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European Timber Trade Federation

ETTF

The European Timber Trade Federation (ETTF) represents the timber importers, distributors, traders and non-importing trader interest’s across Europe and operates on a united base, representing and lobbying on behalf of the trade to national level and EU-authorities as well as key decision makers.

Lobbying Activity

Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis), Cristina Rueda Catry (Cabinet of Executive Vice-President Valdis Dombrovskis), Sofja Ribkina (Cabinet of Executive Vice-President Valdis Dombrovskis) and

17 Sept 2021 · Upcoming Russian export ban on logs

Response to Illegal logging – evaluation of EU rules (fitness check)

18 Feb 2020

ETTF represents 15 European timber trade associations with timber importers who import from all over the world. It is the representative trading organization for timber and timber products in the EU market and worldwide. Moreover, there are 3 Monitoring Organizations (France, Italy, Germany) within the membership of ETTF – others take care of a due diligence system to fulfil the requirements of the EUTR as well. Main issue of ETTF is the request for fair and free trade of legal and sustainable timber from all over the world. First: The FLEGT process started in 2003. Up to now there is only one country that has a FLEGT system in place, namely Indonesia – This is clearly not enough. ETTF fully supports the FLEGT process and asks the EU to speed up the process. The path to FLEGT licensing is already very helpful as it contributes to a risk mitigation in the due diligence – The FLEGT process has raised awareness of legality and sustainability aspects in countries of origin. Second: EUTR and the national legislation are a story of success in general; the European timber trade emphasises the importance of EUTR in forests and the entire chain of custody. Moreover, it is also a suitable instrument to guarantee legality of wood to consumers. Despite the additional bureaucracy, timber importers, MO and national associations have so far done a very efficient and excellent job in achieving the goal of a traceable due diligence. But we must continue to meet the challenges and need support and cooperation at both EU and national level: - Up to now, there is no level playing field within the EU, with the result that there is unfair competition between countries that take tough action and others that take less stringent control; it is urgent to achieve the same level of scrutiny for every country. - Cooperation between EU and ETTF should be enhanced. ETTF has made proposals for a legal due diligence with a CoC dossier. The decision whether this is suitable must be carried out on a technical, but also on a political level. It is not acceptable for the EU to leave political decisions to any foreign trade sector. - When comparing Competent Authorities (CA) within the EU, it is obvious that they operate differently and, also communicate differently – often in a way which operators cannot follow. This often means that rules for certain import cases are changed along the way without communication. This makes it impossible for importers to follow the rules and fulfil their contracts accordingly. That must be improved. - Due to the growing importance of wood as carbon store it is necessary to increase the worldwide use of wood. The EU must take care for that development (Green Deal) and should cooperate more with timber industry. - In our opinion, CA are increasingly confusing due diligence (undefined) with evidence(defined). The EUTR only requires compliance with due diligence – the definition of due diligence lies within the responsibility of the operator. This cannot be emphasized often enough. - The CPI is a valuable method to show corruption in the countries of origin. But it only shows an average value throughout various sectors of an economy and administration in a certain country. Corruption in special parts of countries or sectors in its economy may differ from the average – if this is the case e.g. for the forest industry, and the forestry industry didn’t even play a role in the analysis of corruption in a country, then the CPI must not play a crucial and hence destructive role when it comes to timber imports. Furthermore, we suggest to keeping the UK in the scope of the future public consultations due to the fact, that they have a lot of experiences in that special issue. ETTF and its members are ready to meet any challenge to improve the effects and effectiveness of FLEGT and EUTR; only legal and sustainable timber can form the basis for a successful business for the future. Thomas Goebel, Secretary General
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