Organisations must apply their Due Diligence System to all timber products within scope. There are 3 key areas required as inputs for the Due Diligence System that are outlined in the Commission implementing Regulation (EU) No 607/2012:
Organisations obtain information from their supply chain for their timber within a 12 month period (maximum) to ensure there are minimal changes possible in the supply chain. All findings must be held for a minimum of five years as evidence. This information includes:
- Countries of harvest
- Scientific/botanical name of timber species
- Sub-national region
- Concessions of harvest, if applicable
Any certificates declared must have an unbroken supply chain and available to check from the forest of harvest to the end product. You can use your own Due Diligence System for this or use a monitoring provider that can help to check the Due Diligence System is being used properly
Organisations must analyse and evaluate the information obtained against relevant criteria including;
- Compliance to legislation
- Prevalence of illegal harvesting of the tree species
- Practices in the country of harvest
- Accounting for the complexity of the supply chain.
Organisations must establish a procedure to ensure appropriate checks are made by a third party to verify timber is traceable through the current supply chain, the Due Diligence System works, and the documentation is authentic. Where non-negligible risk is apparent, the organisation must respond appropriately to mitigate the risks identified.
Organisations must hold records to demonstrate how the information obtained was checked against their risk criteria, how specific decisions were made (including concluding the degree of risk) and the details of the measures that were taken.