Regulated timber products

The following products are exempt from the due diligence requirements:

• Products imported into Australia where the combined customs value of the regulated timber products in the consignment is $1000 or less.
• Products:
  • which are recycled material
  • which are entirely made from recycled material
  • where all timber, and products derived from timber, included in the regulated product are recycled material.

If a product contains both recycled and non-recycled timber, due diligence is still required for the non-recycled parts.

Timber or a timber product, is considered recycled material if:

• it was once a different product or part of another product
• it is no longer the previous product, or has been removed from the previous product
• at the time, the other product was no longer used for its intended purpose.

Material is not considered recycled if it is the by-product of a manufacturing process. For example, sawdust or off-cuts from sawn timber used to make particle board or medium density fibreboard.

Due diligence is not required for the packaging material used to support, protect or carry a product that is being imported.

However, if the packaging materials are the main product being imported, and are covered by a regulated tariff code, you must conduct due diligence.

Materials that are not considered timber include:

• bark
• cork
• osier
• vegetable parchment
• rice
• bamboo
• sugarcane 
• rattan. 

They are not regulated under the illegal logging laws.

Under the illegal logging laws, due diligence applies to the regulated timber product being imported.

A regulated timber product is generally identified by its tariff classification and product characteristics, not by internal inventory systems including Stock Keeping Units (SKUs).  SKUs are not referenced in legislation and do not determine the level at which you must apply due diligence.

What this means in practice

Importers do not need to assess every SKU separately where products share the same timber characteristics. Instead, you can:

• group product types with the same timber inputs and supply chain
• map multiple SKUs to a single grouping
• apply one due diligence process to that grouping

Your written due diligence system should clearly set out any SKU grouping processes that form part of your due diligence process.

Repeat due diligence exception

Where businesses use SKUs, the repeat due diligence exception should be considered at the level of the regulated timber product (or product grouping)—not at the individual SKU level.  This means SKUs can only rely on the exception where they represent the same timber product in all material respects.

Examples

Below are several examples to assist importers understand how due diligence applies at the timber product level, where multiple SKUs are used.

Example 1 — Nordic Oak Chair (SKUs can be grouped)

Why these can be grouped

The SKUs differ only by finish/colour, while the product type, trade name, supplier, species, harvest origin, and manufacture country are the same (i.e., same timber product type and inputs).

Example 2 — A4 Colour Copy Paper (SKUs can be grouped) 

Why these can be grouped

Dye/colour does not (by itself) change the timber product profile.

Example 3 — Coloured Kraft Board Sheets (SKUs can be grouped) 

Why these can be grouped

Dye/colour does not (by itself) change the timber product profile.

Example 4 — ‘Looks the same’ but SKUs must not be grouped

Here’s the same ‘A4 Copy Paper – 80gsm’ trade name, but distinguishing factors differ (origin and/or supplier and/or manufacture), so they should be treated as separate groupings.

Why these must not be grouped

The supplier and/or species and/or harvest origin and/or manufacture country differ.

Differences in paper weight (gsm) do not, in themselves, require separate due diligence assessments.

Where products of different weights (e.g. 80 gsm and 200 gsm) or size (e.g. A4, A5, B5) are made from the same timber inputs, sourced from the same supplier, and share the same harvest origin and manufacturing process, they may be treated as the same regulated timber product for the purpose of due diligence.

However, where differences in weight reflect differences in fibre composition due to species, origin or supply chain, separate due diligence assessments may be required.