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What is European Industry doing to respond to the EUTR Rachel Butler Independent Technical Advisor . USA, Europe & Australia Illegal Logging Laws…markets are aligning but will not change overnight.. These laws changes fundamentally one concept; the risk & obligation is on the importer.
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What is European Industry doing to respond to the EUTR Rachel Butler Independent Technical Advisor
USA, Europe & AustraliaIllegal Logging Laws…markets are aligning but will not change overnight..These laws changes fundamentally one concept; the risk & obligation is on the importer
Due Diligence & Certification/Verification • Not a new concept • BWWF Buyers Groups 20+ years old • Certification eg FSC Controlled Wood • AHEC/Seneca Creek – large scale regional risk assessment • Private Sector purchasing policies Legal Verification Certification Due Diligence/Due Care
Establish procedures • Initiate performance monitoring • Define scope of supply chain & products • Keep records • Evaluate supply chain info • Identify risks: • forest management • supplier level • risks of mixing & substitution • Specify risks where identified 1 2 3 4 Manage supply chain Risk mitigation Quality system Risk assessment • Record supply chain info: • origin • suppliers • species • legality documentation • Collect additional supply chain info Mitigation options • Additional documentation • Replace supplier • Source certified material • Supply chain verification audits
Certification & Verification • Certification and legality verification is a tool to support due diligence notautomatically compliant; operators choice to use it& assess it. • ProForestReports commissioned by ETTF highlights the gaps in meeting legality requirements • Further issues with certification/verification not covered in the report • Lack of info; species &source country • Fraudulent certificates
EU industry Indicators of Risk • Complexity of supply chains • Evidence of non-enforcement • Known cases of illegal activities in the supply chain • Known corruption • Lack of information about source • Lack of supply chain control • Lack of transparency • Poor quality information or documentation • Tree species
Global Trade Implementation …consistent? • Little guidance from any authorities • Good thing; flexibility!? • Lack of information on risk • Some initiatives – little of much use as yet • Buyers & producers need to know their supply chains! • Documents are not enough! • Confusion with operators who do not understand the EUTR & producer national legal regimes…. LEADING TO PANIC! • ETTF working to address e.g one due diligence system
Confusion amongst operators • Asking for information beyond the regulation • Not meeting and understanding due diligence • Putting obligations on producers • Indemnity contracts • Not a documentation regulation • Awareness will slowly increase
Guiding your Buyers • Down to the global trade to work it out therefore……. • Consistent messaging from Cameroon Industry • Easy for EU importers to understand • Helps you • Not contentious in Civil Society
Thank you! rachel.butler@rba-solutions.com or raichbutler@gmail.com