TTF Q&A Page

This page has the answers to the questions that are sent and asked by TTF members during our monthly TTF Q&A Clinic. Here you will find frequently asked questions about preservative treatment, UKTR, due diligence, UKCA marking, Code for Construction Products Information and much more. We will keep adding to this page after every session of our monthly clinic.

 

The next TTF Q&A Clinic is on Monday 26 July, 12:30

Register: https://zoom.us/meeting/register/tJIqce2vqDIuHtV_4E0TJvLRzS50SyFOFfV2

UKCA/CE marking

Q: How do we apply for UK CA marking on plywood from Malaysia?

 

Assuming the supplier already has CE marking in place and FPC Certification provided by an EU Notified Body then the two options to achieve UKCA marking are:

 

Engage with a UK Approved Body directly and have two separate factory production -controlled (FPC) systems and two different sets of auditing,

OR;

Speak to their existing EU Notified Body to ask them to sign a subcontract with a UK Approved Body to audit two (FPC) identical systems which are currently identical.

 

Q: Are my CE marked products still valid for sales in the UK?

 

Yes, they are. The UK Government are saying that CE marked products can be placed on the UK market until up until the end of the year, and once placed on the market they are fully compliant until finally sold and used.

 

Q: What are UKCA marked products?

 

The UK is developing its own system to show products are compliant with UK safety rules. The UKCA mark is the badge to show this compliance. The system is based on EU CE marking and so currently the requirements are identical with the UK adopting the EU harmonised standards as UK Designated standards.

UK Timber Regulations (UKTR)

Q: What are the UKTR compliance requirements for importing from Ukraine?

 

EU common position paper on Ukraine was released on Dec 2020 with a list of risk areas and mitigation measures that need to be taken into account during due diligence. Robust mitigation measures must be proved to be in place before importing. For more info and recommended mitigation measures: https://ttf.co.uk/updating-members-of-countries-becoming-at-risk-ukraine/

 

Q: What degree of supply chain transparency ought to be made available to customers in Northern Ireland in relation to EUTR?

 

OPSS will be enforcing both UKTR in GB and EUTR in NI, so similar requirement / standard of due diligence are expected. Supply chain transparency will depend on risk levels, e.g. when sourcing from a high risk (high level of illegal logging) country, mapping back to the forest/concession level will be excepted; whereas for a low-risk product, mapping back to the country of harvest may be sufficient. For more info: https://ttf.co.uk/webinars/brexit-uktr-webinar-qa-with-opss/

 

Q: Where to get the list of countries being sanctioned under EUTR/UKTR? How to know which countries are high risk and should avoid sourcing from?

 

EU/UK joint enforcement position is in place on Myanmar (no import allowed). There is also an EU enforcement position on Brazil and Ukraine (a strict set of risk assessment and mitigation measures are required). For more info: https://ttf.co.uk/webinars/brexit-uktr-webinar-qa-with-opss/

Preservative Treatment

Q: Why is it that treatment plants are allowed to continuing to treat imported unseasoned German spruce sleepers to UC3?

 

Commercially no one can ban what treatment plants accept for treatment, particularly because the situation with the treatment of spruce is not black and white. Only goods which are at a suitable moisture content should be put into the treatment plant, and every plant should be checking that as part of the pre process inspection checks. The information in BS.8417 suggests in most cases wood should be treated at a moisture content below 30%.

 

To me at the present time with the lack of wood available to the UK it seems counterproductive to be producing external timbers to only UC3 as there are limited uses in out of ground contact applications. Surely it must add more value and from a stock point of view be more sensible to get that wood to a suitable condition where it can be incised so it can achieve UC4.

 

Q: Is it acceptable to sell Scandinavian or Baltic KD C24 whitewood treated to a UC3 cycle as UC3?

 

This is rather like asking if its ok to sell C24 stamped wood without having any real evidence that it had been correctly graded.

 

As I said in the presentation the third stand of the TTF Action Plan is about each treatment plant having the accreditation and audit procedures in place. This will give treaters the confidence that the product quality in terms of the penetration and retention levels given in BS.8417 are being achieved within the acceptable limits on an ongoing basis. Remember, June 2022 is the end date for getting auditing in place. Advice from the TTF / WPA is to get that process started as soon as possible so you know where you stand.

 

We also simply cannot make generalisations about the treatment of whitewood. We know it is resistant to treatment, but there are differences between the species within this group. Sitka does not necessarily give the same results as European Spruce. Kiln drying is useful to get the MC down but in the process of ensuring everything is below 18% we see a lot of material at 12-14% which probably means the structure has closed up, and there is little chance of penetration. There will also be differences depending on the finish. Sawn will always allow greater penetration than PAR particularly if it’s a “glass” like finish.

 

Q: Why is it that the UK timber trade continues to pressure treat unseasoned timber with a FSP way over 30%?

 

We simply cannot make generalisations about the treatment of whitewood. The UK production sector probably has more experience in applying preservative treatment to Sikta Spruce than anyone else in the world. Where they are treating at moisture levels over 30% then that will be because the process audits they have in place are providing them with the confidence that is an appropriate moisture content for the products they are manufacturing, given the resource they are using.

Rules of Origin

Q: I thought the UK/EU trade deal meant that all products exported to EU would be duty free?

 

No, only those that meet the “rules of Origin” set out in the deal.

  • Grown or harvested in the UK
  • Manufactured in the UK
  • Imported but significantly processed in the UK

 

 Q: Why am I being charged 7% duty on the Russian Birch Plywood I am sending to Northern Ireland as we are in the same country?

 

Yes, we are all in the United Kingdom but to prevent a hard border with border controls across the Ireland of Ireland, it is thought necessary to have controls on goods moving from GB to Northern Ireland.

 

When moving stock to NI, you will need to make declarations and pay any tariffs due when bringing goods into Northern Ireland from Great Britain or from countries outside of the EU and the UK: https://www.gov.uk/guidance/check-if-you-can-declare-goods-you-bring-into-northern-ireland-not-at-risk-of-moving-to-the-eu

 

Goods which enter Northern Ireland from countries outside of both the EU and UK, where the applicable EU duty is greater than the applicable UK duty by 3 percentage points or more, cannot be declared ‘not at risk’ and are therefore automatically ‘at risk’.

 

For more info:  https://www.gov.uk/guidance/trading-and-moving-goods-in-and-out-of-northern-ireland#overview

Plant Health

Q: Can Pinus Caribaea still be shipped to the UK? Is phytosanitary needed in Honduras for kiln dried clear soft wood lumber?

 

TTF have a new Plant Health page for members which can be found here https://ttf.co.uk/trade/brexit-plant-health/ As part of the BREXIT process the UK has developed its own Plant Health regulations. Schedule 7  lists the Phytosanitary measures which need to be applied to specific species or groups of species form defined countries or regions.  In this case (Pinus Caribaea), item 113 is the critical measure.

 

Q: What is an export phytosanitary certificate (PC)?

 

This is document issued by the UK authorities to confirm the goods meet the import requirements of the country you are sending the goods to. Forestry Commission are the UK authority

 

Q: When will I need an export phytosanitary certificate?

 

Rule of thumb if you needed a PC to bring the wood into the UK then you will probably need one to export it. Different species potentially carry different pests so for more detail you need to look at the different clauses in schedule 7 of the EU plant health regulation. See my blog for a summary and links.

 

Q: What is the UK requirement on ensuring zero pests and diseases for pallets and imported wood products?

 

Wood Packaging material (WPM) such as pallets associated with ANY product imported into the UK are required to meet the very specific requirements of ISPM 15 (International Standards for Phytosanitary Measures no 15) to ensure that such packaging is free of pests and diseases which could damage UK woodlands and forests. See https://www.gov.uk/wood-packaging-import-export or the Wood Packaging Material section on the TTF Plant Health page https://ttf.co.uk/trade/brexit-plant-health/

 

In this case it is the importer of the Indian paving flagstones who is responsible to ensure such packaging carries the correct ISPM 15 mark on each pallet or crate and in theory risk based checks at UK ports should be in place to ensure this requirement is being met as failure to do so is a legal offence. If you are the Importer then you should ensure that your purchase contracts always include the requirement for all packaging to meet ISPM15 otherwise there is a risk future shipment may be ceased and you may be liable for significant additional costs. If these goods are being purchased from a UK importer then please pass on this information as we must all act together to help keep our UK woodlands and forests safe from potential pests and diseases.

 

Q: Can Pinus Caribaea still be shipped to the UK? Is phytosanitary needed in Honduras for kiln dried clear soft wood lumber?

 

TTF have a new Plant Health page for members which can be found here https://ttf.co.uk/trade/brexit-plant-health/ As part of the BREXIT process the UK has developed its own Plant Health regulations. Schedule 7  lists the Phytosanitary measures which need to be applied to specific species or groups of species form defined countries or regions.  In this case (Pinus Caribaea), item 113 is the critical measure.

Click the image for plant health contacts around the world

Dumping

Q: Is Dumping duties still applying to Okoumé plywood originating from China and entering the UK since Brexit happened?

 

As part of the BREXIT process the government undertook a review process of all active Trade measures that the UK was obliged to undertake as part of EU membership. For each measure, a decision was taken whether it was relevant to include as part of future UK Trade Policy or bring the process to a close and terminate the measure on date of exit.

 

These included the current statues of the anti-dumping measures which can be found on the government website : https://www.gov.uk/guidance/trade-remedies-transition-policy#anti-dumping-and-anti-subsidy-trade-remedy-measures

The decision taken regarding the Anti-Dumping trade measures on Okoume plywood from China was that as the UK has no domestic Plywood industry it should be terminated as of 1st Jan 2021. “Okoume plywood , AD471, China, Terminated”

 

Q: The EU will be applying Anti-dumping measures on Russian Birch Plywood from July will the UK be obliged to follow suit?

 

As of 1 January 2021 the UK began operating an independent trade policy and there is no obligation within the UK/EU Trade and Cooperation Agreement which requires the UK to adopt any existing EU trade measures or align with any new EU trade measures which are put in place after this date.

 

An EU investigation into Russian Birch Plywood started in October 2020 but measures have not been put into place until June 2021. Given there is no UK domestic industry to protect there does not seem to be a basis for such a measure and there is no indication the UK will undertake its own investigation or implement similar measures.

 

However, there are implications for moving stock to NI because the government website states: https://www.gov.uk/guidance/trading-and-moving-goods-in-and-out-of-northern-ireland#overview

 

You will need to make declarations and pay any tariffs due when bringing goods into Northern Ireland from Great Britain or from countries outside of the EU and the UK. https://www.gov.uk/guidance/check-if-you-can-declare-goods-you-bring-into-northern-ireland-not-at-risk-of-moving-to-the-eu

 

Goods which enter Northern Ireland from countries outside of both the EU and UK, where the applicable EU duty is greater than the applicable UK duty by 3 percentage points or more, cannot be declared ‘not at risk’ and are therefore automatically ‘at risk’.

FOR MORE INFORMATION VISIT OUR BREXIT PAGE