The EU Timber Regulation (EUTR) set out to call time on the trading of illegal timber into EU member states. Years in the making and enshrined in law on March 3, 2013 – in the UK at least – it’s had some time to bed in to the psyche of the timber industry and the supply chain.
But has it actually achieved its lofty ambition of eradicating illegal timber from the EU market? Unfortunately not entirely. In fact, according to WWF-UK’s recent report "In or out? Can the European Union’s Timber Regulation keep out illegal timber?", the legislation is only doing 41% of the job (by product value) in Europe – and only in 15 of the 28 member states.
Not that WWF-UK wants to knock the EUTR; it just wants it to do what it says on the tin.
"We think the EUTR is a great piece of legislation and we’ve always supported it," said Beatrix Richards, WWF-UK head of natural commodities. "We also think the FLEGT Action Plan within which it sits is a really good initiative. But when it comes to the implementation, the devil is in the detail. "There has been very patchy commitment in terms of the level of priority that has been put on it by certain member states and our government barometer exercise in July showed that 13 of them still hadn’t enacted it. That’s a huge gap that the EU needs to address. And countries that are implementing it need to apply pressure to those that aren’t because they don’t have a level playing field."
The other major issue that the EU needs to address when it reviews the legislation at the end of 2015 is its current product scope. There are major product omissions within the EUTR that not only cause confusion for those trying to implement it, they also effectively open a legal gateway through which illegal timber can be traded – and this could include some illegally harvested tropical hardwoods.
WWF-UK’s study (conducted in partnership with Newleaf Sustainability Practice) identifies that of the EU’s 934 combined nomenclature (CN) headings and subheadings that contain wood and wood-based products, only 47% are ‘in scope’ – ie covered by the legislation – and 2% are officially exempt (packaging and recycled materials). The remaining 51% are identified by WWFUK as being in an "out of scope" category.
In value terms this translates as 59% out of scope and includes products such as seating, printed material and musical instruments.
The omission of seating is a serious problem, says WWF-UK, because its study indicates that 77% of seats imported into the UK contain wood. And while it might be tempting to dismiss the use of wood for musical instruments as niche and low volume, the organisation points out that in value terms, this sector is the third most significant out of scope category and tends to use high-risk timber from high-risk sources.
Out of scope products
Out of scope products are a huge bugbear, particularly as so many of them are hardwoods, including tropical hardwoods.
"From a UK perspective it’s a concern for us because a significant proportion of what we trade is via China," said Ms Richards.
China is deemed to present a particular risk with respect to out of scope products because of what the study refers to as "the well documented contamination of wood-based supply chains with illegal timber before and after entry into China for further processing".
Including further CN codes in the EUTR would extend the reach of the legislation to cover these types of products and lessen the risk of illegal timber permeating through the supply chains, says the report.
The report is one element of an 18-month cross-divisional "priority campaign" for WWF-UK. In September it launched its new Forest Campaign to around 100 businesses, marking the first phase of a three-pronged initiative to engage industry, the public and the government. The remit is to start in the UK but extend the campaign through Europe via sister WWF organisations, businesses and NGOs.
"It’s EU legislation so obviously it has to be made to work at an EU level but we’re prioritising it from a UK perspective because the UK is one of the biggest traders in imported timber in Europe," said Ms Richards.
The campaign has two objectives: to apply pressure on the EU to make the EUTR more robust and product inclusive; and to create the right "enabling environment" for the UK government to achieve its target of 100% sustainable timber by 2020.
"There is a huge amount of work that needs to be done to identify what the sustainability mechanisms – the tool chest – need to be," said Ms Richards, adding that political lobbying and advocacy work would follow.
The current phase of the campaign – engaging the business community – is creating "a narrative about why this is a good opportunity to get the EUTR right and send the correct signals to decision makers in government that the regulation shouldn’t be weakened or dropped or seen as a burden but that it should do the job it’s meant to", said Julia Young, WWF-UK Global Forest & Trade Network (GFTN) manager.
The campaign has already seen some highprofile signatories including Marks & Spencer, Carillion and Kingfisher and, from the timber world, Travis Perkins, BSW Timber, James Latham, Saint-Gobain and EcoChoice.
Other backers are being sought via a range of tactics – leaflet drops at Timber Expo, one-to-one conversations, outreach events and liaison with industry associations such as the Timber Trade Federation, the British Woodworking Federation, the Furniture Retailers Association and FIRA.
If anything is likely to cause reticence among other timber companies to sign up it will probably be the fact that it involves publishing annual progress performance on that commitment.
"There is still reticence to publish if they are at the start of that journey," said Ms Young. "My view, and one that’s borne out through my experience of working with GFTN members, is that it’s far better to acknowledge where you are, make the commitment and start taking manageable steps. In my experience the sooner a company starts making those kinds of things public, the better they do in terms of progressing their performance towards a sustainability goal."
Presenting the business case
The organisation is acutely aware that it has to convince industry of the business argument for both sustainability and for signing up to the forest campaign and is conducting research on the economic case.
"If you don’t investigate other ways of incentivising and changing the market – tax breaks or other kinds of bilateral agreements, for example – you could just be looking ahead to more regulation on sustainability in five or 10 years time," said Ms Young.
Greater transparency could be part of the equation.
For example, said Ms Young, including sustainability credentials on tenders for work with local authorities can improve a company’s chances of turning a bid into a live project.
"I think companies who have made progress on sustainability sometimes miss a trick," she said. "By not being transparent about it they’re not differentiating themselves from their competition. Businesses should be more positive about their sustainability."
Becoming more open about sustainability credentials should also sit well with consumers, enabling them to make more informed decisions about what they are buying. They’ll be invited to engage with the Forest Campaign this month, when phase two is launched, and then in spring phase three will see WWF-UK lobbying government. At that point the three arms of the campaign will be running in parallel.
"We aim to get all the dialogue in one place and go forwards with a number of recommendations to government on the back of that," said Ms Richards. The organisation has been checking out the various political party manifestos and says the run-up to the general election is a perfect time to pitch to incumbent and prospective MPs who are keen to become involved in the sustainability agenda – and raise their profiles to boot.
"We’ll also be using our public call to action to encourage consumers to get in touch with their MPs on the issue," said Ms Richards.
While WWF-UK’s favoured approach is more carrot than stick, unlike some other high-profile NGOs, the strength of feeling around its new Forest Campaign is such that it may "want to draw attention" to those companies it feels aren’t doing enough in their pursuit of sustainability. It may also single out "problems with certain products" and says it will encourage the public to do the same.
"We want the public to get involved with helping us," said Ms Young. "We want them to ask questions and ask how certain companies can say they’re not contributing to the problem."
"This is a challenge everyone needs to rise to because if you look at the results of the Living Planet report and the issues of deforestation and sustainable forest management, we’re against a ticking clock," she said.
