Brazil Timber Risk Profile

Mitigate the risks in your supply chain

Learn which actions we recommended to mitigate the risks associated with the timber sources from Brazil

Source Certified Materials 

NEPCon believes that third party certification (for example FSC and PEFC certification) can provide strong assurances of the legality of the products they cover. Companies seeking to mitigate the risks of sourcing illegal timber should seek to purchase third party certified materials wherever possible. 

While the European Timber Regulation does not include an automatic “green lane” for certified products, it does recognise the value of certification as a tool for risk assessment and mitigation. The European Commission says that companies “may rate credibly certified products as having negligible risk of being illegal, i.e. suitable for placing on the market with no further risk mitigation measures, provided that the rest of the information gathered and the replies to the risk assessment questions do not contradict such a conclusion.”

For more information on using certified materials in your due diligence, including how to assess whether a certification system meets EUTR requirements, see the page on Certification and Due Diligence.

Mitigation recommendations

There are five recommended actions to mitigate the risks associated with the timber sources from Brazil.

1. Fully map your supply chain

• Our supply chain mapping tool can help you do this.

2. Obtain and verify documents 

• Land tenure and business documents
  • Land registry - confirm ownership and validity of property deed
  • Business Register - confirm valid business license to operate within the jurisdiction
  • Management contract or other agreements with the owner - confirm clear management rights
  • Map of traditional communities in wood-supplying districts, and when potentially affected by forest management activities - confirm these communities were consulted beforehand
• Tax related documents
  • Sales documents - confirm that information on species, quantities, qualities etc. are correctly stated, and that sales prices are in line with market prices
  • Fiscal bills of sale - confirm that includes applicable sales taxes, correct species, volumes and qualities
  • Receipts for payment of sales taxes
  • Invoices - confirm volumes, species and quantities match the taxes paid
• Harvesting documents
  • Forest Management Plan - confirm contains all legally required information and procedures; identifies harvesting restrictions (including maps); includes all legally protected areas, including species habitats
  • Harvesting inventories - confirm conducted according to statutory requirements
  • Harvesting permits (license or similar statutory document governing the harvesting of forest resources)
  • Annual Operating Plans for harvesting - confirm contains information and procedures, according to all statutory requirements and legally approved by Competent Authorities and be consistent with forest management plans
  • Maps of conservation units in the vicinity of supplier districts when activities occur in the buffer zone - confirm appropriate approvals are obtained by the management
  • Harvesting Plans (subject to public disclosure if legally required) - confirm consistency with forest management plans
  • Environmental and/or Social Impact Assessments - confirm in place and approved by the relevant authority, if legally required
  • Pollution monitoring reports - confirm that the requirements for the prevention of air and water pollution are in place (where applicable)
• Employment-related documents
  • Employment contracts for all employees
  • Evidence of insurance policies (INSS)
  • Employee certificates of competence
  • Salary payment receipts
• Trade and transport documents
  • Customs documents - confirm species, quantities, qualities correctly stated
  • DOF/GF – Document of Forest Origin (Documento de Origem Florestal) - confirm species, quantities, qualities match the taxes paid

3. Consult stakeholders

• Environmental agencies confirm the supplier's activities have not been embargoed
• Authorities confirm that the operation is up-to-date in the payment of the applicable sales taxes
• Authorities confirm the validity of the harvesting permit
• States or municipalities verify the applicability of the environmental licensing for planted forests
• Neighbours, local communities and others confirm that customary and / or indigenous peoples' rights are observed during harvesting activities and that land tenure rights are clear (in areas with land ownership conflict)
• Staff and contractors confirm that legally required protection equipment is required / provided by the organisation at no cost to the forestry worker and that forced or compulsory work is not involved in harvesting activities
• The Blacklist of Slave Labor of the Ministry of Labor and Employment can be reviewed

4. Carry out on-site verification

Of the harvesting activity, to ensure that: 

• Maps reflect reality
• Information relating to area, species, volumes, and other information provided in the harvesting permit is correct and within the limits prescribed in the legislation
• Harvesting takes place within the boundaries of the authorised FMU, in accordance with the management plan, within the scope of the harvesting permit and in accordance with the harvesting plans
• Environmental restrictions and requirements are followed in the field, including that:
  • Requirements related to soil damage, buffer zones, retained trees, seasonal restrictions, etc, are met
  • Harvesting is not taking place in permanent preservation areas
  • The management of permanent preservation areas shall not have affected their physical integrity
  • Harvesting of tree species or selected trees for which felling is prohibited is not taking place and are marked in the field
  • Requirements for surveying, managing, and protecting endangered or threatened species within the management unit are followed
  • The requirement for environmental monitoring is observed
• All safety and health supplements and regulations are followed and all required safety equipment is used 

Of the harvesting company (can be desk-based, but on-site), to ensure that:

• All workers are employed according to the regulations and required contracts
• Persons involved in harvesting activities:
  • Are covered by mandatory insurance policies (INSS)
  • Hold certificates of competence required for the function that they perform
  • Are paid a salary which is officially stated by the employer according to legal requirements
  • Are above the minimum age for both harvesting activities and hazardous work
  • Are paid at least the legally established minimum wage
• The company does not employ unregistered workers, either on probation, or who receive government benefits for the unemployed

5. Conduct targeted timber testing

• Conduct timber testing on samples of purchased material to verify the species or origin of timber, where appropriate