Advanced Timber Knowledge

Understanding UKTR

UKTR is the UK post-Brexit equivalent to EUTR.  Both regulations govern the import and trading of sustainable timber, particularly with regards to controlling the trade of illegally harvested timber.  This blog will assume that the reader has some understanding about the EUTR regulations such as the difference between operators and traders.  If not, it may be useful to read our blog here which explains EUTR in more detail. 

All information correct as of December 2020. 

Q&A’s Regarding the transition from EUTR to UKTR

  • Q: Currently, the problems caused by the EUTR to UKTR transition are minimal. This is thanks to UKTR regulations being almost identical to EUTR.  However, in the future, will UKTR remain consistent with EUTR? 
  • A: The policy owner of UKTR, DEFRA, currently has no plans to make any changes.  We would estimate that since EUTR is a relatively new set of regulations anyway, there will be no policy changes for the next 3-5 years.   
  • Q: Is there any differences between EUTR and UKTR? 
  • A: Both regulations are consistent with each other.  The only difference is in the definitions of operators and traders. 
  • Q: Will the change make importing and exporting timber between the UK and EU more complex? 
  • A: Yes.  For example, an EU based trader may have to become an operator for EUTR compliance in addition to meeting UKTR requirements. 
  • Q: If EUTR regulations are expanded to cover a greater number of products, would UKTR also be expanded? 
  • A: No – updates to EUTR would not automatically result in updates to UKTR.  Updates to UKTR are at the discretion of DEFRA. 

Q&A’s Regarding UKTR Definitions

  • Q: How are Operators defined? 
  • A:  The operator is whoever places the product on the market for the first time. 
  • Q: How are Traders defined?  
  • A: A trader is anyone after an operator in a supply chain.  Therefore, companies who have purchased from a trader will also be a trader (obviously apart from private consumers). 
  • Q: What products are covered/excluded? 
  • A: Any products covered by EUTR remain covered by UKTR and vice versa for products excluded from EUTR. 
  • Q: How does UKTR apply to products made from recycled materials?   
  • A: Products that have reached the end of their lifecycle fall outside of the regulations.  Therefore, an old railway sleeper repurposed as a bench would not need to be compliant.  However, second-hand products which can be reused for their former use such as whiskey barrels would need to be UKTR compliant. 

Q&A’s Regarding UKTR’s relationship with FSC

  • Q: Can FSC certification be used in compliance? 
  • A: Simply submitting a FSC certification will not mean that the timber is UKTR compliant.  Our opinion is that FSC is more comprehensive in terms of protecting forests and people who depend on forests but it is a voluntary scheme. Therefore, it cannot be used in lieu of UKTR documentation. 
  • Q: What documentation is needed? 
  • A: UKTR requires due diligence to be performed on all imports.  That includes having all relevant information regarding the species and location of its harvest, transport-related documentation and to perform a risk analysis.  If risks are found, then you would need to demonstrate that risk has been mitigated.  This is where FSC can be used in UKTR compliance, because UKTR recognises that FSC certification can be a method of mitigating risk. 

Q&A’s Regarding UKTR’s role in the future

  • Q: Looking ahead, do FSC have any plans for FSC certification to become a green lane to EUTR/UKTR? 
  • A: FSC have tried and will continue to try ensuring that FSC certification is applicable to meet EUTR and UKTR risk mitigation.  However, it is up to DEFRA to decide how they want FSC to fit within the regulations. 
  • Q: What will be the role of monitoring organisations compared to EUTR? 
  • A: Monitoring organisations will have the same function under UKTR as they did under EUTR.  Organisations registered in the UK and recognised by the EU Commission will continue to be recognised as monitoring organisations under UKTR.  Organisations based in other EU member states will not be recognised as monitoring organisations under EUTR.  If an organisation aims to become a UKTR monitoring organisation, they can apply to DEFRA.
  • Q: What will be the approach taken by the Office for Product Safety and Standards (OPSS) in assessing compliance? 
  • A: UKTR came into effect on January 2021.  However, OPSS will be working to inform and support companies in implementing the legislation and taking a tiered approach to its enforcement. 

Sources 

https://www.fsc-uk.org/preview.uk-timber-regulation-uktr-faqs.a-1142.pdf

https://www.fsc-uk.org/en-uk/business-area/fsc-certificate-holders-and-other-stakeholders/hot-topics/uk-eu-timber-regulations

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