The enforcement of the EU Timber Regulation (EUTR) has evolved in ways that few industry participants might have anticipated when the law first came into force in 2013. By the first half of 2019, authorities across member states had noticeably intensified their scrutiny of timber imports, particularly those originating from regions with well-documented risks of illegal harvesting. What stood out during this period was not simply the number of seizures or administrative penalties issued, but rather the growing sophistication of the methods used by regulators to detect non-compliance. Importers, for their part, were left in no doubt that basic paper trails no longer suffice to satisfy due diligence obligations.
A recurring pattern in these enforcement actions involved tropical hardwoods from Latin America and West Africa. Authorities increasingly expected importers to go beyond supplier declarations and provide independent evidence of legal harvesting. The traditional reliance on invoices, bills of lading, or even third-party certificates was, it seemed, no longer enough when confronted with the complexity of global timber supply chains. And here’s where things get particularly interesting—or troubling, depending on your point of view. The enforcement reports from 2019 revealed a subtle but significant shift: the burden of proof was moving decisively towards demonstrating, through verifiable data, the lawful origin of timber at the point of harvest.
For companies sourcing tropical hardwoods, this change effectively meant integrating new, often unfamiliar data sources into their compliance workflows. OSINFOR’s open logs from Peru, for example, offer detailed records of approved harvesting permits, GPS coordinates of felling locations, and post-harvest inspection outcomes. Similarly, for timber sourced from Ghana, the FLEGT Voluntary Partnership Agreement (VPA) portal provides access to legality licenses that, in theory at least, can be cross-referenced against shipment documents. But making practical use of these tools is rarely straightforward. The data can be fragmented, inconsistently formatted, or simply difficult to align with internal procurement records. Moreover, while such open data sources present an opportunity to bolster due diligence, they also introduce a degree of complexity that many smaller importers are still struggling to manage.
One approach that has gained traction among more compliance-conscious firms is the creation of what might be called a due diligence evidence ledger. This is not merely a folder of PDFs stored on a company server, but a structured repository—sometimes a dedicated database, sometimes a more informal but carefully maintained spreadsheet—that links each import transaction to the underlying documentation and data supporting its legality. The core idea is to connect supplier invoices with harvesting permits and GPS data in a way that can be easily audited, whether by internal compliance teams or external regulators. In practice, this means ensuring that each load of timber is traceable back to a specific harvesting site, with coordinates that match approved logging concessions as recorded in OSINFOR or FLEGT systems.
Of course, assembling such an evidence ledger is not without its challenges. The data itself can be messy. GPS coordinates might be provided in different formats, or they might not match perfectly with mapped concession boundaries due to technical errors or, less charitably, deliberate obfuscation. There can be discrepancies between declared species and the actual timber loaded, or between the volumes authorized for harvest and the volumes shipped. These inconsistencies require companies to engage in an almost forensic level of document reconciliation—something that, truthfully, not all firms have the capacity or inclination to undertake with the rigor that regulators increasingly expect.
Still, there’s a certain inevitability to this direction of travel. With each enforcement action publicized, with each seizure or fine levied, the message becomes harder to ignore: due diligence is no longer just about gathering documents, but about actively verifying their authenticity and coherence. And while the tools to do this—open databases, satellite imagery, digital traceability platforms—are improving, they remain uneven in quality and accessibility. This leaves importers in the awkward position of having to fill the gaps themselves, whether through direct engagement with suppliers, commissioning independent audits, or investing in proprietary tracking technologies.
Interestingly, some firms have begun to explore partnerships with NGOs or academic institutions to help interpret and validate the open data on which their compliance now depends. These collaborations can offer fresh perspectives, and sometimes, a level of credibility that purely internal processes struggle to achieve. But they can also introduce delays, additional costs, and, at times, conflicting advice on what constitutes an adequate demonstration of legality. The tension between commercial imperatives and regulatory expectations is, if anything, becoming more pronounced.
In the midst of all this, one is left to wonder whether the EUTR enforcement trends seen in 2019 mark the beginning of a broader redefinition of supply chain transparency in the timber sector. The push towards evidence-led due diligence, supported by open-source data and digital verification, seems likely to continue. But what remains uncertain is how uniformly this will be applied across the EU, or how effectively smaller operators will be able to keep pace with the demands of this new compliance environment.