Sustainable trade requires substantiated reporting from NGOs
2nd October 2020

Sustainable trade requires substantiated reporting from NGOs

Sustainable trade requires substantiated reporting from NGOs


TTF Members may have been made aware of a news article published by the Environmental Investigation Agency stating that the Dutch Competent Authority had ordered a Dutch importer to stop importing Chinese plywood with a “tropical face” and that the company was in breach of the EUTR.

High-profile alerts from NGOs like this are usually picked up by TTF to pass on to members. However, we also like to corroborate the facts within the article. In this case there are several areas causing concern:

  1. The ‘cease and desist’ order claimed in the article is not supported by further explanation and there is not any information released on the decision from the Dutch Competent Authority.
  2. It was not clear from the article the timing of the import made, and what the issues were which led to the violation of the EUTR claimed in the article.
  3. Non-compliance is incorrectly used to refer to the timber product when EUTR is about Due Diligence by the importer. ‘EUTR compliant product’, or ‘non-compliant product’ are misleading terms.


Information such as these points above is crucial in helping businesses review their existing practices to address gaps in the supply chain and should be made accessible to the public. Since it was published, we have contacted the EIA, the Dutch Competent Authority, the company named in the report, Dutch trade associations, and a number of other NGO’s in the industry, but unfortunately to date we have not been able to corroborate the claims made in this article.

To further add to the confusion, the article was revised in the second day of its first release, with its message about the Competent Authority’s decision altered. Original post.

Timber from tropical regions is often considered high risk due to poor governance or law enforcement capacity, and companies conducting Due Diligence need to ensure strong controls in place. However, there are feasible mitigation approaches for businesses to adopt when considering tropical species. For example, using verifiable timber harvested from certified or legally verified forest sources and ensuring measures is in place to eliminate mixing along the supply chain and on the factory floor.

Indeed, the plywood manufacturer named in the EIA report has released its own statement highlighting that all of the tropical material it exports to the EU is from FSC 100% certified concessions and has been increasingly replacing tropical species with temperate timber materials.

Responsible sourcing of timber harvested from legal and responsible tropical sources helps keep forests standing, and we can support this by keeping the trade alive and working with supply chain players to make positive changes on the ground.

Unfortunately, tabloid-style unsubstantiated reporting from NGOs can quickly undermine these efforts.

NGOs have a vital role to play in shaping Due Diligence, helping to highlight potential risks from regions, companies or products, and initiate positive transformations across the industry.

To allow us achieve this, we recommend the following actions for stakeholders involved in this case:

  • For EIA:
    • To provide supporting information on the decision of the Competent Authority
    • To ensure accurate messages in future reporting and avoid use of misleading terms.


  • For Importers in the EU and UK:
    • To ensure information published by NGO is assessed against Due Diligence risk criteria.
    • To check the validity, relevance and accuracy of any input data.
    • To work with supply chain players to identify and address gaps and support continuous improvements wherever possible.


  • For Exporters in China:
    • To improve understanding on the requirement of due diligence when exporting to the EU/UK.
    • To actively seek information about source country risks and illegal logging activities, buying certified or FLEGT licensed where possible.
    • Where possible, to work with trade associations in China to ensure continuous improvement on responsible sourcing and factory control.


The TTF has developed a free Due Diligence Toolkit, including a Case Study on the common Due Diligence gaps which can appear when sourcing from China. Please download HERE.

In addition, the TTF provides a specially designed due diligence system for importers of plywood from China. This system takes additional steps to go above and beyond what is legally required under the EUTR and provide an extra layer of assurance that the products traded by our members qualify as “Timber You Can Trust”. For more information, please ask your TTF supplier or contact our office.