EU Timber Regulation No. 995… or ” An Inspector Calls”
The new regulation No 995 has been live now for some three months and yet we don’t really know how it will proceed.
The need for legislation, to prevent the import of timber & timber related products from illegal sources into the EU geographical domain, is a long overdue requirement, but there remain many loopholes.
For us at Gould, the implication was that we are classified as a "Trader" and the majority of our paper/board (timber related products) originates from mills within the EU or from the USA which has a complementing regulation known as the Lacey Act.
Therefore we were required to ensure that all of our suppliers had the requisite environmental accreditation, and that we maintain copious records of our transactions.
For a limited amount of material that we purchase outside of the EU, we became "Operators" and had to insist on detailed information from our supply chain right back to the forest.
So having done all that, what next?
Well the EU inspectorate haven’t yet appointed the inspectors! And will those inspectors be recruited from the timber or paper industry, thus applying their bespoke market knowledge to the job? No!
Where will the inspectors start? With timber or timber related products? Nobody seems to know.
Are there any exceptions to the legislation?
One would hope that given the object of the regulation is to prevent illegally sourced material entering the EU, the answer would be ‘No’. But that’s not the case.
Already certain printed items are exempt... which means that an EU company can source printed material from say China or other Far Eastern countries, irrespective of where the paper was sourced/manufactured, have it printed and import it without being subject to the regulation.
The 995 regulation document lacks definitive direction, and it is necessary then to search the sub sections 48 & 49 of the whole EU legislation to find specifically detailed information.
This seems to be an ill thought out regulation, and one that could certainly affect UK printers, because the whole regulation could be avoided by simply pushing more print to the Far East.
For the moment though, we sit with our documented information and wait for when "An Inspector Calls"
Written by Roger Warwick