ForestCom Position Document: Strengthening of Transparency in the Ukrainian Timber Supply Chain in relation to the adoption of the new EU Deforestation Regulation (EUDR)

Introduction:

The NGO "Forest Initiatives and Communities" (hereinafter referred to as NGO "ForestCom") acknowledges the severe adverse consequences of illegal logging on the natural environment, economy, and biodiversity. Regulatory changes in the European Union under Regulation (EU) 2023/1115 on deforestation-free and forest degradation-free products (EUDR) and other legislative acts require urgent and effective actions to improve transparency in the timber supply chain in Ukraine.

Key Issues:

Deforestation and Biodiversity: Illegal logging has significant negative impacts on biodiversity, including the disappearance of rare plant species in forest ecosystems.

Forest degradation: Illegal logging does not always lead to deforestation, but it often causes forest degradation. Forest degradation is a serious environmental problem, as it can significantly impact the condition of forest ecosystems, their resilience to climate change, their ability to provide ecosystem services, and resource potential.

Illicit Trade: Non-compliance by Ukrainian exporters with EU Regulation on Deforestation (EUDR) requirements poses risks and threatens the exclusion of products from Ukrainian markets in the EU, even if manufactured from legally harvested timber, causing public outcry and negative economic consequences.

Recommendations by NGO "ForestCom":

1. Amendments to Timber Electronic Accounting System: Include information on the geographic coordinates of logging site edge points and the logging ticket (official permit for logging) number in the existing timber transportation notes/waybills (TTN-forest).

2. Additional Information Submission for Timber Auctions: To ensure transparency of timber origin and provide buyers with timely information, Wood Suppliers (timber sellers) should, before the trade, provide information on the applied logging types used to harvest the selling timber.

3. Information Collection for Verification: National producers of timber products should collect and submit to the EU Operators relevant documentation (electronic copies of contracts, invoices for specific product batches, TTN-forest, logging tickets, conversion coefficients for finished products from a unit of round timber, other relevant documents) for each timber product batch to be sold to the EU market. This is necessary for generating a report on the transparency verification of the timber supply chain and entering it (after key information verification, including geographical coordinates of logging sites) into the EU information system in accordance with EUDR requirements.

4. Additional Security Measures: Third-party investigations should be conducted into questionable logging types (sanitary and other "gray" logging types unrelated to commercial harvesting) with the possibility of photographic documentation of areas before and after logging.

Conclusions:

NGO "ForestCom" emphasizes the importance of transparency in the timber supply chain for sustainable forest management and the development of businesses related to the processing of legally sourced timber in Ukraine. Implementing the recommendations will help avoid the mentioned risks and preserve forest resources for future generations.

L’viv, Ukraine                                                                                                                      

March 2024