EU Timber and Timber Products Regulations March 2013

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EU Timber and Timber Products Regulations March 2013

Post by thatsnotafestool » Sat Feb 02, 2013 6:38 am

More red tape. Coming into force March 2013.

Unclear what it means for anyone already holding stock of tropical/exotic hardwoods. Trying to find out.

PITA probably. Anyone mentioned these regulations to the illegal importers of China?
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Re: EU Timber and Timber Products Regulations March 2013

Post by jrm » Sat Feb 02, 2013 8:35 am

I (and Mark numbers) did post links for some info a while ago on this.

http://woodworkuk.co.uk/forum/viewtopic ... 57#p102257" onclick="window.open(this.href);return false;

though the original link doesn't seem to be working, this should do:

http://ec.europa.eu/environment/forests ... let_EN.pdf" onclick="window.open(this.href);return false;


Most of us here are 'traders' and simply need to keep records of when and from whom we bought timber if bought from anywhere in the EU. Since this is already done for accounting reasons, I don't see it makes any difference whatsoever.

If, however, you import timber into the EU from outside, import furniture or convert your own timber, then you are an 'operator' and it does become more onerous. I suppose it may be a pain if you are the sort of woodworker who occasionally has a tree converted for your own use.

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Re: EU Timber and Timber Products Regulations March 2013

Post by thatsnotafestool » Sat Feb 02, 2013 8:53 am

Hi John

Missed that thread (and I even contributed to it).

However, reading a little bit more, I think it may be more onerous than simply saying 'I bought this bit of mahogany from John Boddy'.

The Timber Trades Federation have produced quite a lot of information on their website. In particular this 'Responsible Purchasing Policy' http://www.ttf.co.uk/Environment/Respon ... olicy.aspx" onclick="window.open(this.href);return false;

which suggests that a Risk Assessment is required ! Just what would that consist of? Don't get me wrong.....I hope that I am mithering about nothing.

And what about that stack of teak that you bought five years ago at auction ? How would you Risk Assess that !
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Re: EU Timber and Timber Products Regulations March 2013

Post by jfc » Sat Feb 02, 2013 9:48 am

Is anyone here actually a member of the TTF ?
Im not .
Risk assessment over :lol:

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Re: EU Timber and Timber Products Regulations March 2013

Post by thatsnotafestool » Sat Feb 02, 2013 9:55 am

You may jest, mate, but they have put this together I think in response to the EU directive. Think of it as 'best practice'.

This is the line in the EU Regs that affect you and me

It requires EU traders who place timber products on the EU market for the first time to exercise 'due diligence';

And this is what they (the EU...not the TTF) say they mean by Due Diligence

The core of the 'due diligence' notion is that operators undertake a risk management exercise so as to minimise the risk of placing illegally harvested timber, or timber products containing illegally harvested timber, on the EU market.

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 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 the regulation.
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.


How many of us have racks of timber where some of it we probably have no idea where it came from? Is 'Dunno' a good enough 'Due Diligence'?
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Re: EU Timber and Timber Products Regulations March 2013

Post by karl » Sat Feb 02, 2013 10:21 am

Surely buying your timber from a reputable dealer would suffice for due diligence purposes - ergo, no further action necessary.

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Re: EU Timber and Timber Products Regulations March 2013

Post by thatsnotafestool » Sat Feb 02, 2013 10:32 am

Karl, that would probably be OK, I'd guess. But what about the stuff already on your shelves?
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Re: EU Timber and Timber Products Regulations March 2013

Post by Leveller2911 » Sat Feb 02, 2013 10:36 am

karl wrote:Surely buying your timber from a reputable dealer would suffice for due diligence purposes - ergo, no further action necessary.

Exactly, I only deal with 3 companies and all 3 import, so the onus shouldn't be on me/you/us as we are the end user in the UK.

Just for the record the sooner we have the EU referendum the better,its ours by right and not for any Government to "offer".We can trade with the EU without drowning in its bureaucracy. :roll:

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Re: EU Timber and Timber Products Regulations March 2013

Post by thatsnotafestool » Sat Feb 02, 2013 10:57 am

Leveller2911 wrote:.....
Exactly, I only deal with 3 companies and all 3 import, so the onus shouldn't be on me/you/us as we are the end user in the UK.

.....
So all this stuff you buy in, you are keeping? Fair enough..that then makes you the end-user. But if you are using it to make something to sell to someone else then that makes you a trader and so you'll need to do the Due Diligence bit.
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Re: EU Timber and Timber Products Regulations March 2013

Post by Leveller2911 » Sat Feb 02, 2013 11:32 am

thatsnotafestool wrote:
Leveller2911 wrote:.....
Exactly, I only deal with 3 companies and all 3 import, so the onus shouldn't be on me/you/us as we are the end user in the UK.

.....
. But if you are using it to make something to sell to someone else then that makes you a trader and so you'll need to do the Due Diligence bit.

Quote: 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 information on compliance with national legislation.

The "due diligence" is already there with companies in this country who import, its all bureaucratic bullsh*t .I buy all of my timber from companies signed up to all sorts of certification so they already carry out diligance.If there is not faith in the certification then scrap it but show me proof of UK companies importing illigal timber.Is there a suggestion that when Brooks Bros load their lorry with my timber the driver stops off half was and sticks a few lengths of Congolese Sapele on from a dodgy container at Harwich docks?.

Its typical of the EU blanket regulation when in fact the countries that promote illigal logging etc are China and Indonesia and Russia who they have no power or influence over.

The UK implements EU regulation completely and yet France and Germany implement a "light touch" regulation (ie they don't give a monkeys Chunky if their industries don't implement 100%). Good example is the latest animal welfare legislation that came in on 1st Jan 2013,only 36% of French farmers have complied and only 47% of German farmers and yet they have known for years it was coming in. Who would have thought it eh? Germany and France having the most influence over EU policy making ,whilst at the same time breaking their own laws.

Call me a sceptic .......... :roll:

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Re: EU Timber and Timber Products Regulations March 2013

Post by mrgrimsdale » Sat Feb 02, 2013 12:21 pm

thatsnotafestool wrote:.......I hope that I am mithering about nothing......
You are. Don't worry, relax, drone about something else even less interesting!

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Re: EU Timber and Timber Products Regulations March 2013

Post by woodsmith » Sat Feb 02, 2013 12:24 pm

It's amazing that even the Germans implement EU directives with a "light touch" whilst we slavishly implement them with a draconian bureaucracy. Seems to me that Europe isn't the problem, its our Civil Service.
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Re: EU Timber and Timber Products Regulations March 2013

Post by thatsnotafestool » Sat Feb 02, 2013 12:27 pm

Leveller, you are entitled to your interpretation of the rules. Seems pretty clear to me in the first line I highlighted in blue.

It requires EU traders thats you and me who place timber products that's what you and I make on the EU market for the first time to exercise 'due diligence';
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Re: EU Timber and Timber Products Regulations March 2013

Post by thatsnotafestool » Sat Feb 02, 2013 12:27 pm

mrgrimsdale wrote:
thatsnotafestool wrote:.......I hope that I am mithering about nothing......
You are. Don't worry, relax, drone about something else even less interesting!
No one is forcing you to read it, you miserable old git. Anyway, it doesn't concern you as you only make stuff out of recycled orange boxes.
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Re: EU Timber and Timber Products Regulations March 2013

Post by Leveller2911 » Sat Feb 02, 2013 12:37 pm

thatsnotafestool wrote:Leveller, you are entitled to your interpretation of the rules. Seems pretty clear to me in the first line I highlighted in blue.

It requires EU traders thats you and me who place timber products that's what you and I make on the EU market for the first time to exercise 'due diligence';

But I already carry out due diligence..........

http://www.brookstimber.com/environment-purchasing.php" onclick="window.open(this.href);return false;

http://www.goldberg.uk.com/environmentalpolicy.html" onclick="window.open(this.href);return false;

http://www.jwtimber.co.uk/environment.htm" onclick="window.open(this.href);return false;

Job done.......... :) It will have little or no effect on the Countries that encourage illegal logging etc.

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Re: EU Timber and Timber Products Regulations March 2013

Post by Mike Dempsey » Sat Feb 02, 2013 12:39 pm

I mill all my own timber from windblown trees on local estates and council parks. A few years ago I was FSC certified and had to get letters from the relevant landowner to prove that it was windblown and I had permission to mill it. I used to get inspected every year and had to show all my paperwork. This was vey time consuming as well as expensive. I came out the the certication scheme and havent lost any customers as a result. If anyone wants me to prove that my timber is legal I can show them photos of me milling and the tree stumps. I have saved myself a huge amount of time and money by doing it my way. I also think that my logs are more eco friendly than FSC certified logs as they are windblown or thinnings and all come from about a 4 mile radius of the workshop. I dont fell any trees for milling and and when I inform customers about where I get my timber from, none of them have accused me of not being eco friendly. I have also planted saplings to replace the trees that I have used over the years and take part in environmental community action days.
By the way there are illegally felled logs imported into the uk and any scheme to mitigate their importation is a good thing in my opinion. Cutting the number of customs and excise officers is not a good way of stopping this though!
Mike

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Re: EU Timber and Timber Products Regulations March 2013

Post by karl » Sat Feb 02, 2013 12:57 pm

thatsnotafestool wrote: It requires EU traders thats you and me who place timber products that's what you and I make on the EU market for the first time to exercise 'due diligence';
Surely we're not putting the timber on the EU market for the first time - the timber merchants are. We are secondary/tertiary re-sellers.

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Re: EU Timber and Timber Products Regulations March 2013

Post by promhandicam » Sat Feb 02, 2013 1:22 pm

I very much doubt that for one man bands like the majority of us it will have any impact whatsoever in the same way we (probably) don't comply with a whole raft of EU or UK directives. For bigger (limited) companies, particularly those dealing with the public sector (like Mark) then it may have some bearing but they will be dealing in the main with large timber suppliers or importers who will have the responsibility for the due diligence. And if anyone does come asking I'll respond in French and tell them 'Je m'en fiche de tes reglements !' like all good Frenchmen do when it comes to EU directives :lol:

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Re: EU Timber and Timber Products Regulations March 2013

Post by thatsnotafestool » Sat Feb 02, 2013 1:22 pm

karl wrote:
thatsnotafestool wrote: It requires EU traders thats you and me who place timber products that's what you and I make on the EU market for the first time to exercise 'due diligence';
Surely we're not putting the timber on the EU market for the first time - the timber merchants are. We are secondary/tertiary re-sellers.
They seem to differentiate between 'timber' (ie bit of lumber) and 'timber products' (what you and I make).

I have no idea if it is going to affect any of us.
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Re: EU Timber and Timber Products Regulations March 2013

Post by thatsnotafestool » Sat Feb 02, 2013 1:25 pm

Hopefully you're right Steve. But then again hasn't the PRS gone after one man bands?

I did start watching the webcast that is linked to on the URL given earlier on. Got bored. Mind you there is a nice cleavage shot around the 46 minute mark.
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Re: EU Timber and Timber Products Regulations March 2013

Post by senior » Sat Feb 02, 2013 3:17 pm

You're a bit of a worrier aren't you.
Have a look at my facebook page and leave a comment or two.
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Re: EU Timber and Timber Products Regulations March 2013

Post by jrm » Sat Feb 02, 2013 4:38 pm

'Due diligence' applies to the person (the operator) who first puts timber or a timber product onto the market in the EU. This could be timber which they have converted, timber imported from outside the EU or timber products from outside of the EU. Once the stuff is in the EU, it can be freely traded and the only obligation on subsequent traders is to keep records of their suppliers and customers so that traceablity is maintained. It will make no difference at all to you unless you are felling and converting timber or are shipping it in from the USA or wherever.

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Re: EU Timber and Timber Products Regulations March 2013

Post by mark270981 » Sat Feb 02, 2013 4:55 pm

Being fsc certified is burocratic b*llsh*t to be honest however by rights to work and produce timber products for public sector you need to show due diligence with by being fsc or pefc certified although it isn't heavily enforced however it will be shortly now the eu commission are pushing it through. Due to me being on the register we are getting enquiries left right and centre to do work.
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Re: EU Timber and Timber Products Regulations March 2013

Post by mrgrimsdale » Sat Feb 02, 2013 5:15 pm

No it's in a good cause and has some effect, if not the 100% success hoped for. Better if more heavily enforced.

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Re: EU Timber and Timber Products Regulations March 2013

Post by mrgrimsdale » Sat Feb 02, 2013 5:18 pm

thatsnotafestool wrote:
mrgrimsdale wrote:
thatsnotafestool wrote:.......I hope that I am mithering about nothing......
You are. Don't worry, relax, drone about something else even less interesting!
No one is forcing you to read it, you miserable old git. Anyway, it doesn't concern you as you only make stuff out of recycled orange boxes.
And no one is forcing you to read it and witter on about it, you miserable old git.
And you can't get the orange boxes nowadays.

If you want to do something useful you could join the real world, support the WWF and help lobby against illegal logging.

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Re: EU Timber and Timber Products Regulations March 2013

Post by katellwood » Sat Feb 02, 2013 8:15 pm

What about second hand timber, I have quite a large amount of mahogony based timber and oak that has been recycled from large door frames, snooker tables etc. most of it is large section and can be easily converted to furniture products where it would appear new.

Do I have any responsibilities re this material ???

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Re: EU Timber and Timber Products Regulations March 2013

Post by mark270981 » Sat Feb 02, 2013 8:18 pm

I doubt it as its already be used once, the whole idea behind this legislation is to stop illegal logging etc
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Re: EU Timber and Timber Products Regulations March 2013

Post by thatsnotafestool » Sat Feb 02, 2013 8:30 pm

mrgrimsdale wrote:
thatsnotafestool wrote:
mrgrimsdale wrote: You are. Don't worry, relax, drone about something else even less interesting!
No one is forcing you to read it, you miserable old git. Anyway, it doesn't concern you as you only make stuff out of recycled orange boxes.
And no one is forcing you to read it and witter on about it, you miserable old git.
And you can't get the orange boxes nowadays.

If you want to do something useful you could join the real world, support the WWF and help lobby against illegal logging.
Time for your meds....

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Re: EU Timber and Timber Products Regulations March 2013

Post by thatsnotafestool » Mon Feb 04, 2013 9:45 am

OK...from the horses mouth. Good to have clarification.

Briefly stated, the EU Timber Regulation only applies to timber which has been 'placed on the market' after 3rd March 2013. So any timber you have in stock that pre-dates the regulation will be exempt from it.

'placed on the market' is one of those legalistic euro-speak terms that means very little to most people. Essentially, goods are considered to have been placed on the market once they have cleared customs in the UK/EU and are made available for free circulation.

Taking your surplus timber example, the timber you have now is placed on the market already. Timber can only be placed on the market once, so if you sell this timber after March, it is not placed on the market for a second time. That said, from March you will need to maintain records of any other traders you supply timber to, and the traders in question would need to record who they have purchased the timber from.


So if I understand you correctly then after 3rd March if I sell some of my surplus stock to another cabinet maker (aka trader) then I just need to keep a record ?

Has the level of detail been defined? Is 'Sold - 2m x 50mm x 300mm board of surplus mahogany - to A.N. Other Cabinet Maker on 8th June 2013' sufficient? I may no idea what type of mahogany it is, to be honest.


That sounds fine - as long as you can demonstrate what you have sold and to who, you should be fine. It is important however that you obtain the address of the company in question, so that should we need to, we could visit them too.
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Re: EU Timber and Timber Products Regulations March 2013

Post by Peter Gee » Mon Feb 04, 2013 10:12 am

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Re: EU Timber and Timber Products Regulations March 2013

Post by Nick Gibbs » Fri Feb 08, 2013 9:10 pm

The National Measurement Office (NMO) are the appointed authority in the UK. At a forestry conference on EUTR recently their reps said that they planned a 'light touch' on policing this new regulation. Keeping a paper trail of invoices should be enough. Timber felled in the UK will be covered by the FC felling licences, and reportedly there is only 0.1% illegally logged timber in Britain. I suspect it will be a stick that is used only on extreme cases, so I wouldn't worry too much.

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