Illegal logging compliance for non-loggers.

If you import paper, tissues, wooden handled brushes, timber furniture, paper bags, cigarette papers or other regulated timber products the due diligence obligations under Australia’s illegal logging laws are likely to apply to you.

Recently the Department of Agriculture and Water Resources (DAWG) sent letters to importers of regulated timber products (identified by HS code) reminding them of their obligations to comply with illegal logging laws. For some, this was less of a timely reminder and more of an alarming announcement.

While there is no ‘quick fix’ for complying with the illegal logging laws, these 5 steps will get your company on track:

  1. Have a written due diligence system setting out how you will carry out due diligence checks, including for new suppliers, existing suppliers and ongoing period checks (the department may ask for a copy of this due diligence system);
  2. Gather supporting information and evidence about the sources of your products from suppliers, online etc to inform your risk assessment (a starting point is sending out a standard supplier questionnaire);
  3. Assess the risk that the products contain illegally logged timber using the Timber Legality Framework, Country Specific Guidelines, undertaking assessment of the regulated risk factors.
  4. Mitigate any risk, if necessary based on your assessment of the risk. This could include independent verification of documents or requesting further information or clarification from suppliers.
  5. Maintain suitable records (for at least 5 years). This should include a record of your risk assessment. If certain information is not ‘reasonably able’ to be obtained you should maintain records of steps you took to try to obtain it.

Get in touch with Bespoke’s Trade, Transport and Regulatory group for further information or assistance with preparing an illegal logging due diligence system, or undertaking risk assessments.

Trade, Transport & Regulatory

Posted on: 7 August 2018