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The UK Modern Slavery Act and EU Timber Regulation

Synergies and Divergence

By Duncan Brack, Jade Saunders
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In recent years, international supply chains for many primary products have come under scrutiny due to increased demands from consumers or regulatory bodies to ensure no negative social or environmental impacts are associated with their production. The UK Modern Slavery Act (MSA), enacted in 2015, has created new requirements for all industrial sectors to ensure that slavery and human trafficking is not taking place in supply chains. Given the historical prevalence of illegal and unsustainable logging in many forest-rich countries, supply chains for timber and forest products in the EU, USA, and Australia have been subject to scrutiny for a number of years. In the UK , the Timber and Timber Products (Placing on the Market) Regulation, which incorporates the EU Timber Regulation (EUTR) into UK law, prohibits the placing of illegally sourced timber products on the EU market, and also creates a requirement on companies or individuals first placing timber products on the market to exercise “due diligence” in sourcing, and thereby minimize the chance of their handling illegal products. Given that both the MSA and the EUTR seek to influence corporate buying behavior in global supply chains in order to reduce undesirable practices (forced labor, slavery, and illegal logging), this report analyzes the similarities and differences between the two sets of regulatory requirements, exploring the extent to which there are opportunities to learn from EUTR experiences to inform implementation of the more recently enacted MSA.