TDUK issues warning over Birch Plywood imports

birch plywood

TDUK, and previously TTF, has always operated the Responsible Purchasing Policy (RPP) due diligence system to maintain the reputation and integrity of the timber supply chains and timber goods being placed on the UK market via our members.

This due diligence is particularly relevant now given the situation with Russia and the ban on trade.

Our recent analysis of import data available for 2023 shows very high volumes of Birch Plywood entering the UK from sources never before known to have supplied or produced Birch Plywood. We have had contact with OPSS in the UK as well as from European counterparts who are also monitoring this situation. We are therefore trying to ensure we take all reasonable precautions to maintain the reputation of our membership and the wider industry.

At present there is only a very limited supply of Birch Plywood which has evidence to show it is fully compliant with the UK and EU timber regulations, with origin from negligible risk sources. This means there is a high risk of Birch Plywood being placed on the UK market where the veneers or other birch raw material has originated in Russia or Belarus, but the plywood itself has come from other sources eg China, Turkey, Vietnam etc.

Given the sanctions that are in place under UK law and throughout European member states such wood based raw materials originating in Russia or Belarus since the implementation date of the sanctions, would clearly be a breach of the UK Timber Regulations and the EU Timber Regulations and are therefore illegal. The only exception are goods where it can be proven that they were sourced prior to the invasion of Ukraine.

Companies which are bypassing the sanctions via 3rd countries are committing an illegal act and in the view of TDUK and its members should be held fully to account for their actions. Companies who are purchasing such Birch Plywood once landed in the UK are in our view equally culpable because they are not ensuring their supply chains are fully legal and giving an outlet for the illegal importer.

This communication is being sent to all TDUK members trading in panel products to ensure you are fully informed about the heightened concerns around the import of Birch Plywood. TDUK want to remind all members that as an Operator or Trader, robust due diligence, fully supported by reliable evidence is the only way to protect yourselves and the sector against accusations of illegal trading.

TDUK therefore reminds members that the UK Timber Regulation requires Operators to have in place a fully evidenced process of due diligence that is conducted and recorded in advance of the Birch Plywood arriving in the UK. The conclusion of this due diligence process must confirm that there is only a negligible risk that the Birch Plywood being imported could contain illegal wood.

In the current climate it is not possible for any forms of mitigation which could support the purchase of Birch Plywood at a higher risk status.

TDUK will continue to closely monitor the situation and encourage OPSS as the UK enforcement body to investigate and, where necessary, act against companies whose due diligence processes for Birch Plywood are not sufficiently robust or evidenced. Members should be aware that this ongoing monitoring work may in some circumstances require submission of Birch Plywood due diligence ahead of scheduled RPP audit dates.

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