Regulation and sustainability
Proving where a raw material came from
What you must be able to show when origin stops being data and becomes an obligation.
For several raw materials — timber, paper and board, palm oil, soy, cocoa, coffee, rubber, and cattle linked to them — origin has moved from commercial information to a documentary obligation. With one uncomfortable detail: the country is not enough, you must be able to point to the plot.
What you must be able to show
| Element | What it means in practice |
|---|---|
| Where it was produced | Plot coordinates, not the region |
| When | Production date or period |
| Who sold it | The full chain down to you, with no gaps |
| What you checked | Your risk assessment and what you did about it |
Important
The fourth is the one almost everyone forgets and the only one that depends solely on you. The first three must be given to you; the fourth you produce, and its absence is what turns an incomplete file into a breach.
Where to start if you have nothing yet
- 1
List what you buy that is affected
Usually fewer items than expected: three or four references.
- 2
Look at who sells it to you
A large importer will already hold the file; a small intermediary probably will not.
- 3
Ask everyone the same thing, in writing
An identical request is what makes the answers comparable.
- 4
And keep the refusals too
A supplier who cannot provide origin is a decision you have to take, and it helps to record when you knew.
Watch out
The usual blind spot is the processed product. If you buy ready-made packaging, the obligation does not vanish because you never saw the tree: it travels with the product.
How it holds up over time
Worth knowing
This fits what you already do for other things: per-supplier documentation, with expiry and reminders. What is specific is what you ask for and how precisely, not the mechanism.
›Is a signed supplier declaration enough?
It is the starting point, not the end: you must be able to back it up.
›What if the supplier is outside the EU?
The obligation falls on whoever places the product on the market; usually you.
›How long must it be kept?
Years, not months. Keep it where it can be found, not in an inbox.
A real case
The situation
A packaging firm finds its board is affected and its supplier cannot give coordinates.
What you do
- Sends the same written request to all three suppliers
- Records the refusal with a date and assesses the risk
What you get
Switches supplier with a documented reason, instead of finding out during an inspection.
The situation
The origin is asserted by the supplier and nothing more.
What you do
- Requests the document that backs it
What you get
The claim stops being only a claim.
The situation
Consignments of different origins get mixed.
What you do
- Records which consignment went into which production
What you get
You can say what came from where.
The situation
A client asks about the origin of a specific shipment.
What you do
- Checks that delivery's file
What you get
You answer per delivery rather than per catalogue.
The situation
The supplier changes origin and does not say so.
What you do
- Asks them to report any change
What you get
The change arrives before the question.
The situation
The origin document is filed by supplier.
What you do
- Also files it against the consignment
What you get
You answer for a specific shipment.
This article answers
- prove where timber came from
- raw material traceability
- due diligence declaration
- documenting raw material origin