This, it says, is a great concern, as companies risk violating both the EU's sanctions against Russia and the EUTR.

As a consequence of its invasion of Ukraine, the EU has adopted extensive sanctions against Russia. These include bans on the import of all timber products and apply both to direct imports from Russia and to imports of processed goods via third countries.

In addition to the EU's sanctions, the EUTR regulates the import of wood and wood products into the EU. It sets precise requirements on identifying the origin of the wood, regardless of whether it has been processed in a third country.

The EUTR/FLEGT committee, comprising EU member states competent authorities, concluded at a meeting in April 2022 that it is not possible to comply with the EUTR if you bring wood and wood products originating in Russia into circulation in the EU. These conclusions remain valid.

The data extract from Statistics Denmark registers imports of birch plywood from Kazakhstan, China, Vietnam, Turkey and Brazil. None of these countries have introduced sanctions against Russia, and given where birch grows, DTTF concludes that the likelihood is that the imports may have come from Russia. Kazakhstan stands out particularly clearly, as imports of birch plywood, let alone other wood-based panel products, have not been registered previously.