Exploratory Assessment of a Company’s Due Diligence System against the EU Timber Regulation: A Case Study from Northwestern Russia

Abstract

This study uses a company’s due diligence system (DDS) as an operational tool to ensure the origin of wood coming from northwestern Russia. The company exports a majority of its wood products to European Union (EU) countries, and its DDS consists of a statement of origin, geographical information, and field verification audits. Its DDS is assessed against the European Union Timber Regulation (EUTR). Enforcement of the EUTR began in March 2013 and is compulsory for all companies importing wood-based material from outside the EU. The DDS must contain three key components: access to information on operator’s supply of timber or timber products placed on the market, a risk assessment, and a risk mitigation method. The workflow of the conformity assessment must include a literature review, statistical and field data collection, and further analysis of the requirements. Although enforcement of the EUTR began almost two years ago, there is little research on its implementation. This DDS system showed high functionality of its existing components corresponding with the general requirements of the standards developed by the Nature Ecology and People Consult (NepCon), a non-profit organization recognized as the monitoring organization by the European Commission. This wood origin system also meets the requirements of the Forest Stewardship Council (FSC) certification system, while maintaining full harmonization with the EUTR legislation. However, major obstacles persist in implementation of legislation by EU member states, in terms of interpretation of requirements, prosecutions and fines, and the role of third-party evidence.