Understand what new Timber Regulation (EU) no: 995/2010 (EUTR) means to you as a printer. Matthew Botfield, environment manager at Antalis UK, explains.
Did you know that on 3 March this year the European Union implemented Regulation (EU) no: 995/2010, otherwise referred to as the European Timber Regulations (EUTR), making it a criminal offence for any organisation to place illegally sourced timber or timber-based products onto the EU market. If you think that has nothing to do with you, think again.
Implementation of this legislation in the UK will be enforced by the National Measurement Office (NMO), which will undertake checks to ensure all parties – and yes, that includes printers - are fully compliant with the regulations.
The underlying objective for the introduction of the EUTR is commendable, as it seeks to eradicate the illegal destruction of forests for commercial purposes. Prior to this there was no specific legislation within the EU to prohibit illegal timber trading, or any requirements for organisations to obtain materials from legal sources. By contrast this new law requires anyone handling timber or timber-based products such as paper and card to keep records of the products purchased and assess the risk that the products they are using may have come from an illegal source, and take appropriate action to mitigate that risk.
This process includes recording details of the products used, supplier information and to whom the products will be forwarded to. Furthermore, this information needs to be stored and be easily accessible to the NMO for a period of at least five years.
At first thought you might assume that these regulations would not affect print businesses, but there’s the rub. Within the legislation framework, any business that buys or sells timber or timber-based products in the course of a commercial activity is classed as either a ‘trader’ or an ‘operator’ and therefore has certain obligations to comply with the law.
Traders are now required to be able to identify their suppliers of timber and paper products, and this information will enable the NMO to identify the ‘operators’ who may be placing non-compliant timber or paper products on the European market. Printers are of course users of paper and board and as a result generally fall into the category of ‘trader’ and with that goes the need for compliance.
At this time, there is no known direct cost for compliance, but there may be some additional administrative work to be undertaken and in some cases new processes introduced to record and store the required data, all of which will need to be taken into consideration.
Actions to ensure compliance
In order to comply, print businesses need to identify whether they are a ‘trader’ or the ‘operator’. If yours is sourcing paper and board materials from UK-based paper merchants or suppliers, it’s most likely to be a ‘trader’ and you should request a letter of compliance from your suppliers for the products you purchase, which will provide assurance that they complying with EUTR either as a trader, an operator or both.
If, however, your business is purchasing products from other sources - such as brokers or suppliers outside the EU - then you will need to check whether the supplier is within the listed countries of the ‘internal market’.
If the supplier is outside the internal market, your company may be regarded as the ‘operator’ and it will be your own responsibility to undertake due diligence as to the origins of your product and assess the risk of it coming from an illegal source.
Whether you are a trader or the operator, EUTR also requires you to record to whom you supply your finished products, to ensure on-going traceability.
The good news for the majority of print businesses sourcing product from UK-based merchants, is that much of this information is a fundamental part of your existing business process.
There are of course penalties for non-compliance, which, according to the Regulation, will be ‘effective, proportionate and dissuasive.’ Therefore if you have any doubts or questions, contact your supplier, who should be able to offer you all the necessary advice you need.
Further information on the EUTR can be found at www.antalis.co.uk/ EURegulation_995