Illegal logging

The effectiveness of the prohibition and of the due diligence system depends on the seriousness of controls by the public authorities.
Very little information exists on the controlling, by the competent authorities of Member States, of the monitoring organisations. Larger companies complain of being more frequently and more intensively exposed to checks by the national authorities as to their due diligence system than small companies. Small companies, in turn, complain that the establishing of a due diligence system and, when they are also traders, of a traceability system requires a considerable and very costly bureaucratic effort, which often exceeds the advantages of the system and will reduce imports of timber into the EU. All companies complain of the costs involved with the system.

Monitoring organisations are, overall, of limited effectiveness.
In some Member States they do not appear to be active at all (Slovenia, Italy). Some of them do not appear to have developed due diligence systems of their own or not to make it available to operators and traders. The verification of operators, one of the tasks attributed to them, also depends on the consent of the operator concerned which limits the number and effectiveness of such verifications. Their added value is doubtful.

As these answers were given only two years after the application of Regulation 995/2010, it appears early to take them as final statements and draw conclusions on the effectiveness of the Regulation on their basis. It appears clear, though, that the European Commission seriously needs to give more detailed guidance to Member States, to operators and to traders as to a number of key elements of the system. This includes the "due diligence system", where many details appear unclear, such as the relationship with existing international certification and verification schemes (Forest Stewardship Council (FSC), Programme for Endorsement of Forest Certification Schemes (PEFC), etc.), the required documentation and the risk assessment. The monitoring organisations, not forming a coherent body, seem to be of limited help in this regard; their active cooperation with operators and traders cannot be enforced. They might need some form of 'model due diligence system' themselves. This also applies to small and medium-sized operators.