The BFM recognised at an early stage the impact that the EUTR would have on the furniture industry’s supply chain and to help companies prepare for compliance we launched a number of education initiatives and entered into partnerships with the Timber Trade Federation, PEFC and the Soil Association. We also met with the British Retail Consortium to establish its position with regard to EUTR, which in turn led to an exchange of information.
The education process began in September last year with a seminar followed up by a workshop in December. The BFM has developed on-line tools to help companies comply with their ‘trader’ or ‘operator due diligence’ requirements including a supplier’s questionnaire and a declaration of legality. Realising that for some companies the requirements would be daunting the BFM engaged a EUTR consultant, Steve Moore, to offer practical assistance and advice including on-site support and at no cost to BFM members.
Steve has now assisted quite a number of member companies and he said – ‘A definite pattern is emerging. Even though traders, under the Regulation are not subject to due diligence, retailers (particularly multiples) are expecting them to assume the role of operator by providing evidence to show the legality of their products. This in turn means that the trader has to go to the business that supplied it to obtain proof of legality. So the pressures of compliance are not just with the operator. DEFRA recently confirmed that traders are not exempt from seizure of timber from their premises if illegality is suspected’.
Below is the checklist that Steve uses in company compliance reviews. For further information please contact Mike Dimond at the BFM (MikeDimond@bfm.org.uk)
EUTR IMPLEMENTATION & COMPLIANCE REVIEW
Process & Guidance Questions:
1. Have your timber and timber based product suppliers been identified?
2. Have you mapped your supply chains – upstream and downstream?
3. Have you identified all species by timber or timber based products?
4. Have you checked for ‘endangered species’ and ‘controversial sources’?
5. Have you obtained quality supply information - Supplier Questionnaire?
6. Have you determined if you are an Operator and/or Trader by supplier?
7. Operator – have you put in place a Due Diligence (DD) procedure?
8. Does your DD capture the information required under the regulation?
9. Does your DD have a process of risk assessment and risk mitigation?
10. Does risk ‘assessment /mitigation’ cover certified and uncertified wood?
11. Does your DD conform to an MO or PAS 2021:2012 standard?
12. Does your DD meet the requirements for keeping records (5 years)?
13. Do you action DD prior to placing timber or products on the market?
14. Do you have a process in place to regularly audit/evaluate your DD?
15. Trader – can you identify operators or traders who have supplied you?
16. Can you identify the traders, as applicable, to whom you have supplied?
17. Can you keep your upstream / downstream trader information (5 years)?