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

The EU Timber Regulation requires operators to carry out due diligence to assess the risk of illegal timber being present in their supply chains.

Competent Authorities who are responsible for the application of the EU Timber Regulation at national level must carry out checks on operators to verify that they comply, among other things, with the obligation to exercise due diligence.

Documents from official sources are one type of information that operators are very likely to use to exercise due diligence. This briefing illustrates why having access to official documentation is not, on its own, sufficient to comply with the Timber Regulation. It explains why the credibility and relevance of official documents must always be considered by both operators and Competent Authorities.

In addition, it suggests certain practical steps which can be taken by operators in order to scrutinise official documentation against additional sources of information. This guidance should be understood as an indication only of what can be done to look beyond official documentation. It is the operators’ responsibility to take all reasonable steps to do so, depending on the circumstances of each case.