There has been a great deal of comment in the press about the new regulation EUTR that is designed to help stamp out the global problem of illegal logging and, especially in the tropics, deforestation. The law covers timber and timber products, so as far as the print industry is concerned this means paper and board. It is now mandatory for all EU importers of these goods to carry out due diligence to ensure that these goods have not been produced from illegally logged wood.
The paper industry items covered by the EUTR are listed in Chapters 47 & 48 of the Common Customs Tariff, these lists cover a wide range of goods including converted paper items and even some printed materials. Recycled paper fibre is exempt, but for part recycled the importer still needs to carry out due diligence on the virgin wood fibre content. Paper made from bamboo is also exempt.
The Customs Tariff publication (Official Journal of the European Union L304) can be downloaded directly from the EU, it is roughly nine hundred pages long! But as a quick reference on converted and printed paper goods, including some stationery items, covered by the EUTR here is a rough guide.
For goods included within the scope of the EUTR an effective due diligence process should be carried out by the importer which identifies the process and origin right back to the actual tree species used and locality of the growth & harvest.
The big "print" items to watch here are printed labels, a great deal of printed cartons and bags, as well as many types of paper stationery goods with or without print. These all now require due diligence under the EU Timber Regulation, failure to do so can result in criminal prosecution, fines and jail sentences.
The list attached is not fully inclusive, each EU member state has appointed a national Competent Authority to implement EUTR, in the UK this is the National Measurements Office, who will also carry out physical inspections in ports and warehouses, investigations, and will ultimately decide which goods are covered by the EUTR and which are not. With specific reference to print the subsequent chapter of the customs tariff, Chapter 49, is not included in the EUTR, this covers PRINTED BOOKS, NEWSPAPERS, PICTURES AND OTHER PRODUCTS OF THE PRINTING INDUSTRY; MANUSCRIPTS, TYPESCRIPTS AND PLANS.
Looking at the types of printed goods listed and the traceability rules for EUTR due diligence there are probably numerous printers across the EU able to pick up interesting domestic contracts from companies who previously imported print and stationery from outside the EU. The main reason being the comparative ease of due diligence for the print buyer when dealing with a domestic printer!
Stuart Andrews is director at Sustainable Options.
