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Letter of  President of the European Timber Trade Association - FEBO - to the European Parliament
trade associations

20 April 2009

Letter of President of the European Timber Trade Association - FEBO - to the European Parliament

The letter accompanies Febo's statement on the proposal of the Environment Committee for the first reading in the European Parliament on 23rd April 2009 concerning the obligations of operators who place timber and timber products on the European Market.

'Ladies and Gentlemen, Members of the European Parliament!
On 17.10.2008 the EU Commission published a draft regulation whose aim is to forbid imports of timber and timber products from illegally-felled sources into the EU.
The European Timber Trade Association – FEBO – whose membership includes national federations from 12 European states, expressly welcomes this aim and supports the fight against illegal timber felling.
Wood is the only truly sustainable raw material. Wood also absorbs carbon from the air and stores it permanently. A precondition for using wood is that the sustainable management of our forests is guaranteed in the long term. Trading in timber from sustainably managed forests around the world contributes to the preservation of the forests, providing economic benefit to people whose livelihoods depend on them as well as playing a major part in the fight against climate change.
However, the fight against illegal logging should not impede or hinder the trade with legal timber products any more than necessary. The European timber trade, therefore, expects clear goals and transparent, understandable rules from such legislation. The prescribed measures must be practicable and should disadvantage the operator as little as possible.
On the whole, the European Commission’s draft regulation meets these requirements. The planned monitoring and control systems, although involving more bureaucracy and higher costs, do limit the burden. Against this background, the European Timber Trade Association expressly supports this draft regulation.
A series of amendments, however, which significantly alter the original draft and seriously hinder the international trade with timber, were agreed upon in February 2009 by the Environment Committee of the European Parliament.
One example is that all operators are obliged not just to ensure the legal sourcing of their timber products but also that the criteria of sustainability are adhered to, which in its turn means that numerous regulations and international agreements would have to be taken into account. This would lead to legal problems with, for instance, the violation of foreign legislation being penalised by the European authorities.
As enclosure to this letter we have set down our most fundamental misgivings on the Environment Committee’s proposed amendments. Our statement is supported by the European softwood and hardwood importers’ associations – UCBR and UCBD – as well as by the panel products import association, UCIP.
We would be grateful if you would take our position into consideration when making your decision on the regulation.
Yours faithfully,

The President
Franz-Josef Kall