Using official documentation under the EU Timber Regulation’s due diligence obligation

The briefing explains that under the EU Timber Regulation (EUTR), operators must exercise due diligence to minimize the risk of illegally harvested timber entering the EU market. While official documentation—such as permits issued by public authorities or government-accredited schemes like Indonesia's SVLK—is a common tool, the document asserts that it is not sufficient on its own for compliance. It highlights several risks that undermine the reliability of official papers, including forgery, corruption in permit allocation, the use of outdated permits, and a lack of enforcement or monitoring on the ground. To mitigate these risks, the briefing recommends that operators and Competent Authorities supplement official documents with data from NGOs, research institutes, public bodies, and satellite imagery, while maintaining detailed records of their risk assessment procedures.

• The EU Timber Regulation (EUTR) requires 'operators'—those placing timber on the EU market for the first time—to follow a risk management approach consisting of three elements: accessing supply chain information, assessing risks of illegal timber, and mitigating any non-negligible risks identified.
• Official documentation, defined as assurance of compliance issued by a body exercising official authority (including government agencies and accredited schemes like Indonesia's SVLK), is insufficient for EUTR compliance because operators must evaluate the credibility and relevance of such information.
• Official documents can be unreliable due to forgery and corruption. For example, the German EUTR Competent Authority encountered a fraudulent letter allegedly from the Environment Ministry of the Democratic Republic of Congo in 2013, and Cameroon's independent anti-corruption commission reported irregularities in logging permit tenders in 2011.
• Legal gaps can occur when old permits remain in use despite new legislation. In Ghana, research by Global Witness indicates that many permits granted before the 1998 Timber Resources Management Act have not been converted into required Timber Utilization Contracts, rendering them illegal under current law.
• Authentic official documents may still mask illegal practices, such as logging beyond quotas or poor enforcement. In the Brazilian state of Pará, sawmills have used authorized forest management plans that do not match actual harvested areas, and in Myanmar, a lack of segregation at Yangon's seaports allows timber from non-exportable sources to be mixed with legal timber.
• To properly scrutinize documentation, operators should use diverse information sources, including public bodies (UNEP, FAO, ITTO), research institutes (EFI, WRI), NGOs (Greenpeace, WWF, Global Witness), and satellite imagery from platforms like Global Forest Watch and Google Earth.
• Operators can verify the validity of documentation by contacting public authorities in the country of harvest to prevent forgery, checking if procedural requirements for specific permits were met, and keeping historical records of documents to identify inconsistencies.

APA

Unwin, E., & de Rouvre, D. (2015). Using official documentation under the EU Timber Regulation’s due diligence obligation. ClientEarth. https://www.clientearth.org/media/fe2j5qdp/2015-03-25-using-official-documentation-under-the-eutr-due-diligence-obligation-ce-en.pdf

Chicago

Unwin, Emily, and Diane de Rouvre. Using official documentation under the EU Timber Regulation’s due diligence obligation. ClientEarth, 2015. https://www.clientearth.org/media/fe2j5qdp/2015-03-25-using-official-documentation-under-the-eutr-due-diligence-obligation-ce-en.pdf.

Wikipedia

{{cite report |last1=Unwin |first1=Emily |last2=de Rouvre |first2=Diane |title=Using official documentation under the EU Timber Regulation’s due diligence obligation |publisher=ClientEarth |date=March 2015 |url=https://www.clientearth.org/media/fe2j5qdp/2015-03-25-using-official-documentation-under-the-eutr-due-diligence-obligation-ce-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{unwin2015using, author = {Unwin, Emily and de Rouvre, Diane}, title = {{Using official documentation under the EU Timber Regulation’s due diligence obligation}}, institution = {ClientEarth}, year = {2015}, month = mar, url = {https://www.clientearth.org/media/fe2j5qdp/2015-03-25-using-official-documentation-under-the-eutr-due-diligence-obligation-ce-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }