China's furniture exports can calmly deal with EU timber rules

The British Furniture Association recently published an article on its website that outlines the EU timber rules and explains how to comply with the regulations in the UK. This has certain implications for us to understand and respond to this new regulation.

Good forest management can reduce the impact on climate change and better achieve environmental, social, political and economic benefits. This has formed a consensus around the world. The EU has accordingly enacted the EU Timber Regulations. Its purpose is to further improve forestry operations and logging activities and prevent illegally harvested timber from entering the EU market. The regulation is a mandatory regulation that will take effect in March 2013, which means that it will be officially implemented in less than 12 months. It is mainly suitable for wood and wood products produced in the EU and imported from countries outside the EU. Therefore, this regulation is closely related to furniture products and wood products for interior decoration such as wood, floor and joinery. Furniture and wood products manufacturers, retailers and importers will face a new and stringent requirement.

1 main content of the regulations

The title of this regulation is: EU Timber Regulation No. 995/2010. It contains the following basic content:

(1) Basic requirements of the EU timber rules;

(2) The role of the certification scheme;

(3) How to enforce the EU timber rules;

(4) A timetable for implementing this regulation.

Regulations require companies that enter timber and wood products in the EU market to assume an obligation that timber is not from illegally harvested forests. It also imposes requirements for institutions within the EU that engage in the trade of these products, which cover a wide range of categories, with the exception of some that are clearly recycling projects and their materials.

1.1 Basic requirements of the regulations

The basic requirement of the regulation is to implement a “due diligence investigation” procedure for the first contractor (defined as “operator”) of timber products entering the EU market to minimize the “illegal logging”. The risk of wood products entering the EU market.

However, traders who purchase within the EU do not require a “due diligence investigation”, but records must be kept from other agencies.

The “due diligence survey” set by the EU Timber Rules allows most companies to use existing work methods or relatively easy work methods to reduce the amount of extra work and costs that are not appropriate.

All relevant records must be kept for 5 years and must be supported if necessary. However, sales records to the general public sector and end consumers are outside the scope of this regulation.

Obviously, these operators may also be traders, especially for the furniture industry, because its product supply chain can be complex and involves many different relationships between institutions. Therefore, it needs to be analyzed. Among them, the typical situation may be as follows:

Selling furniture purchased directly from Chinese retail channels in the UK. This retailer is the so-called "operator" because he is the first person to introduce furniture to the EU market.

A British furniture manufacturer, he purchased wooden legs from Indonesia, assembled them on upholstered furniture, and then sold them to British retailers. Well, the furniture manufacturer in the UK is the so-called “operator” because he is the first person to introduce this leg into the EU market.

Also a British manufacturer, he bought a chair armrest and a fully painted table from a French company. In this case, the British manufacturer is defined as a trader and does not require a “due diligence” for products such as these; as their procurement and sales records already meet the requirements of the regulation.

The agent handles the purchase, loading and import of furniture parts produced in Vietnam to the UK, but all contracts are signed directly by the agent's UK customers and Vietnamese suppliers. The agents are neither “operators”. ", not a trader. In this way, the agent's UK customer is the so-called “operator” because he is the first person to introduce the product into the EU market.

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