The 2021 enforcement report on the EU Timber Regulation (EUTR), published eight years after the regulation’s entry into force, offers a telling snapshot of both progress and persistent gaps in Europe’s efforts to curb illegal timber trade. The EUTR, designed to prevent illegally harvested timber and timber products from entering the EU market, was lauded at its inception as a major step towards sustainable supply chains. Yet the enforcement data, particularly concerning hardwood imports, paints a picture that is more mixed than policymakers might have hoped.
In the report, national competent authorities detailed thousands of checks on operators across member states. What emerges is a pattern of compliance in name, but often not in substance. Among the most common deficiencies highlighted were inadequate risk assessment procedures, superficial due diligence documentation, and in certain cases, outright failure to request verifiable information from upstream suppliers. The hardwood sector, with its complex, multi-jurisdictional supply chains, was repeatedly cited as an area of concern. Importers of tropical hardwoods—used extensively in furniture manufacturing—appeared especially prone to gaps, whether through incomplete documentation or reliance on unverifiable assurances from intermediaries.
For furniture retailers importing hardwood, this enforcement snapshot should serve as a wake-up call. The era in which firms could lean heavily on supplier declarations without rigorous third-party verification is, if not entirely over, at least under growing scrutiny. Competent authorities have made it clear, albeit sometimes in cautiously worded statements, that reliance on paper assurances without meaningful verification will no longer suffice in demonstrating compliance with EUTR obligations.
It’s in this context that open data resources like the Forest Stewardship Council’s (FSC) audit database become invaluable. The FSC, as most in the sector will know, operates one of the most widely recognised certification systems for sustainable forestry. Its open audit records provide an accessible, verifiable trail of certification assessments, non-compliance findings, and corrective actions. Furniture retailers who have not yet integrated FSC audit data into their timber sourcing protocols may want to reconsider. The data offers more than just a certificate number or logo. It enables importers to cross-check supplier claims against independently audited outcomes—something that national enforcement agencies are increasingly expecting to see as part of operator due diligence systems.
Of course, adopting such data resources requires more than an ad hoc review of certificates at the point of purchase. Firms should aim to build reconciliation checks directly into their enterprise resource planning (ERP) systems—particularly those modules handling procurement and supplier onboarding. It sounds straightforward, but in practice, the integration of EUTR compliance into ERP systems can be anything but. Legacy procurement platforms may not have fields designed to capture or flag third-party audit data. Customisation, or in some cases significant reengineering, may be necessary to embed reconciliation logic that compares supplier timber origin claims with FSC audit records or other verifiable data points.
The key is to design ERP workflows that don’t just capture documentation passively, but actively interrogate it. For instance, when a procurement manager enters a purchase order for a hardwood input, the ERP system should prompt a reconciliation check: is there a valid FSC audit on record for this supplier? Does the audit cover the relevant species and jurisdiction? Has the audit flagged any non-conformance that would raise a red flag for EUTR purposes? These are the sorts of practical checks that, when built into routine procurement operations, can help retailers demonstrate to enforcement authorities that their due diligence is more than box-ticking.
Interestingly, the 2021 report also alludes—though not always with full clarity—to possible future directions for EUTR enforcement. Several member states are reportedly piloting or planning to pilot digital timber traceability platforms, which would require operators to input supply chain data into shared government-industry systems. While details remain sparse, the implication is clear: the trend is towards greater digital transparency and fewer opportunities for opacity or plausible deniability in timber supply chains. Retailers who move early to digitise and integrate their own due diligence procedures are likely to find themselves ahead of the regulatory curve when these platforms come online.
That said, it would be a mistake to assume that technology alone will solve the compliance challenge. The enforcement report underscores that many instances of non-compliance were not due to an absence of systems, but rather a failure of firms to use those systems meaningfully. Operators maintained due diligence files, but these files were often incomplete, outdated, or insufficiently detailed to substantiate low-risk claims. In that sense, the heart of the matter remains organisational culture as much as systems design. Retailers must foster internal practices that value substantive due diligence—not as a regulatory burden, but as an integral part of responsible business conduct.
What may complicate matters further is the unevenness of enforcement across member states. Some authorities are well resourced and proactive; others have struggled with staffing, expertise, or political will. This inconsistency can create a temptation for operators to calibrate compliance efforts to the most lenient jurisdiction. It’s a temptation that firms would do well to resist. The European Commission has signalled, in multiple forums, its intention to push for more harmonised and rigorous enforcement. And as consumer awareness of deforestation-linked imports grows, reputational risks are coming to match, or even exceed, regulatory ones.
The 2021 enforcement data should not be seen merely as a backward-looking assessment. It offers a window onto the pressures and priorities shaping the next phase of timber supply chain governance in the EU. Retailers who treat it as such, and act accordingly, are likely to find themselves better prepared for what comes next—whatever form that may take.