Illegal logging
The Timber Regulation (2/3)
In order to make the import prohibition of Article 4 operational, Regulation 995/2010 did not introduce a general requirement of an export licence of the country where the timber had been harvested; the experience with FLEGT export licences were probably considered to be too negative. Instead of that, the Regulation required "operators" (Article 2(c) and Article 2(d) of Regulation 995/2010) 
to exercise "due diligence", when they place timber or timber products on the EU market. "Due diligence" was described, in Article 6, as a system of measures and procedures which allowed tracking the operator's activity and involved the description and name of the product, the country and sub-national region of the harvest and the concession of harvest, the quantity of timber, the name and address of the supplier to the operator as well as the name and address of the trader to whom the timber was supplied and documents which indicate compliance with the applicable national legislation. Furthermore, the operator was required to document risk assessment procedures on the risk of timber stemming from illegal logging; this included an assurance of compliance with the applicable legislation of the country of harvest; such assurance may be given by certification or other third-party-verified schemes as well as information on the practice of illegal harvesting of specific tree species or other illegal harvesting practices. Finally, the operator was to document possible mitigation procedures, in order to reduce the risk of illegal harvesting.
Source: 123RF Stock Photo. Siegfried Kopp
It is not surprising that such a complex system, which asked the operator to create a considerable system of paperwork, required further specifications which the Commission gave in 2012 in Commission Implementing Regulation 607/2012. It asked operators to store the documentation for possible checks by the competent authorities of the EU Member States for five years. These competent authorities were also asked to check the operators at regular intervals as to their compliance with the due diligence requirements of the Regulation, and also to control whether the monitoring organisations were fulfilling their functions.