The recommended measures for DDS implementation are the result of  public consultations organized by WWF for the development of Centralized National Risk Assessment (FSC® CNRA)  attended by representatives of the state and private forest administration, operators, traders, competent authorities, local communities, NGO’s, professional associations in the field.

Legal rights to harvest

Risk description

Recommended measures

Relevant only for timber sourced from national forest fund which is in property of private individuals:

In practice, some forest administrations are satisfied with the presentation of an affidavit from one successor (in cases of multiple ones of the same inheritance), requesting the forest administration /forestry services and assuming full responsibility in the name of legal heirs. Thus, a certain successor may benefit of the wood products in possible detriment of others potential legal successors of the same inheritance. This fact my lead to Civil Code violation.

  • Check if the material originates from private or state forest.
    • State forest –Low risk;
    • Private forest – go to step 2;
  • Is the sourcing area covered by FMP?
    • If yes – Low risk;
    • If no – go to step 3;
  • Requirement of additional documents to prove the legal property rights:
    • Property title;
    • Sale contract;
    • Land book extract;
    • Inheritance certificate;
    • Final court sentences related to shares;
    • Notary empowerment (in cases of multiple beneficiaries);
  • Verification as appropriate, of property and harvesting sites limits;

Relevant only for timber sourced from forest vegetation outside the national forest fund:

Frequently, there is no clear demarcation of land properties.

  • Requirement of additional documents to prove the legal property rights (see above);
  • Verification as appropriate, of property and harvesting sites limits;


Amendments to the Forestry Code (Law 46/2008), through the adoption of Law 175/2017, as well as amendments to the Methodology for approving the exceeding of the annual capacity with the volume of the wood mass in the stands affected by biotic and / or abiotic factors, by MO 1094/2017 brings clear specifications regarding the quality of the beneficiary, quality to be proven in accordance with the provisions of Law no. 287/2009 (Civil Code), but the level of enforcement is not evaluated at this time.

Taxes and fees

Risk description

Recommended measures

Regarding only the toll tax and local fees for the use of local public infrastructure (communal or forest roads):

The risk on avoiding the road tolling payment appears due to forest ownership and management fragmentation, respectively of forest roads distribution. In many situations, the timber owner and road owner/manager is not the same entity and thus cannot charge this road toll. In such situations, some of the operators are avoiding the payment of this tax by not informing the rightful owner/administrator of the road.

  • Check if the wood material owner and the road owner/administrator is the same entity:
    • If yes – Low risk;
    • If no – go to step 2.
  • Check the existence of contracts/protocols between parties that are also covering the road tolling aspect:
    • If yes – Low risk;
    • If no – go to step 3;
  • Notify the road owner/administrator in order to obtain road owner/administrator agreement:
    • If yes – Low risk
    • If no – do not buy;

Timber harvesting activities

Risk description

Recommended measures

Examples of third-party legal rights being affected:

(i) location of timber collecting and removing paths,
(ii) tonnage restrictions on the timber transport.

  • Verifying as appropriate, during the timber harvesting process, that the use of property is in compliance with the legal rights of third parties (obtaining their consent, or as appropriate, observance of the agreements between parties).

Regarding the application of forestry rules for the harvesting process:

Due to high frequency with which these rules are breached at national level, the origin must be verified.

An internal verification program will be set up regarding compliance with harvesting rules, the prioritization of controls should be done following a risk based approach.

Sources for control prioritization (the list is not exhaustive):

  • Map of illegal logging prevalence:
  • Media news on the subject;
  • Complaints register of the harvesting company;
  • Technical record of the harvesting company;
  • Control records issued by relevant forest authorities (e.g. Forest Guard, forest administrator).

Control measures:

  • Additional verification at the harvesting sites for: (i) assuring compliance with the provisions of the harvesting permit and with the measures issued by the competent authorities; (ii) observing the deadlines, modalities and periods of collection, removal and transport of timber;
  • Additional trainings appropriate to the responsibilities of staff, established through specific work procedures (for risk mitigation)

Regarding the harvesting operations carried out in protected areas:

Due to high frequency with which these conditions are not followed, checks will be made systematically through harvesting controls.

  • Existence of harvesting permit, which also includes environmental conditions, according to the law;
  • In forests under ”Pin-Matra/2001/018” study or any other background studies submitted in accordance with legal procedures, operations will be carried out only on the basis of the opinion of the specialized territorial structure of the central public authority responsible for forestry, which certifies that the stands do not meet the criteria and indicators approved by the Ministerial Order of Environment and Forests no. 3397/2012;
  • Harvesting activities will start only after obtaining the harvesting permit, according to the legal procedures;
  • Additional field inspections to follow compliance with environmental conditions and monitoring measures imposed through the harvesting permit, according to legal procedures.

Employee qualifications and rights

Risk description

Recommended measures

Concerning labor health and safety:

At the moment, noncompliance to H&S norms represents a widespread practice in timber harvesting activities, at national level.

  • Existence of risk assessments on H&S specific to each job;
  • Existence of equipment according to identified risk mitigation measures regarding H&S;
  • Conducting specific trainings;
  • Field verification regarding compliance with H&S measures (staff interviews);
  • Immediate steps will be taken to remedy H&S nonconformities and where appropriate and until resolution, harvesting activities shall be suspended.

Regarding the qualification and legal employment of the personnel:

Undeclared work, as well as job placement for unqualified staff, are widespread practices at national level.

  • Compliance will be monitored in practice with the attestation conditions of operators (including the necessary equipment) for the harvesting activity.
  • Functioning of specialized personnel in the harvesting activities according to the legal conditions of accreditation;
  • Qualification of hired personnel according to applicable legislation (diplomas, certifications, authorizations);
  • Adequate training of staff according to the established role and responsibilities;
  • Employment according to legal procedures (REVISAL)

Purchase, marketing and transport

Risk description

Recommended measures

Regarding quantitative / qualitative classification and timber transport:

The main risk associated with the transport of wood occurs due to the deficiencies of the WoodTracking traceability system and it is manifested in the form of multiple shipments performed on the basis of the same code issued by the application.
Also, due to the legal method of cubage based on volume estimation, after the harvesting process, an additional volume of wood can result. This volume is not systematically declared.

  • The level of implementation of additional measures regarding risk mitigation will be followed by the operator through internal monitoring and official control reports.
  • Verify shipment documents (delivery documents) and codes regarding wood origin and destination (Provided by Wood Tracking System). Delivery documents shall confirm the date/time and the logging/destination area.
  • Total volume and assortments specified on delivery notes (round wood, logs, firewood) will be compared with the register of entries to ensure assortments are correct.
  • Physical checks should verify that the present material is corresponding to the one on the invoice and delivery notes;
  • Extra tolerance volumes, shall be separated and the territorial Forestry Guard shall be informed, according to law;
  • Adequate trainings for workers on: legislation provision, measurement methodologies, WT & SUMAL software;

Maintenance and periodic evaluation of the efficiency of established prevention system (DDS)

Descrierea riscurilor

Masuri recomandate

The lack of national assessment regarding the degree of implementation of the requirements imposed by EU Timber Regulation (995/2010) implies a precautionary approach.

  • Check the existence of DDS system;
    • If yes – go to step 2;
    • If no – exclude supplier/subsupplier from supply chain;
  • Verify compliance with the established DDS system through:
    • Internal monitoring;
    • Verification of compliance with any corrective measures imposed by controls of competent authorities.