If your company imports timber or timber products from outside the European Union, you are considered an "operator" under the EUTR Regulation (EU) No 995/2010. This means you have specific due diligence obligations you must meet to avoid fines and legal problems.
Who Is an "Operator" Under EUTR?
You are an operator if you place timber or timber products on the EU market for the first time. This includes:
- Import of round wood from non-EU countries
- Import of sawn timber or plywood
- Import of wooden furniture
- Import of paper, cardboard or derived products
- Forest harvesting in Romania (Romanian timber)
If you buy timber already imported by someone else in the EU, you are a "trader", not an operator. Obligations are different.
Your Obligations as Operator/Importer
As an importer, you must implement a due diligence system with three components:
1. Information collection
- Product description (trade name, tariff code)
- Country of origin of the timber
- Wood species (common and scientific name)
- Quantity (volume, weight, number of units)
- Supplier name and address
- Documents certifying harvest legality
2. Risk assessment
- Risk level of country of origin (corruption, governance)
- Supply chain complexity
- Existence of certifications or verifications
- Credibility of provided documents
- Supplier history
3. Risk mitigation
- Requesting additional documents
- Audits or visits to suppliers
- Use of FSC/PEFC certified timber
- Changing supplier if risk remains high
High-Risk Countries
Imports from certain countries require extra attention due to risks associated with illegal logging:
This doesn't mean you can't import from these countries, but you need to be much more careful about document verification and demonstrating legality.
What You Risk If You Don't Comply
- Fines from 5,000 to 200,000 lei
- Product confiscation
- Import activity suspension
- Reputation damage and client loss
- Criminal liability in serious cases
Solutions for SMEs
Implementing a due diligence system can seem complicated, but there are accessible solutions:
Joining a certification group
Benefit from ready-implemented procedures, due diligence forms and documentation support.
Using a digital platform
The Sustainability Today platform offers tools for managing information and demonstrating compliance.
Working with certified suppliers
FSC or PEFC certifications significantly reduce risk and simplify due diligence.
Frequently Asked Questions
How long must I keep documents?
Minimum 5 years from the date of placing the product on the EU market.
Is FSC certification enough for compliance?
Certification significantly reduces risk, but doesn't eliminate the due diligence obligation. You must assess and document risks.
How do I prove I did due diligence?
By keeping documents (risk assessments, supplier correspondence, certificates, invoices) and having a documented procedure.
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