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EU Timber Regulation (EUTR)

EU Regulation 995/2010/EU lays down the due diligence obligation on operators who place timber and timber products on the internal market of the European Union for the first time, as well as the record keeping obligation on traders that supply those products, with the aim to prevent the illegal logging of timber as well as the related trade of products made from that timber.

It is your responsibility to comply with Regulation 995/2010/EU. This material is for informational purposes only. It is not intended as legal advice. We encourage you to consult your legal counsel if you have questions about the laws and regulations concerning your product. In this regard, please note that Regulation 995/2010/EU has direct effect, but Member States are competent for laying down penalties, and for enforcing the Regulation.

What products does the EU Timber Regulation apply to?

Regulation 995/2010/EU applies to the timber and timber products set out in the Annex of this Regulation, which is available on European Commission website (see Additional Information below). The Annex of this Regulation 995/2010/EU lists the timber products using EU Customs code nomenclature.

In this regard, the Regulation covers a broad range of both imported and domestically produced timber and timber products, including solid wood products, flooring, plywood, pulp and paper, etc., but not including printed papers such as books, magazines and newspapers, musical instruments, toys and games, etc. In addition, Regulation 995/2010/EU contains an exemption for timber products or components of such products manufactured from timber or timber products that have completed their life cycle and would otherwise be disposed of as waste, that is, products made from recycled timber.

Furthermore, Regulation 995/2010/EU empowers the Commission to adopt delegated acts to amend and supplement the list of timber and timber related products set out in the Annex. However, no amendments to the Annex have been published to date.

Operators' obligations

Operator is defined by Regulation 995/2010/EU as any natural or legal person that places timber or timber products on the market, and in turn, placing on the market is defined as the supply by any means, irrespective of the selling technique used (including the supply by means of distance communication), of timber or timber products for the first time on the internal market for distribution or use in the course of a commercial activity, whether in return for payment or free of charge.

In this regard, operators are subject to two obligations:

  • Not to place on the market illegally harvested timber or timber products (i.e. timber that has been harvested in contravention of applicable legislation in the country of harvest, or products derived from this illegal timber); and
  • To use a "due diligence system" to exercise due diligence when placing timber or timber products on the market in the EU.

    In this regard, the operator can choose either to develop its own due diligence system or to use a system that has been created by a monitoring organisation, which are private bodies that have been recognised by the European Commission to assist operators with discharging their due diligence obligation.

    The requirements for the due diligence system are laid down in article 6 of the Regulation 995/2010/EU, and has been developed in the Implementing Regulation 607/2012/EU, both available on European Commission website. But at a high level, the three key elements of the due diligence system are:

    • Information: The operator must have access to information describing the timber and timber products, country of harvest, species, quantity, details of the supplier and documents and information on compliance with national legislation.
    • Risk assessment: The operator should assess the risk of illegal timber in his supply chain, based on the information identified above and taking into account criteria set out in Regulation 995/2010/EU.
    • Risk mitigation: When the assessment shows that there is a risk of illegal timber in the supply chain that risk can be mitigated by requiring additional information and verification from the supplier.

However, these operators' obligations do not apply to the following timber and timber products, given that the Regulation 995/2010/EU considers that this timber and timber products have been legally harvested for the purposes of this Regulation:

  • The timber: (i) originates in a partner country listed in Annex I to Regulation 2173/2005/EC; (ii) is embedded in a timber product listed in Annexes II and III of the same Regulation; and (iii) complies with the requirements of that Regulation: and
  • The timber or timber products are in scope of Annexes A, B or C of the EU CITES Basic Regulation and comply with the requirements of that regime.

Traders' obligations

Trader is defined by Regulation 995/2010/EU as any natural or legal person who, in the course of a commercial activity, sells or buys on the internal market timber or timber products already placed on the internal market.

In this regard, traders are subject to a basic traceability obligation which requires them to be able to identify:

  • the operators or the traders who have supplied them with the timber and timber products; and
  • where applicable, the traders to whom they have supplied timber and timber products.

This information must be kept for at least five years and made available to competent authorities on request.

Additional information

We strongly encourage you to visit the European Commission’s website for more information on EUTR, that includes a Guidance Document for the EU Timber Regulation in the 23 languages of the EU, as well as a list of recognized monitoring organisations, and the implementing regulations:

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