Saturday 13 July 2013

Effects on printers of the Timber Products Regs. 2013

The Timber and Timber Products (Placing on the Market) Regulations 2013 came into force on 3rd March 2013.

What has this to do with printers?
Those of you with PEFC certification will already be aware of this which is in the new regs. PEFC ST 2002:2013.  Strategic Safety Systems is sending out updates to companies whom we have helped with FSC/PEFC to procedure 6.6 prA Supplier Review that has a sentence stating that this procedure already meets the new requirements.

There are 2 categories:

  • Operator - organisation that imports paper into the EU 
  • Trader - person who subsequently uses the paper. 
Printers will predominantly be classed as "Traders".

Obligations on traders
Maintain records on their suppliers and customers in relation to these products.

Obligations on operators
You have a duty to undertake a due diligence operation to ensure that the timber has been felled legally.
If you are buying FSC or PEFC paper (even if you are not making a claim), this is already covered.  However if you are importing paper from outside the EU and it is not FSC or PEFC, you need to undertake a due diligence check on the source of paper. This should also include the pallets on which the paper is delivered, but not the packaging around the paper.

How do I do this?
You need to do the following:

Gather the following information on the timber:
Description (including the trade name, type of product and common name/full scientific name of species);
  • Country of harvest (and, if applicable, region of harvest, as well as the concession of harvest – i.e. any arrangement conferring the right to harvest timber in a defined area);
  • Quantity (expressed in volume, weight or number of units);
  • Name and address of the supplier to the operator;
  • Name and address of the buyer (trader) who purchases the timber;
  • Documents or other information indicating compliance of the timber and timber products with the applicable legislation. For some concrete examples of what counts as ‘documents or other information’, please see section 4 of the Guidance Document.

Risk assessment
Analyse and evaluate the risk that the timber you are dealing in is illegally harvested. When making this assessment, investigate the wood you are dealing in using the following criteria:
  • Assurance of compliance with applicable legislation, which may include certification or other third-party-verified schemes which cover compliance with applicable legislation;
  • Prevalence of illegal harvesting of specific tree species;
  • Prevalence of illegal harvesting or practices in the country of harvest and/or sub-national region where the timber was harvested, including consideration of the prevalence of armed conflict;
  • Sanctions imposed by the UN Security Council or the Council of the European Union on timber imports or exports;
  • Complexity of the supply chain of timber and timber products.

Risk mitigation
If you are not satisfied that the risk of placing illegally harvested timber on the market is negligible, you must take action by implementing risk mitigation measures. These may include:
  • Requiring additional information from your suppliers;
  • Requiring additional documents from your suppliers;
  • Requiring third party verification, etc.”

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