Stephen Mitchell Associates

+61 2 8006 8850

PO Box 309
Earlwood NSW 2206
AUSTRALIA

©2019 by Stephen Mitchell Associates.

Tips for compliance

January 18, 2018

We’ve been helping clients tidy up loose ends before the end of the soft start compliance period. Here are a few tips for to make life easier at the same time as helping comply with the due diligence requirements:

Approving new suppliers/vendors

Amending any standard operating procedures you have for approving new suppliers/vendors of wood or paper products to take into account compliance with the Illegal Logging Prohibition regulation is essential. This is so that the person responsible for Timber Due Diligence can undertake a risk assessment on the new supplier and the new product before an order is made. Remember - due diligence for illegally logged wood needs to be undertaken before the regulated timber products arrive in Australia.

Imports from Indonesia

For imports from Indonesia, set up simple checklists for shipping clerks to check V-legal certificates to ensure each and every consignment is compliant with the Indonesian Country Specific Guideline.

Due diligence on imports from China

Nearly every factory in China manufacturing wood or paper products appears to be FSC CoC certified. That is an exaggeration but it feels like it some days! If you want to purchase FSC or PEFC certified product (and these are within the scope of what they can actually supply), this is great. However, if you aren't buying a certified product (or aren't CoC certified yourself), FSC certification can be a real distraction from the information you actually need. Sending your Chinese suppliers a sample of what specific information or documentation you actually need can save everyone time. Site visits (with photos) by buyers or quality control to verify specific claims are also a handy tool for due diligence.

Consider Controlled Wood

If you are FSC or PEFC chain of custody (CoC) certified but can't justify the purchase of 100% or Mixed FSC or PEFC products - consider purchasing FSC Controlled Wood or PEFC Controlled Sources product. Controlled Wood is a wood product that has been assessed by a supplier's certifying body as a negligible risk of being illegally logged.
Buying Controlled Wood can be a much simpler route to comply with the Regulations if a products supply chain is complex. An importer has to undertake the same checks as for other types of FSC or PEFC certified products, however, you can't claim the product as FSC or PEFC certified to end users.

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