Under the UK Timber Regulation (UKTR), the business that first places timber or a timber-based product — such as the MDF in this panel — on the UK market is the 'operator', and must carry out due diligence on legality of harvest, recording species, country of harvest and supplier information. Published guidance identifies that business by the importer named on the customs declaration, not by whoever sold the goods. Under DAP as we currently offer it, you clear the panels into the UK, so on that reading the operator duty is yours. We are pre-launch: we hold no compliance documents and run no due-diligence system, so we are not in a position to carry it for you. Confirm the declared importer with us per order, and take advice on your own position.
Operator vs trader, in plain English
Under the UK Timber Regulation, an operator is the business that first places timber or a timber product on the UK market. An operator must exercise due diligence: identifying the product, the country and, where relevant, the concession of harvest, and assessing the risk that the timber was illegally harvested. A trader is a business further down the supply chain buying and reselling an already-placed product within the UK — traders have lighter obligations, mainly keeping records of who they bought from and sold to.
The panel's MDF core originates outside the UK, so on every order one of the two parties holds the operator duty. Which one is not a matter of preference, and it is not settled by the sales relationship.
Who carries the duty on your order
It follows the customs entry, not the invoice. UK guidance identifies the operator by the importer named on the declaration — so it is the paperwork on a given shipment that decides who holds the duty, not who sold the goods to whom.
Under DAP as we currently offer it, that is you. Our terms are delivered at place: we arrange and pay for transport to your named UK address, and import clearance and any duties or taxes at destination are yours. If you are named as importer, the operator duty is yours in full — not the lighter record-keeping duty of a trader buying a product that somebody else has already placed on the market.
We are not in a position to take it from you. We hold no compliance documents and run no due-diligence system. The entity behind this site is not UK-established, and whether it could be named as GB importer at all is unresolved — where an indirect representative is required for customs, that representative becomes the declared importer and carries the operator role with it. Ask us where this stands on your order rather than assuming it is settled.
This is our reading of published guidance rather than legal advice, and we would rather show you the reading than hand you a conclusion. The guidance identifying the importer predates the customs system now in use, so the read-across is ours and not something we have seen stated. The liability here is yours — take your own advice on it.
What a due-diligence pack contains
A due-diligence system under UKTR typically gathers: a description of the timber product and its species; the country (and, where applicable, sub-national region and concession) of harvest; supplier documentation confirming legal harvest; a risk assessment against that information; and risk-mitigation measures where risk is identified as more than negligible.
What we currently hold for this product
| Document | Status |
|---|---|
| No compliance or test documents are published yet for this product. Documents are published here as they are issued and confirmed — never before. | |
This includes an E1 formaldehyde emission declaration for the MDF core and ISPM15 confirmation for export packaging, both requested from our manufacturing partner but not yet received. We do not assert compliance ahead of holding the documents that evidence it.
Frequently asked questions
Are you the 'operator' or the 'trader' under UKTR for this product?
It depends on your order, and a supplier who answers that confidently in the abstract is guessing. The operator is the business that first places the product on the UK market, and published guidance identifies it by the importer named on the customs declaration rather than by who sold the goods. Under DAP as we currently offer it, import clearance is yours — so on that reading you are the operator, and the full due-diligence duty is yours rather than a trader's lighter record-keeping duty. Stated plainly, because it is the sort of thing a supplier should not let you discover later: we are pre-launch, our due-diligence system is being built rather than running, and we hold no compliance documents yet. Do not plan your own UKTR position on the assumption that ours is in place; confirm the declared importer with us when you order.
Can you be the importer of record instead, and carry it for us?
Not today, and we would rather say so than agree and work it out afterwards. We hold no compliance documents and run no due-diligence system. The entity behind this site is not UK-established, and whether it could be named as GB importer at all is unresolved — where an indirect representative is required for customs, that representative becomes the declared importer and carries the operator role with it. If your order needs us to import, ask, and we will tell you where it stands rather than assume it.
What documents do you currently hold for this product?
None are yet published — see the table above. Each is published here as soon as it is issued and confirmed; nothing is claimed before it exists.