Earlier this month (8 February), PrintWeek reported that the European Union Timber Regulation (EUTR) was to come into action from 3 March, marking the first time that the entire EU supply chain has been legally bound to play a part in efforts to eliminate deforestation caused by commercial production.

Until this point, recording information on pulp and paper sources has been limited to merchants and manufacturers.

Imminent introduction
However, the imminent introduction of the EUTR will mean that anyone using timber-based products – including printers – in the EU will be required to ensure that they maintain a comprehensive and up-to-date catalogue of their sources and suppliers.

Failing that, you may find yourself facing a £5,000 fine or up to two years in jail.

The legislation is being implemented in the UK by the Department for Environment, Food and Rural Affairs (DEFRA), and will be enforced by the National Measurement Office (NMO).

The EUTR is part of DEFRA’s Structural Reform Plan to "champion a reduction in emissions through lower deforestation and enhanced biodiversity" by legislating in the UK to make it a criminal offence to allow illegal timber to enter the EU market for the first time.

So, who is responsible for what under the EUTR?

Recycled papers and timber-based substrates that have already been printed are out of the EUTR scope, which means that end clients can breathe a sigh of relief when their orders arrive.

But anyone sourcing and selling untouched paper, board and pulp products is affected by the legislation, and will be obliged to begin compiling a comprehensive report of their sourcing activities.
For example, if a company buys magazines from the US and brings them into the EU to sell, this falls outside of the EUTR.  However, if a printing company buys in unprinted paper to then use for printing, it will have to comply with the EUTR.

Under the regulations, anyone placing timber products on to the EU market for the first time (such as merchants and printers sourcing direct from outside the EU) is an ‘operator’ required to keep records of the timber product itself.

This includes a description of the type of product and species of the timber used, the country of harvest (and, if there is a risk of illegal harvesting in the country of origin, which sub-region), the quantity brought on to the EU market, the names and addresses of the external suppliers and internal buyers.

Next in the chain are the "traders", a broad spectrum of users that will include printers, defined in the legislation as those buying or selling timber products once it has reached the EU. Traders are obliged only to retain information on who they bought their paper, pulp or board from and who they sold it on to.

‘Negligible risk’
The job of the trader is to add to the traceability map, should illegal products be found in the supply chain, while the operator must ensure there is only ‘negligible risk’ of such timber entering the market in the first place.

Quite rightly, some will perhaps ask if the EUTR is an alternative to the existing FSC and PEFC sustainability certifications in the UK. They may also ask if using products accredited by theses standards will suffice.

But Michael Kearney, project manager for timber regulation enforcement NMO, says that they will not automatically comply with the new EUTR.

"Operators must still apply due diligence to certified products, which will involve information gathering, risk assessment and risk mitigation if necessary," he explains.

But he adds that FSC and PEFC accreditations can be used to supplement records needed for the EUTR and the due diligence procedure.

And as Paperlinx procurement director Scott Barclay says: "If any printer has gone through the chain of custody for FSC or PEFC, I think they would only have to make a small change in their procedures to capture this data. But for anyone who has not gone through that process, it may require a bit more work."

Barclay confirmed that Paperlinx expects to be entirely compliant with the EUTR in time for its introduction, a sentiment echoed by Antalis McNaughton and Arjowiggins.

But Asia Pulp and Paper head of European sustainability and stakeholder outreach Liz Wilkes points out that others may need more time: "I would hope that the printing industry would be given some time to meet the standards, because a lot of the marketplace isn’t aware of the legislation, let alone what is needed to meet it."

In fact, those bound by the new EUTR have until 3 March 2018 to be fully compliant, by which time they are expected to have compiled a comprehensive five-year database of their buying and selling activities.

Risk-based approach
And Kearney says that the NMO will be taking a risk-based approach, assessed on a case-by-case basis. "We don’t want to be overzealous or sanction-heavy, and may give people a notice of remedial action if their records don’t comply."

He adds: "While we will take a robust line with serious, persistent and deliberate non-compliance, we recognise the importance of supporting companies that are seeking to comply with the regulation."

Kearney says that by reducing the demand for illegally harvested timber in the EU, it will become a less economically viable product, and the incentive to be a part of the chain will diminish.

He adds: "Illegally harvested timber destroys wildlife habitats and forces reputable traders out of business – as well as compromising human and child rights – especially among indigenous workers.
"Everyone loses out with illegal harvesting, except the organisations and businesses sitting at the top."

30-second briefing

• The European Union Timber Regulation comes into effect on 3 March and prohibits the trade of illegally harvested timber products within the EU market
• The regulation has been put in place by DEFRA, and will be enforced in the UK by the National Measurement Office
• Traders are classified as those trading in timber products once they have entered the EU supply chain. They are required to keep records of the products’ suppliers and buyers
• Failure to comply with the EUTR can result in a £5,000 fine or up to two years in prison
• Its aim is to reduce the economic viability of illegal harvesting to get rid of the incentive to engage in it, thereby working toward eliminating the practice altogether
• Illegal harvesting negatively affects the environment, wildlife, business and human and
• children’s rights

READER REACTION

Is the print sector now ready for the introduction of EUTR?

Simon Biltcliffe
Managing director, Webmart UK
"I was unaware of the EUTR, but we have already, wherever possible, sourced from suppliers that we know are beyond the minimum [for environmental credentials]. We also try to use FSC and PEFC paper. Illegal logging is the bane of our lives – it ruins the image of print and what we’re doing. If you get illegally logged timber, everything that the print and paper industry does is blown out of the water. It is incumbent on everyone in print that we are whiter than white and take a zero-tolerance stance."

Aaron Griggs
Account manager, VR Print

"As this is a very new policy within the EU, I feel that I talk for most when I say we will see how it runs and slowly implement various changes to our paper trail internally in order to to conform to the new regulations. I worry about it turning into an idea that’s just there to make someone some money, policed initially and then not looked at again – an issue the recent horse meat scandal makes an example of. I see many FSC logos around that still have no chain of custody numbers on them, which I thought was the whole point."

Richard Owers
Marketing director, Pureprint
"As members of the WWF Global and Forest and Trade Network Paper Group we have considered EUTR for some time. In January, I contacted our paper merchants to discuss putting the framework in place. The customer-facing sales side we deal with had patchy knowledge at that point, but the speed of their answers showed their procurement departments were well up to speed. Paper merchants’ customer-facing staff are the source of paper information for most printers, so the spread of EUTR knowledge will depend on them."