The UK Timber Regulation was implemented on the 1st of January 2021 to replace the EU Timber Regulation after Brexit. The UKTR is broadly similar to the EUTR in that it curbs the trade of illegal timber entering the UK/Europe. Businesses across the UK are required to continue to implement a system of due diligence to ensure imported timber products have been legally harvested, traded and exported in the country of harvest.
There is one significant difference between the two regulations. UK Businesses who import timber from outside the UK are considered an ‘Operator’ under UKTR. Therefore, due diligence has to be implemented to prove ‘negligible risk’ of the timber.
Successful implementation of the regulation is of great importance. Illegal logging leads to widespread biodiversity loss, impacts forest-dependent communities, contributes significantly to greenhouse gas emissions and undercuts legitimate businesses seeking to operate responsibly. It costs governments in timber producing countries between 10 and 15 billion euros per year, which could otherwise be spent on schools, roads and other much needed development.
Our approach to due diligence
As a major importer of timber from around the world (including the EU and UK), Brooks Bros (UK) Ltd acts as an "Operator" under Regulation. Out of our legal obligations comes an opportunity to engage constructively with our suppliers, providing a solid framework from which to reward good practice.
We have implemented a Due Diligence System, which was developed by an EU-approved Monitoring Organisation and tailored this to our businesses to provide us with a steadfast assurance that we would comply with the regulatory requirements.
Due diligence is integrated in our purchasing and company processes. The key steps are:
1). Collect information about the product and supply chain. We work with our supplier to obtain information the species, mapping how the product changes through the supply chain and understanding the nature of the business of each company.
2). Assess the risk of illegal harvesting, trade and export in the country of harvest, as well as the risk of mixing along the complete supply chain. We take into account the research by NGOs and governments, assess gaps in certification schemes, and liaise with a range of stakeholders in country to better understand the legality issues in our supply chain.
3). Mitigate identified risks. Depending on the risks identified, this could include: desk-based audits and document reviews; building our supplier’s due diligence capacity through training; auditing our supplier’s factory, sawmill and/or forest ourselves or hiring third-party experts; implementing a programme of product testing (DNA, isotopic, microscopic etc.) to verify origin or species.
4). Determine the final risk conclusion; only if negligible risk can be concluded can the product be purchased.
Purchasing UK-landed stock
Brooks Bros (UK) Ltd also purchases timber products that have been customs-cleared in the UK. As such, we assume responsibility as a "Trader". Our obligations are simple: to maintain records of purchases and sales.
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QUESTIONS AND ANSWERS
As a customer of Brooks Bros, do I need to carry out due diligence on products that you sell to me?
No. Brooks Bros (UK) Ltd only sells products that have already physically landed in the UK and are customs-cleared. Therefore you will be acting as a "Trader". Your only legal obligation is to keep a record of your purchases and sales.
If you implement a voluntary due diligence system, we will do our best to support you. However, we do recommend that you source FSC® or PEFC certified products from us as this is most appropriate market tool in responsible sourcing and provides safeguards beyond legality.
How will Brexit affect Brooks Bros’ Responsible Purchasing Policy?
It hasn't. As stated in our environmental strategy and Responsible Purchasing Policy we are committed to sourcing legal and responsible timber. We fully support the intention of the UKTR and will continue to operate a robust due diligence system post Brexit.