Last week, Andre de Boer, Secretary General of the European Timber Trade Federation (ETTF) said that he saw "no reasons to doubt that the EU Timber Regulations (EUTR) will come into full force as scheduled on 3/3/13." I asked him how the ETTF was preparing.
Q: What is the ETTF doing to prepare for the EUTR?
A: We are working on a harmonized due diligence procedure that will become the minimum standard for ETTF members. This will provide a guideline to help companies comply with the EUTR.
We are also working closely together with producer organizations such as AHEC and MTC to ensure that the regulation-that is the implementation-is done in a robust but also practical way.
Q: The new regulations seem to be intent on exposing the supply chain, including to the competition. If records are submitted as part of import documents, it's nearly impossible to protect proprietary lines. How is the government responding to concerns about protecting the supply chains of legitimate businesses?
A: I don't think it's true that this will expose the company's supply chain to the competition. While companies have to give information to either the authorities or to the monitoring organizations, this information is not available to the public.
Q: Certainly it will be difficult for suppliers of multi-component products (furniture, engineered flooring, etc.) to be able to trace back their production to the extent the regulations would like (the actual supplying concession.) How do you anticipate the law being applied in these cases? What recommendations would you make to importers or foreign manufacturers? How can these companies participate in the process of creating the regulations (is there a place where they can comment on proposals)?
A: The EUTR certainly creates problems for multi-component products. For some products-particleboard is a good example-it is impossible to say what timber species exactly are used let alone that one can say something about the origin of the timber. We raised these issue of course whenever we could but haven't seen final solutions yet.
At the end of the day the market will find its own proper solutions. Everyone must start by buying from reliable suppliers able to give a contractual guarantee with regards to the legal origin of their supplies.
All the companies-be it importers or suppliers-have had the possibilities directly or through their organizations to comment on the EUTR. In all fairness one can say only that the EU did a lot to involve all the stakeholders-trade and industry included-to give their comments. The EFFT did so and have been heard.
Q: Do you have any concerns about the implementation of the EUTR?
A: There are many factors to consider, but certainly one of the points we worry about is the possibility that the enforcement of the EUTR will differ country by country. In short, the problem will concentrate on the weakest point of entry. For Lacey, what is entered in the port of New York is treated basically the same as what enters in Los Angeles. But we are a federation of countries, and not every country enforces law the same way.
Should the EUTR not be enforced in an equal way all over the EU, then in principle it would be simple to circumvent. Of course that's not what we as ETTF wants to happen. We strongly advocate the enforcement of the EUTR throughout Europe in order to create a level playing field. Traders wanting to do it the illegal way shouldn't have a chance to get away with it.
We are also starting a programmed to reach Eastern European traders and their associations to support them in their awareness of the EUTR and the way to implement the regulation.
(Read the final part of the interview with de Boer, including his insights on the future of certification, in next week's post.)