Due Diligence

In October 2010, the European Union approved a system to prevent the illegal timber trade in Europe through two specific regulations, the n ° 2173/2005 and the n ° 995/2010, known with the acronyms FLEGT (Forest Law Enforcement, governance and trade) and EUTR (European Union Timber Regulation).

The latter, which came into force on 3 March 2013, is applied to wood and all products derived from it, including paper. For companies that introduce wood fiber based products into Europe, the regulation prohibits the placing and trading of products of illegal origin and obliges the introduction of an internal system of due diligence (Due Diligence).

The EUTR is the regulation for the “legal” wood of the European Union:
1. Prohibits the first placing on the Community market of wood and illegally-cut products derived from it;
2. Introduce to EU operators who place wood products on the Community market for the first time, to perform due diligence (due diligence);
3. obliges traders to keep the documentation of their suppliers and customers in order to facilitate traceability of wood and its derivatives;

The “due diligence” is based on 3 principles aimed at minimizing the risk of introducing illegal timber or products derived from it into the market:
1. information on risk
2. risk assessment
3. risk mitigation

This regulation is applicable to operators, therefore to companies that cut timber to process it or sell it, to companies that import wood and products derived from it to process or sell them and companies that import wood into the EU exclusively for their own use, in any case those who first enter Extra EU timber in the EU. It is the nature of the activities performed to determine the status of operator or trader.

Our company is part of the group of operators, because it puts wood or products derived from it for the first time on the EU market, we are therefore subject to the obligation to introduce due diligence and for some time we are already working to be in order with this legislation.

With respect to this legislation, all our customers are traders / retailers, that is, any natural or legal person who, during a business activity, sells or buys wood or derived products already on the internal market on the internal market (from an operator), therefore already nationalized. The obligations required by law for our customers are:

1. be able to identify the operators or traders who supplied the wood and products derived from it and thus ensure the traceability of the materials.
2. be able to identify the traders to whom the wood and products derived from it were supplied and therefore ensure the traceability of the materials.
3. The information must be kept for at least five years and provided to the competent authority if required.

According to the law, therefore, we are not obliged to provide any certification or documentation to our customers who buy from us already Italianized goods (subject to our FSC certification in case of FSC purchase, but this was also a previous obligation, and in any case our certificates are set out on our website).

Our customers have to “only” keep their supplier (purchase) / customer (sales) register, in case of control by the competent bodies we will be tracked as suppliers of goods and at a later check we will ourselves have to provide the documents required to the control body and not to our customers.

However, for customers who request it, although it is not required by law, we have set up a summary declaration with the information concerning: common name, botanical name, country of origin that we can safely provide in view of each sale.