Check if you are an importer

In most cases, Timber Trade Federation members will be both the Importer and Operator. As an Importer you will be responsible for the customs entry, and as an Operator, you will be responsible for completing due diligence on any timber and timber products.

Before bringing timber into the UK

From 1 January 2021, all importers bringing goods into the UK must follow the below steps to ensure you are complying with the new rules and regulations in place.

1. Get an Get an Economic Operator Registration and Identification (EORI) number that starts with GB.
2. Decide if you want to make customs declarations yourself or get help
3. You may need to buy specialist software to use simplified procedures.
4. You could be entitled to financial help to help your business complete customs declarations.
5. If you have authorisations to use special or simplified procedures check if they still apply.

Timber merchants will need to follow different processes for trading timber and timber products (timber) currently covered by EU law, as the UK will have its own law for trading timber. This law, called the UK Timber Regulations, will have the same requirements as existing EU rules.

The result of these changes mean you’ll need to show imports from the EU and European Economic Area (EEA) have been legally harvested. Businesses must follow these regulations now when they import timber from non-EU and EEA countries.

Plant Health

Imports of sawn conifer timber, which is bark-free, will still be permitted without Phytosanitary Certificates (unless it is from Portugal or Spain).

It is recommended that any accompanying commercial documentation carries the statement that the product is free from bark (not de-barked).

Associated dunnage (bearers, stickers and spacers) of the same type and quality of this bark-free material do not have to be ISPM15 compliant where it is banded together with the sawn timber product.

High priority hardwood and hardwood products imported from the EU for physical checks (including firewood):

• Plant passports will be replaced with import PCs for Castanea (unless free from bark) and Platanus.

Other regulated hardwood and hardwood products imported from the EU (including firewood):

• Wood of Juglans (walnut) and Pterocarya (wingnut).
• There will be a new requirement for PCs from EU countries where Asian longhorn beetle (ALB) and the Red-necked longhorn beetle (RNLB) are present, this will apply to a wide host range of timbers but not to oak:
o For RNLB wood of Prunus will require PCs from Italy and Germany.
o For ALB wood of Acer, Aesculus, Alnus, Betula, Carpinus, Cercidiphyllum, Corylus spp., Fagus, Fraxinus, Koelreuteria, Medikus, Platanus, Populus, Salix, Tilia and Ulmus will require PCs from Italy, Germany, Austria, France, Finland and Switzerland.

Timber importers will be classed as Operators

As the UK will no longer be in a custom union with the EU, this means timber importers bringing wood in from EU countries will become ‘Operators’ (instead of their current status as ‘Traders’).

Importers and exporters will both need to ensure they have appropriate documentation to meet their obligations under UKTR.

These changes will encompass the vast majority of Timber Trade Federation members and those builders’ merchant chains who conduct their own timber importing activities, having an immediate impact on their due diligence procedures.

Under UKTR, Operators must collect and demonstrate much more detailed due diligence procedures. They are obliged to ensure there is ‘negligible risk’ of illegally- harvested timber entering their supply chains.

In the case of Timber Trade Federation members, under the TTF’s Responsible Purchasing Policy, Operators must also submit their due diligence actions to independent third-party audit, ensuring that customers can continue to buy ‘Timber you can Trust’.

If the timber has a Convention on International Trade in Endangered Species (CITES) import permit, the UK will recognise it as legally harvested. You will not need to carry out due diligence on this timber.

How the UK Global Tariff (UKGT) will affect timber importers

The UK will replace the EU’s Common External Tariff on 1 January 2021 at the end of the transition period with the UK Global Tariff (UKGT). The new tariff will be in pounds (£), not euros.

The broad aim of the UKGT according to the UK Government is to streamline and simplify nearly 6,000 tariff lines. These changes include scrapping unnecessary tariff variations, rounding tariffs down to standardised percentages, and eliminating tariffs below 2%.

It is important to know the specific Commodity Codes for the products you are importing. For timber importers, wood and wood products are contained within Chapter 44 of the Integrated Tariff of the UK.

Commodity Codes will help alert you to any Duty or VAT to pay on the good during import, relief available, or any restrictions on import or export. You can find out more by checking out our page on Commodity Codes.

Apply for a grant for UK Customs Academy courses

To help prepare the UK for new customs procedures, the Government has made available £50mn in government grant funding to cover the costs of any of the courses provided by the UK Customs Academy.

We encourage our members to apply for the grant and ensure any staff members who will be responsible for completing customs entry are supported to gain these qualifications. More information on applying for the grant, as well as details about courses, can be found on the UK Customs Academy website.

What is currently required by law?

Businesses currently trading timber or timber products already placed on the EU, EEA or UK market, are required to have basic traceability information on supplier and seller and keep these records for at least five years. These businesses are known as Traders.

Businesses placing timber from non-EU/EEA countries and domestic (UK) forests on the UK market are obliged to exercise Due Diligence (DD) to ensure the risks of illegally harvested timber enter the product supply chain is negligible. These businesses are known as Operators.

The reason many merchants have been able to operate as traders is because the UK is party to EU Timber Regulations (EUTR) and a part of the single economic market. However, this may soon change.

What will change from 1 January 2021

Businesses importing into the UK from the European Economic Area will need to carry out due diligence confirming that the timber product placed on the UK market has been legally harvested to meet the UK Timber Regulations.

This will effectively mean all timber importers in the UK will be classed as Operators, unless special arrangements are made within the context of a Free Trade Agreement between the EU and UK by 1 January 2021.

Currently only around 12% (around 1.23 million cubic metres) of annual imports made by TTF members are from outside of the European Economic Area and subject to due diligence under the EUTR.

Read our UKTR guide on the right hand side to find out what you need to do to be ready for the new regulations, and make sure to download our free Due Diligence Toolkit which will help you undertake and report on Due Diligence.

Getting your due diligence right

The Timber Trade Federation has long been a world leader in responsible sourcing and supply chain management. We were the first timber trade association in the world to introduce a compulsory risk management and verification system – the Responsible Purchasing Policy (RPP) – to keep members and their products in line with the requirements of the EU Timber Regulations and the Construction Products Regulation (CPR).

We strongly advise all timber merchants to get in touch with use to ensure they are prepared to meet all their obligations as operators under the upcoming UK Timber Regulations. Some of the first you should take in preparing for Brexit is to establish your product supply chain risk profile. This should include finding out about your products Country of Harvest, Country of Production/Supply, Species, and Certification Status

It is also important you can identify products and supply chains that carry higher risks, such as products from non-EU forests, or products from countries with high prevalence of illegal logging, or uncertified products. It will be important from 1 January 2021 that you are requesting all the relevant information under the UKTR from your product’s supplier. If you have any questions, contact the Timber Trade Federation for guidance and tools on how to carry out due diligence for your timber products.

Construction Products Regulations

EU Construction Product Regulations (CPR) are designed to harmonize construction product technical standards across EU member states to ensure that construction products sold within the EU meet certain safety and technical standards.

Harmonising these standards has allowed trade barriers between the manufacture and sale of construction products between member states to be reduced, enabling greater inter-country trade.

CE Marking indicates that the manufacturer takes responsibility for the conformity of that product to its declared performance in the standards, as required under the harmonised standards created under CPR.

You can find out more about these regulations in our Trade Hub.

One of the key changes for merchants as a result of Brexit will be that the UK will no longer be a part of these harmonised standards in future, with the UK setting up a parallel system which will mean new Marks and approved bodies.

What will happen to these regulations after Brexit?

All existing European harmonised standards will become UK ‘designated standards’ and immediately following the UK’s exit from the EU, the European harmonised standards and UK designated standards will be identical.

This means that as a UK manufacturer or importer placing CE marked goods for construction on the UK market your business can, in the event of a deal or a no deal scenario, continue to operate legally without significant change.

Members are advised to check with their notified body to confirm they have the necessary arrangements in place.

As a consequence of leaving the EU, there will be longer term changes because the UK will no longer be able to participate in the EU structures developed for implementation of the Construction Products Regulation.

While immediately after leaving the EU, the Construction Products Regulation will become UK law. If “frictionless trade” is to be maintained via Construction Products Regulations, the UK will need to maintain a parallel system.

This will mean that:

• Existing harmonised standards such as – EN.14250 for Trussed Rafters (used to demonstrate conformity with EU essential requirements) will become UK ‘designated standards’, used to demonstrate conformity with UK essential requirements. Immediately following exit these will be identical to EU essential requirements.
• Notified bodies based in the UK will be granted new UK ‘approved body’ status and listed on a new UK database.
• Approved bodies will be able to assess products for the UK market against UK essential requirements. Immediately after exit day in a No Deal scenario, UK requirements will be identical to EU essential requirements.
• A new UK conformity mark is being developed by the UK for manufacturers to affix before placing a product on the UK market.

For UK manufacturers wishing to export and place CE marked goods for construction on the EU market, your business can, in the event of a deal or a no deal scenario, continue to operate legally provided the notified body you are using is registered in an EU member state or has a partnership arrangement with such a body.

How might these regulations change in the longer term?

While in the majority of cases you will still be able to use CE marking if you are selling goods on the UK market after the UK leaves the EU, the Government has indicated CE marking will only be accepted in the UK for a limited time after Brexit.

Notified bodies operating under the CPR and based in the UK will be granted new UK ‘approved body’ status and be listed on a new UK database. Approved bodies will be able to undertake conformity assessment activity for UK designated standards.

Where an approved body has undertaken the assessment, the manufacturer (or their authorised representative) must affix UK marking.

Manufacturers will only be able to continue relying on assessment by a UK-based approved body after the UK leaves the EU if the UK marking has been used. Where certificates have been transferred to an EU-recognised notified body, the CE marking can continue to be used for the UK market.