Timber sourcing compliance for construction

If your construction business places timber or timber products on the Great Britain market for the first time, you must exercise due diligence to ensure the timber has been legally harvested. This obligation comes from the UK Timber Regulation (UKTR), which replaced the EU Timber Regulation on 1 January 2021.

The UKTR applies to all operators who first place timber on the market in England, Scotland, or Wales. In construction, this typically means businesses that import structural timber, joinery timber, plywood, formwork panels, or timber cladding directly from overseas suppliers. If you buy timber from a UK-based supplier who has already placed it on the market, you are a trader rather than an operator, and your obligations are limited to maintaining traceability records.

Enforcement is carried out by the Office for Product Safety and Standards (OPSS), which has the power to inspect your due diligence system, require corrective actions, issue compliance notices, and prosecute for non-compliance. On conviction on indictment, placing illegally harvested timber on the Great Britain market carries a fine and/or up to 2 years' imprisonment (on summary conviction, a fine and/or up to 3 months).

When this applies to you

You need to follow this guide if you are:

• A construction business importing timber or timber products directly from outside Great Britain
• A timber merchant or distributor placing timber on the Great Britain market for the first time
• A manufacturer producing timber products (such as engineered timber, glulam, or CLT) from imported raw timber
• A construction contractor who sources timber directly from overseas for a specific project

This guide does not cover Northern Ireland, where separate requirements apply under the Windsor Framework.

How to set up your due diligence system

The UKTR requires operators to implement a due diligence system with three steps: information gathering, risk assessment, and risk mitigation. You can either develop your own system or use the system provided by a recognised monitoring organisation.

Step 1: Gather information from your supply chain

For each consignment of timber you place on the market, collect and record the following:

• Species identification - the common and scientific name of the timber species
• Country of harvest - where the trees were felled, including the sub-national region where applicable
• Quantity - volume, weight, or number of units
• Supplier details - name, address, and contact details of your immediate supplier
• Compliance documents - any certificates, licences, or permits demonstrating that harvesting complied with the laws of the country of origin

For construction timber, pay particular attention to the country of origin. Tropical hardwoods, Eastern European softwoods, and timber from countries with high rates of illegal logging require greater scrutiny.

Step 2: Assess the risk of illegal harvesting

Using the information you have gathered, assess whether there is a risk that the timber was illegally harvested. Consider:

• The prevalence of illegal harvesting in the country of origin (use Transparency International corruption indices, the Preferred by Nature Sourcing Hub, Global Forest Watch, and Chatham House forest governance research)
• The complexity of the supply chain - longer chains with more intermediaries increase risk
• Whether the timber is covered by a credible third-party certification scheme (such as FSC or PEFC)
• Any sanctions or trade restrictions applicable to the country of origin

Step 3: Mitigate any identified risk

Where your risk assessment identifies the risk as non-negligible, take proportionate steps to reduce it. This may include:

• Requesting additional documentation from your supplier, such as harvesting permits and transport documents
• Commissioning independent verification of the supply chain
• Switching to a certified or lower-risk supply source
• Refusing the consignment if the risk cannot be adequately mitigated

Timber products covered in construction

The UKTR applies to a wide range of timber products commonly used in construction. If you are the first to place any of these products on the Great Britain market, you must exercise due diligence:

• Structural timber - sawn softwood and hardwood for framing, roofing, and floor joists
• Engineered timber - glulam, cross-laminated timber (CLT), laminated veneer lumber (LVL), and I-joists
• Plywood and panel products - including structural plywood, OSB, particle board, and MDF
• Formwork - plywood and timber used for concrete shuttering
• Joinery - windows, doors, staircases, and internal fittings made from timber
• Cladding and decking - external timber cladding, rainscreen panels, and decking boards
• Fencing and hoarding - site hoarding panels, temporary fencing, and palisade fencing

Exclusions: Recycled timber products and timber products that have reached the end of their lifecycle are excluded from the UKTR due diligence obligation. However, if you are reusing reclaimed timber in a new product that you then place on the market, the exclusion only applies to the reclaimed component.

FLEGT licensing and CITES permits

FLEGT licensing

Timber imported under a valid FLEGT licence (Forest Law Enforcement, Governance and Trade) is automatically accepted as having satisfied the UKTR due diligence requirement. For the GB market, FLEGT licences are recognised under the UK FLEGT Regulation and are issued by countries that have implemented a Voluntary Partnership Agreement with the UK - currently only Indonesia. A licence issued under an EU VPA does not, of itself, validate timber for the GB market.

If your construction timber is accompanied by a valid FLEGT licence, you do not need to carry out a separate risk assessment for that consignment. However, you must still retain the FLEGT licence documentation as part of your records.

CITES-listed timber species

Some timber species used in high-end construction and joinery are listed under CITES (Convention on International Trade in Endangered Species). If you are importing CITES-listed timber into Great Britain, you need a valid CITES import permit issued by the Animal and Plant Health Agency (APHA). Common CITES-listed species used in construction include certain rosewoods, mahogany species, and afrormosia.

Timber accompanied by valid CITES permits is accepted as legally harvested for the purposes of the UKTR. The CITES permit requirement is separate from and additional to the UKTR due diligence obligation.

What to do next

Record keeping

You must maintain your due diligence records for a minimum of 5 years from the date the timber was placed on the market. This includes supplier information, species identification, country of harvest, your risk assessment, and any risk mitigation measures you took. Keep records in a format that can be produced to OPSS on request.

If you are a trader (buying timber already on the Great Britain market from another UK supplier), you must be able to identify your supplier and anyone you have supplied for a minimum of 5 years. This traceability obligation applies throughout the supply chain.

Monitoring organisations

You can simplify compliance by using a recognised monitoring organisation to provide and maintain your due diligence system. Monitoring organisations must be approved for the UK - approval is separate from EU recognition, and the current list of UK-approved monitoring organisations is published on GOV.UK with the UKTR guidance. Using a monitoring organisation does not transfer your legal responsibility, but it provides a structured framework and access to country-level risk data.

OPSS inspections

OPSS carries out inspections of operator due diligence systems on a risk-based programme. Inspectors may:

• Request access to your due diligence records and supplier documentation
• Assess whether your due diligence system is adequate for the timber products you are placing on the market
• Issue a Notice of Remedial Action if deficiencies are found, requiring you to improve your system within a specified period
• Prosecute for persistent or serious non-compliance

Ensure your due diligence records are accessible and up to date at all times. If OPSS contacts you for an inspection, you will typically be given advance notice, but you must be able to produce records promptly.

Related guidance

If you use construction products that require CE or UKCA marking, see our guide on construction product marking compliance. For a broader overview of construction materials obligations including COSHH and product safety, see the construction materials compliance checklist.