Illegal logging – evaluation of EU rules (fitness check)

We see the EUTR as the right tool to prevent illegally harvested timber and timber products from being placed on the EU market. Many of the provisions of the EUTR currently leave too much room for interpretation, so that Member States implement them in very different ways. The undertakings concerned do not have uniform guidelines, including inspection procedures and acceptance of third-party certification.

Filed in German · English published by the European Commission

The European Union Timber Regulation is a pioneering piece of legislation and remains a vital tool in the global fight against illegal deforestation and the associated trade in commodities. While there have been laudable steps taken by a few Member States to enforce this law over the years, these instances have remained the exception rather than the rule.

CEI-Bois wishes to provide the inputs of the European Woodworking Industry to the EU Timber Regulation and FLEGT fitness check. EU Timber Regulation The EU added value of this instrument is undeniable: only a uniform set of rules valid for all EU countries and a coordinated enforcement can make an impact against illegal logging worldwide.

FINAL CONTRIBUTION. Illegal logging is one of the main global causes of deforestation and causes considerable environmental damage and biodiversity loss. It has serious implications for climate change, and make forests more vulnerable to fires. The European Organisation of the Sawmill Industry condemns any form of illegal logging.

ClientEarth considers that both the EUTR & FLEGT Regulation have contributed to more legality and transparency in the global timber supply chain and have made progress towards achieving the objectives of the FLEGT Action Plan.

The European Furniture Industries Confederation (EFIC), welcomes EU initiatives aimed at strengthening the fight against illegal logging. Illegal logging is a pervasive problem of major international concern. Forests provide a broad variety of environmental, economic and social benefits essential for humankind, such as maintaining biodiversity and ecosystem functions and protecting the climate.

Illegal logging contributes to severe environmental, social and economic impacts globally: from increased greenhouse gas emissions due to deforestation, to biodiversity loss and impacts on indigenous communities living in forested areas.

WWF feedback The intention of both the EUTR and the FLEGT regulation is to fight illegal logging and related trade. A fitness check of the regulations therefore needs to address this overarching objective thoroughly and equally from an economic, social and environmental perspective. EUTR Apparently the fitness check will mainly focus on the implementation of the EUTR over the last years.

The Finnish Forest Industries Federation welcomes the upcoming fitness check to evaluate the key legal instruments of the FLEGT Action Plan, namely the FLEGT Regulation and EU TR. The Finnish forest industry actively promotes procurement of legal timber and subsequently usage of legal timber in the whole value chain.

State Forests National Forest Holding is a Polish governmental organization that manages state-owned Polish forests on behalf of the Polish State Treasury. It was founded in 1924 and now oversees about 7.5 million hectares of forest (about 77% of Polish forests and 25% of Poland's territory).

BirdLife Europe echoes calls for the EUTR fitness check to assess the legislation in light of its environmental goals and legal basis (Art. 192 TFEU), and in terms of its contribution to the EU’s forest protection objectives.

The ELO represents the collective voice of landowners, managers and farmers across Europe. Their business and private properties are the core for a sustainable and prosperous countryside. The ELO addresses issues that affect European rural areas, which represent over 82% of the EU's territory (48% farmland and 36% forest) and is home to around half its population (consisting of farming communities and other…

As a large user of wood, sourcing from over 50 countries, the IKEA business can have a significant impact on the world’s forests and the timber industry. That’s why we place sustainable forest management at the core of our business – working to eliminate forest degradation and deforestation and promoting its importance in and beyond our own value chain.

The European Panel Federation (EPF) supports the use of sustainable materials for wood-based panels and embraces EUTR. Recent experience has shown us how challenging EUTR is for companies, especially when it comes to audits and requests for information from our members’ clients.

Fern is a non-governmental organisation which aims to achieve greater environmental and social justice, focusing on forests and forest peoples’ rights in the policies and practices of the European Union. Fern believes that the EU Forest Law Enforcement Governance and Trade (FLEGT) Action Plan through its Voluntary Partnership Agreements (VPAs) has prompted forest-related legal and policy reforms in all partner…

The attached document provides the Environmental Investigation Agency's full feedback on the Roadmap for the EUTR/FLEGT Regulation Fitness Check. This is a summary of the points made in the feedback document. The Environmental Investigation Agency (EIA) takes the position that the European Union Timber Regulation (EUTR) and FLEGT Regulation provide a framework that is fit for purpose and contributes to the…

The European paper and board industries welcome the upcoming fitness check to evaluate the key legal instruments of the FLEGT Action Plan, namely the FLEGT Regulation and EUTR. Legally sourced, certified primary raw materials from sustainably managed forests are prerequisite for the European paper and board industry. EUTR helps to secure legal sourcing of products sold on the European market.

Forest Stewardship Council (FSC), a global NGO promoting sustainable forest management through its certification scheme, welcomes the EU Roadmap and wish to highlight the following points: 1) FLEGT & FSC – legality and sustainability are better together FSC is committed to fight illegal harvesting together with the EU.

FederlegnoArredo is the Italian Federation of Wood, Cork, Furniture and Furnishing Manufacturers. Within the Federation, timber traders who place timber and timber products for the first time into the European Community are represented by Fedecomlegno.

The EUTR fitness check should assess the legislation in light of its environmental goals and legal basis (Art. 192 TFEU), and in terms of its contribution to the EU’s forest protection objectives. An evaluation limited to the economic costs and benefits for the stakeholders involved would not be appropriate for the EUTR, as its primary objective is environmental, not economic.

As a representative of 36 State Forest Management Organizations which, together, manage 1/3 of Europe’s forests, we would like to share the experiences of our members regarding the present EU rules on illegal logging, specifically the EU Timber Regulation (EUTR) as part of the FLEGT Action plan.

In line with Article 20.4 and subsequent Commission's Report (COM(2016)74), Intergraf calls for the extension of the scope of the EU Timber Regulation to printed products. The trade and economic situation as well as competition and environmental aspects in support of the extension are detailed in the attached position.

The EUTR was a good step into the right direction, but there are at least three elements, which require further improvement (a) the annex of the legislation must be all inclusive to cover all forest related products. This is going to be even more relevant if the EU pushes the implementation of the BioEconomy strategy further.

GD Holz Service GmbH is a recognized EUTR Monitoring Organization. We see the EUTR as a potentially valuable tool to protect forests worldwide. However, only a few EU member states set standards that are high enough to meet this goal. In our opinion, some countries take the EUTR very serious whereas others don’t really care. As long as this is happening, the EUTR remains inefficient.

Fedustria is the Belgian sectoral federation that defends the interests of the textile, wood and furniture industries, including timber import companies. The fight against illegal logging is vital for the continued existence of our sector. Both Fedustria and its individual members are fully aware of this and, to this end, are taking all necessary steps to fight illegality.

ETTF represents 15 European timber trade associations with timber importers who import from all over the world. It is the representative trading organization for timber and timber products in the EU market and worldwide. Moreover, there are 3 Monitoring Organizations (France, Italy, Germany) within the membership of ETTF – others take care of a due diligence system to fulfil the requirements of the EUTR as well.

The illegal logging can be reduced significantly by implementation of systematic utilization of the existing ON-THE-GROUND-MINES, in the meaning of utilization of single-use wooden packaging like pallets, boxes, cable drums which 54% are being scraped after single-use. The tool to be applied exists, it is called INDUSTRIAL UPCYCLING and it is being implemented since 2013.

Dear European Commission, Dear Lady/ Sir, After reading the Roadmap Illegal logging - evaluation of EU rules (fitness check), I would like to recommend the following to help control deforestation as a Global problem and as an environmental and socio-economic problem existing at EU level.