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Report on Regulation (EU) No 995/2010 of the European Parliament and of the Council of 20 October 2010 laying down the obligations of operators who place timber and timber products on the market as assimilated and amended in UK law.

Reporting period: 1 April 2022 to 31 March 2025.

Introduction

1. Prior to exiting the EU, the UK enforced the adopted Regulation (EU) No 995/2010 of the European Parliament and of the Council of 20 October 2010 (EUTR) in the United Kingdom. On 31 December 2020, the United Kingdom retained this law in our domestic law. Currently, the EUTR applies in Northern Ireland under Annex II of the Windsor Framework.

2. This is the second report produced by the government on the application of Regulation (EU) No 995/2010, as assimilated and amended in UK law, since the UK left the EU. Hereafter this is known as the ‘timber regulation’, for England, Wales and Scotland. The report has been produced in accordance with Article 20(1) of the Regulation.

3. The timber regulation prohibits the placing of illegally harvested timber and timber products on the GB market and requires operators, those first placing such products on the market, to exercise due diligence. Illegally harvested timber is timber harvested in contravention of the applicable legislation in the country of harvest. Traders, those who trade in timber and timber products after they have been placed on the market, are required to keep records of who they buy timber products from and any traders they sell them to. This enables timber and timber products to be traced.

4. The timber regulation arose from the 2003 Forest Law Enforcement, Governance and Trade (FLEGT) Action Plan, a European Union (EU) initiative aimed at tackling illegal logging by ensuring that imports of timber into the EU are from legal sources.

5. The Report is based on data for the period 1 April 2022 to 31 March 2025 provided to the Department for Environment, Food and Rural Affairs by The Office for Products, Safety and Standards (OPSS).ÌýOPSS enforce the timber regulation on behalf of the Secretary of State, who is the Competent Authority under The Timber and Timber Products (Placing on the Market) Regulations 2013.ÌýOPSS report on penalties in place, checks on operators and traders and enforcement action.

Enforcement of the timber regulation - requirements of operators, traders and monitoring organisations

6. The requirements on operators, those first placing timber or timber products on the market, are set out in Article 4 of the timber regulation. The requirements on monitoring organisations, who grant operators the use of a due diligence system, are set out in Article 8 of the timber regulation. The requirements on traders, those who buy and sell timber after it has been places on the market, are set out in Article 5  of the timber regulation. The requirements are summarised below:

• Operators are prohibited from placing illegally harvested timber on the market.
• Operators shall exercise due diligence when placing timber or timber products on the market using a framework of procedures and measures, referred to as a ‘due diligence system’ (as set out in Article 6 of the timber regulation).
• Operators must maintain and regularly evaluate due diligence systems except where the operator makes use of a due diligence system established by a monitoring organisation referred to in Article 8, a separate organisation who are able to grant operators the use of a due diligence system.
• Monitoring organisations must maintain and regularly evaluate a due diligence system and grant operators the right to use it. They must also verify the proper use of its due diligence system by such operators and take appropriate action in the event of failure by an operator to properly use its due diligence system, including notification of the competent authority in the event of significant or repeated failure by the operator.
• Traders must be able to identify the operators or the traders who have supplied the timber and timber products and, where applicable, the traders to whom they have supplied timber and timber products. Traders must keep this information for at least five years and provide that information to enforcement officers on request.

Checks on operators

7. The timber regulation sets out the requirements for checks on Operators in Article 10. As the enforcement delivery partner, OPSS must check that Operators are exercising due diligence when placing timber or timber products on the market and using a due diligence system.

8. The checks should be conducted as part of a periodically reviewed plan following a risk-based approach. Checks may also be conducted when relevant information concerning compliance comes to light including substantiated concerns provided by third parties. Checks may include:

• examination of the due diligence system, including risk assessment and risk mitigation procedures
• examination of documentation and records that demonstrate the proper functioning of the due diligence system and procedures
• spot checks, including field audits

9. Where shortcomings have been detected, OPSS may issue a notice of remedial actions to be taken by the operator and may also take immediate interim measures, including:

• seizure of timber and timber products
• prohibition of marketing of timber and timber products

Checks on Monitoring Organisations

10. Article 6 of the Commission Implementing Regulation (EU) No 607/2012 as assimilated and amended in UK law sets out the frequency and nature of the checks on monitoring organisations as provided for in the timber regulation. Checks must be carried out at regular intervals to verify that the monitoring organisations continue to fulfil the functions set out in the timber regulation. Checks are also carried out:

• where shortcomings in the effectiveness or implementation by operators of the due diligence system established by a monitoring organisation have been detected
• where a monitoring organisation has undergone subsequent changes since they have been recognised as a monitoring organisation

11. Such checks include spot checks including:

• field audits
• examination of documentation and records of monitoring organisations
• interviews with the management and staff of the monitoring organisation
• interviews with operators and traders or any other relevant person
• examination of documentation and records of operators – and examination of samples of the supply of operators using the due diligence system of the monitoring organisation concerned - regular checks must be carried out every 2 years

12. The monitoring organisations active in the United Kingdom are Soil Association, Preferred by Nature, Control Union (UK) Ltd, BM Certification and Envirosense.

Access to premises and documents

13.ÌýOPSS enforcement officers require a warrant and access to operators’, traders’ and monitoring organisations’ premises, documentation and records in order to perform these checks. In certain situations, enforcement officers can gain access without advance notice where it can be shown that giving notice would impede the investigation.

Record of checks

14. Keeping records of checks is necessary for carrying out effective inspections and enforcement activities and facilitates planning and reporting. These records also allow the general public access to environmental information upon request. Data related to checks under the timber regulations and kept in the records is considered environmental information. As a rule, access to environmental information needs to be granted to anyone who requests it, unless this information falls under one of the exceptions to this rule, such as confidentiality of proceedings protected by law, ongoing proceedings, commercial information and personal data.

15.ÌýOPSS record the name and address of the company, the reasons for the check (risks identified in check plan, substantiated concern) and the nature of the check (whether it is desk-based on-site, or joint inspections) unless otherwise stated. This information is only partially made available upon request. Similarly, concerns, infringements identified, and enforcement activities are only partially made available to the public.

16. The names and addresses of the supplier companies (applies to operators and traders) and the names and addresses of buyer companies (applies to operators and traders) are restricted. The names and addresses of operators using monitoring organisation services are not retained. Records of checks on monitoring organisations are kept but not made available.

Risk-based approach

17.ÌýOPSS adopt a risk-based approach for planning checks on operators, targeting operators that meet one or more risk criteria. Those operators are considered at risk of breaching the timber regulation. This risk-based approach allows OPSSÌý²¹²Ô»å Defra to take effective measures to prevent illegal timber being placed on the market and if necessary, to impose effective, dissuasive and proportionate penalties.

18.ÌýOPSS rely on a referral from Forestry Commission officials to enforce the timber regulation in relation to domestic timber or timber products. For imported timber, the criteria they use to target specific imports are:

• type of timber products – for example, composite wood
• country of harvest – for example, countries with high corruption, internal armed conflicts, track record of illegal logging, export bans
• area or region of harvest – for example areas or regions with high corruption, internal armed conflicts, a track record of illegal logging
• timber types – for example, tropical, broad leaf or species such as teak
• complexity or type of supply chains - for example, trade involving transit or processing countries
• high value of timber and timber products placed on the market

19. Having identified imports which meet the criteria above, OPSS prioritise which operators to check using the following criteria:

• checks carried over from the previous reporting period which have not yet been actioned
• substantiated concerns from non-governmental organisations (NGOs)
• specific risk criteria ranking higher than others and
• previous compliance levels

20. The risk criteria, risk level and prioritisation of risk are re-assessed when new relevant information becomes available.

Resources

21. Having sufficient resource to perform enforcement activities is key to ensuring the application of the timber regulation, the reduction of illegally harvested timber or derived products being placed on the market, and the improvement of traceability of timber throughout the supply chain.

22. Enforcement costs for OPSS’ role in enforcing UKTR and FLEGT regulations during this reporting period are provided in the table below:

	2022 to 2023	2023 to 2024	2024 to 2025
Staff (Full-time equivalents)	9	3.1	6.4
Total costs	£650,000	£650,000	£650,000

Costs include staff-related spend, and direct spend on workshops, domestic engagement costs, sample analysis, and World Forest ID reporting.

Voluntary Partnership Agreements

23. A Voluntary Partnership Agreement (VPA) is a bilateral agreement between a timber-producing country and the UK. VPAs are a key element of the FLEGT Action Plan published in 2003. The Action Plan aims to reduce illegal logging by strengthening the sustainability and legality of forest management, improving forest governance and promoting trade in legally produced timber. The UK signed a VPA with Indonesia on 29 March 2019 and expects to replicate other EU VPAs. In the EU, the first VPA to be signed was with Ghana, followed by the Republic of Congo, Cameroon, Indonesia, the Central African Republic, Liberia, Vietnam, Honduras, Guyana and Côte d’Ivoire. Negotiations are ongoing with Democratic Republic of Congo, Gabon, Laos, Malaysia and Thailand.

24. VPAs include commitments and action from both parties to halt trade in illegal timber. Producer countries issue FLEGT licences that certify the legality of timber exported to the UK. To issue FLEGT licences, a VPA partner country must implement a timber legality assurance system (TLAS) and other measures specified in the VPA. When fully operational a TLAS includes effective supply chain controls, mechanisms for verifying compliance and is subject to independent audits. A VPA TLAS is built around a practical definition of legality that has been agreed through participatory processes involving stakeholders from government, the private sector and civil society. The VPA also promotes better enforcement of forest law and an inclusive approach involving civil society and the private sector.

25. It is important to gather information on whether the VPA processes are having a beneficial effect on the implementation and enforcement of the timber regulation and whether there is evidence that illegal trade from those countries is reducing, which is indicated by the reduction of the perceived risk of illegally harvested timber and derived products originating in these countries over time. The impact of VPAs is considered further in the FLEGT 2024 to 2025 annual report.ÌýÌý

Risk status

26. Risk status assignment is based on publicly available information such as the Corruption Perception Index (CPI) and reports by NGOs such as World Forest ID & Preferred by Nature and is only valid at a specific point in time. For enforcement investigations, this will be based on the point of time that an import entered the UK.

In some cases, although OPSS assign a risk status that applies to a whole country, a specific due diligence investigation may need to investigate the risk at a lower level as, for example, different areas of the same country may present different risk levels ranging from low to high.  

27. In terms of using risk to identify specific timber imports to target, this is based on the same publicly available information and is subject to change depending on events, for example, the conflict in Ukraine and Russia.

Checks on operators placing imported timber on the market

28. Checks completed (meaning number of due diligence systems reviewed):

• 2022 to 2023: 36
• 2023 to 2024: 30
• 2024 to 2025: 43

29. Checks were mainly desk-based with 2 checks including scientific testing.

Countries of origin

30. Operators had imported from the following countries:

• 2022 to 2023 – Myanmar, China, Latvia, Estonia, Lithuania, Russia, Solomon Islands, and Papua New Guinea
• 2023 to 2024 – Vietnam and China
• 2024 to 2025 – Vietnam, China, Turkey, Italy, Spain, and Rusia

Restriction on activities

31. During the reporting period OPSS did not encounter any issues with undertaking checks on all the operators they had initially planned to.

Records

32.ÌýOPSS recorded the declared country, country of harvest, origin of the timber or timber products, type of timber and timber products (HS Code and denomination)

Products

33. The following HS Codes were subject to checks during the reporting period and were the focus of the project and risk-based approach OPSS used:

HS Code	Details
9403	Wooden furniture.
4412	Plywood, veneered panels and similar laminated wood.
4401	Fuel wood, in logs, in billets, in twigs, in faggots or in similar forms; wood in chips or particles; sawdust and wood waste and scrap, whether or not agglomerated in logs, briquettes, pellets or similar forms.
4408	Sheets for veneering (including those obtained by slicing laminated wood), for plywood or for other similar laminated wood and other wood, sawn lengthwise, sliced or peeled, whether or not planed, sanded, spliced or end-jointed, of a thickness not exceeding 6mm.

Remedial action

34. Effective enforcement of the timber regulation requires a robust framework of measures to be able to take effective, dissuasive and proportionate enforcement action. This includes sanctioning operators, traders and monitoring organisations for not meeting their obligations as laid out in the legislation.

35.ÌýOPSS may issue a notice of remedial action for breach of the obligation to exercise due diligence or for breach of the obligation to maintain and evaluate a due diligence system. On receipt of a notice of remedial action, the operator must act within the timeframe specified. Failure to comply with the notice is an offence, the maximum penalty for which is an unlimited fine on summary conviction.

Penalties

36. A breach of the prohibition on placing illegally harvested timber on the market may result in an unlimited fine, a term of imprisonment and/or seizure of the timber or timber products by an inspector. If timber or timber products are seized, the Secretary of State may order their destruction, donation, sale or disposal, or direct the person who the seizure notice was served on to destroy or dispose of the timber or timber products.  A breach of the obligation to exercise due diligence or the obligation to maintain and evaluate a due diligence system may result in an unlimited fine or term of imprisonment. A breach of the traceability obligation, a breach of the record keeping obligation, obstruction of an inspector or failure to comply with a notice of remedial action may result in an unlimited fine.

37.ÌýOPSS set out their approach to dealing with non-compliance and resolving potential product safety issues in their enforcement policy. This policy details their approach to publishing information about enforcement actions. Data on which companies or online retailers have had remedial actions taken against them and why can be accessed on their website.

39. The details that OPSS publish include:

• company
• action taken and under which regulation
• when the action was issued
• product details
• how the regulations were breached

40. The table below outlines the enforcement actions undertaken by OPSS between 1 April 2022 to 31 March 2025:

	2022 to 2023	2023 to 2024	2024 to 2025
Investigations with new companies initiated	36	30	43
Prosecution under UKTR	0	0	1
Notices of Remedial Action issued	8	7	10
Informal advice and guidance letters issued	9	7	21
Seizure notice issued	0	0	1

Notable enforcement actions – 2022 to 2025

41. Sunseeker International Limited

In November 2024, an OPSS investigation concluded in a successful prosecution against Sunseeker International Limited, who have pleaded guilty to 11 imports of teak from Myanmar, which is a high-risk country. Sunseeker International Limited appeared before Bournemouth Crown Court on 25 November 2024 and received the following sentence: 

• Fine: £240,000
• Confiscation order: £66,950.64
• Costs: £51,619
• Victim surcharge of £190

42. IKEA Supply AG

A case involving IKEA Supply AG, who self-reported non-compliance in their supply chain, was finalised with seizure of 26,767 items of furniture under the timber regulation. A decision was made to have the furniture donated under the regulations. This was the first occasion OPSS issued a Seizure Notice for UKTR. On 4 September 2024, IKEA Supply AG confirmed that the furniture was donated to the charity Nadiya, a Ukraine based charity which has the purpose of assisting Ukrainian people affected by the war. This was a complex and successful seizure and application of the legislation which included donation.

43. OPSS commissioned a Senior Economic Analyst in 2023/24 to assess the size of the UK timber import market to see if trends could be identified to inform enforcement work. This has resulted in furniture imports from China being targeted in the first half of this year.

Collaboration

44. During the reporting period, OPSS strengthened national and international collaboration on timber regulation enforcement by co-hosting and participating in key global forums, including the Timber Regulation Enforcement Exchange (TREE) meetings, Interpol-led events, and the Vietnam Forests meeting, fostering intelligence sharing and joint action on illegal timber trade.

45. Regular engagement with Kew Gardens supported the World Forest ID (WFID) programme, focusing on high-risk species such as Red Cedar, Teak and mislabelled Russian timber. OPSS and Kew Gardens colleagues worked closely to develop a leaflet on wood identification for distribution for Operators.

46. OPSS maintained strong industry outreach through recurring presentations at the Timber Development UK (TDUK) events and attendance at trade shows such as the Telford Furniture Show, distributing materials in partnership with Kew Gardens and providing updates on UKTR, enforcement priorities, certification, and best practice guidance. These activities helped build stakeholder awareness, address market challenges, and support compliance efforts across the timber supply chain.

Raising awareness and building capacity

47. For the timber regulation to be effective, stakeholders need to be aware of how operators, traders, and monitoring organisations, as well as those involved in compliance verification and enforcement, operate. In addition, civil society, particularly consumers, should be made aware of the risk of illegally harvested timber or timber products being placed on the market and of the measures taken to address this issue. Successful dissemination of this information depends on the type of information campaign and the willingness of the audience to engage. OPSS devised a communication strategy to raise awareness of changes to the timber regulation in the lead up to the UK’s exit from the EU. As a result of Russia’s invasion of Ukraine, guidance has been provided to trade associations and monitoring organisations which addresses the issues raised by the events in Ukraine, Russia, and Belarus.

48.ÌýOPSS use various methods of engaging with stakeholders including hosting Timber Expert Panel (TEP) meetings, attending TREE meetings and presenting at virtual events hosted by other organisations. Topics covered during TEP meetings in the reporting period included timber imports from Ukraine, sanctions on Russian timber, challenges in low-risk countries and the introduction of the EU Deforestation Regulation (EUDR). Panels featured presentations from Kew Gardens, the Zoological Society of London, and Defra, and were attended by trade associations, retailers and consultants.

49. OPSS also engage with trade associations to pass information to their members on relevant issues relating to compliance. OPSSÌý²¹²Ô»å the Department for Environment, Food and Rural Affairs (Defra) have also responded to questions from individual businesses concerning various issues, including changes in the obligations of businesses following the UK’s exit from the EU, importing Teak from Myanmar and importing timber from Ukraine, Russia, and Belarus and the EU’s Deforestation Regulation which will apply in the EU from December 2025.

50. During the reporting period OPSS ran multiple workshops in order to improve compliance across the Timber Industry and sector. Two workshops on Due Diligence were delivered to the Fuelwood sector in conjunction with Soil Association and Woodsure. OPSS delivered further targeted workshops focused on countries at risk, legal considerations and document requirements in low-risk countries. A review of feedback forms indicated that these workshops were successful and well-received.

51. Throughout the period, OPSS maintained frequent communication with industry partners, government departments, and certification services, reinforcing positive relationships and building industry capacity to meet regulatory obligations.

Conclusion

52. The primary objectives of the timber regulation are to tackle illegal logging and to create a demand for legally harvested timber. Illegal logging is a major driver of deforestation, leading to loss of ecosystem services and biodiversity, and contributing to climate change. It also affects rural communities that rely on forests for livelihoods, and results in revenue loss to government and legitimate business.

53. By imposing greater responsibility on those placing timber and timber products on the UK market for the first time, the regulations lead to the consolidation of legal practices in the timber sector. The requirements applied to those placing timber on the UK market for the first time have implications on the entire timber supply chain, driving the adoption of similar approaches in source countries. Implementing the Regulations enables the protection of forests around the world, ultimately supporting the government’s ambition to lead the world in environmental protection, end extreme poverty, and be at the forefront of action against global climate change.

54. Implementation of the UK timber regulation has been satisfactory over the reporting period. OPSS have engaged effectively with the sector, both individually and collectively, including through provision of updated guidance on the ongoing situation in Russia and Ukraine. OPSS have carried out checks on businesses, as well as proportional and measured enforcement action where appropriate, in line with the regulators code.

55. The recent post implementation review on the UK Timber Regulation published in March 2025 provides further information on the implementation of the Regulation and identified the need for increased outreach to enhance compliance. Defra and OPSS will consider appropriate next steps to address this.