURE as a supplier and you need to change who uses SURE within your company, or you need to add a new user, please ask your buyer as they need to approve any additional or alternative users. A new account will then be created.

    If you are using SURE as a buyer, please contact the SURE Helpdesk.

    It is important that only registered users access the SURE system. Please do not share logins due to the sensitive nature of the information held on SURE.

  • Can work within the SURE system be transferred between users?

    Select ‘Transfer User Forms’ from the left hand menu on the dashboard.

    Then select ‘Add a new user transfer’

    Select who the work will move from and to.  If you select Yes to ‘Transfer all suppliers? and Transfer all product types? please note that this will transfer ALL of the work.

    By selecting No you will be given the option to select one or more users to transfer work to.  Be aware that if a work transfer request selection affects any part of a range, then the whole range will be transferred.

    What happens next? The request will now be sent via SURE to the SURE Helpdesk.  The request will be checked and approved or rejected with a request for further information.