Guidance for processors

This page provides explanatory information and guidance on the key elements of the illegal logging due diligence requirements, as set out in the Illegal Logging Prohibition Regulation 2012 (the Regulation).

Additional helpful information on the due diligence requirements is on the Frequently Asked Questions and the Guidance Material and Resources webpages (including due diligence toolkits developed in partnership with selected industry associations).

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Due Diligence System requirements

Before you process a domestically grown raw log, you must establish a due diligence system. This needs to describe the practices and procedures you will use to minimise the risk that the logs you are dealing with has been illegally harvested.

Your due diligence system must be in writing and should be tailored to meet your day to day needs. However, these key elements need to be included in every system:

    • the procedures you will use to minimise the risk that the logs you are processing have been illegally harvested
    • relevant details about your organisation/self, including your company or business name (where applicable), your street and postal address, and a contact telephone number and email address
    • if you are processing the log for commercial purposes, an Australian Business Number or Australian Company Number, and a description of your principal business activity
    • the person responsible for maintaining the due diligence system and their contact details.

Once established, your system should guide your due diligence decisions. It is up to you how often you review your system, but it should be kept up to date and relevant.

You may be asked to provide a copy of your due diligence system to the department as part of a compliance assessment process. Further information about the department’s compliance assessment process is on the Illegal Logging Compliance page.

Step 1 - Gather information

Before you process a domestically grown raw log, you need to gather certain information about the log and its background. This information will form the basis of your risk assessment.

As a bare minimum, the Regulation requires you to gather the following information (where reasonably practical):

  • a description of the logs, including the common name, genus or scientific name of the tree/s from which the logs are derived
  • the area in which the logs were harvested, including the State or Territory and forest harvesting unit
  • the quantity of raw logs to be processed, expressed in volume, weight or number of units
  • the name, address, trading name, and business identification numbers (if any) of your supplier
  • the documentation provided by your supplier in relation to the product’s purchase
  • materials that attest to the product’s legality, this could include a suitable Timber Legality Framework certificate or license; the documents identified in a relevant State Specific Guideline; or other evidence that suggests the product has not been illegally logged.

What is ‘reasonably practical’ depends on your individual circumstances. As a guide, you should consider the availability of the required information; the time, expense and difficulty in gathering the information; and the steps required to gather the required information. Ultimately, you need to be able to show that you have made reasonable efforts to seek the required information.

In some circumstances, it may not be possible to gather all of the required information. The absence of this information should be factored into your risk assessment. An inability to gather key pieces of information about your product(s) may make it harder to conclude that it is low risk.

How you gather the required information is up to you. This could include: phone calls, emails, web research, questionnaires sent to suppliers, site visits, etc. However, you must keep suitable written records of your efforts. These records must be held for at least five years after the import date (see Step 5 –Maintain Records).

Step 2 – Undertake a risk assessment

You will need to use the information gathered in Step 2 to assess the risk that the raw logs you are processing contain illegally logged timber. This requires you to consider the information you have collected and then make an informed decision about the risk associated with the logs.

The Regulation allows you to use three potential methods to assess your risk:

  • a Timber Legality Framework (such as the Forest Stewardship Council (FSC) or Programme for the Endorsement of Forest Certification(PEFC) certification schemes)
  • a State Specific Guideline (SSG)
  • the regulated risk factors set out in the Regulation.

The method you use will depend on your circumstance, such as where the raw log is from, what species it is, and the available harvest documentation.

Option 3A - Identifying and assessing risk against a Timber Legality Framework

If you have gathered evidence that suggests the raw logs you are processing are certified under the FSC or PEFC timber certification schemes, you can potentially use the Timber Legality Framework risk assessment method. This method should be available for the majority of Australian harvested logs.

This method relies on the fact that the FSC and PEFC certification schemes provide rigorous forest management and chain of custody standards, and are less likely to include illegally logged timber.

If choose to use the Timber Legality Framework risk assessment method, it is important that you confirm the raw logs you are purchasing are actually certified.

Table 1 below outlines the keys steps that you can take to assess if your raw logs are FSC and PEFC certified. If after completing these steps you find that your raw logs are not certified, you must choose an alternative risk assessment method.

Table 1: Assessing if your products are FSC or PEFC certified

Step One -  Check if supplier’s certificate number is legitimate


Certified suppliers should have a unique FSC or PEFC certificate code or number quoted on their certificate.

Using the certificate code or number, you can verify if the certificate is legitimate by searching on the relevant scheme’s website:

Forest Stewardship Council (FSC)

PEFC International

Common problems and solutions

If the number or code has been typed incorrectly and you cannot locate it online, contact your supplier and request they email you a hyperlink to the online certificate record or contact the respective scheme and query the certificate codes provided by supplier.

Step Two - Check your supplier is the certificate holder


When you have located the certificate details online, ensure they match the details provided by your supplier.

Common problems and solutions

If the details of your supplier do not match those on the certificate, you should seek to clarify the authenticity of the certificates.

If your supplier has claimed the log is FSC or PEFC certified, but it is not their name on the certificate there could be a problem. You need to seek further information from the supplier or the relevant governing body. 

Step Three -  Check the certificate is valid for the period of supply


The expiry date of the supplier’s certificate should be listed on the FSC or PEFC’s websites. Check the certificate is valid for the associated period of supply.

Common problems and solutions

If the certificate appears to have expired or is currently suspended, you should seek further information as to why this has occurred. You may need to clarify this information with the supplier or discuss the matter directly with the governing bodies of the appropriate scheme.

Step Four - Check the logs being supplied are listed on the certificate’s record


Certified suppliers can supply both certified and non-certified logs. You will need to check that the logs being supplied fall with the scope of your supplier’s FSC or PEFC certificate.

Common problems and solutions

If the logs you are purchasing is not covered by your supplier’s certification, you should check with the supplier as to whether there is a mistake on the record. If this is the case, you should also ask for written confirmation from the certification body.

Step Five - : Check the log supplied is the log that was promised


After completing all of the steps above, it is a possibility that the supplier has not provided you with a certified log.

Common problems and solutions

You should seek a sample of invoices and delivery notes to make sure the certificate number is suitably quoted and that under the product description the log is listed as FSC or PEFC certified.

If you can complete the steps above, confirm that the logs you intend to process is certified, and are not aware of any other information that might suggest the product you are dealing with includes illegally logged timber, you can assume the risk is low and process the raw log.

Option 3B - Using a State Specific Guideline

The Australian Government has worked with the state governments to develop State Specific Guidelines (SSGs).These detailed documents help you to better understand the legal frameworks that regulate the harvesting of timber in each state. In some cases, the SSGs also provide helpful information on timber transportation, processing, and export approval processes.

The SSGs provide a useful oversight of how forests are managed in each state and in some cases, relevant documentation that you can seek from your supplier to demonstrate legality. This should help you to assess the risk that the raw logs you are processing includes illegally harvested timber.

Each SSG is accompanied by a “Quick Reference Guide” (QRG), which summarises the key information contained in the SSG. The QRG is your first point of reference for identifying whether the SSG method is an appropriate option for conducting your risk assessment.

Table 2 below outlines the keys steps that you should use when using the SSG risk assessment method. The ‘questions to consider’ included in the table will help you when using the SSG method, but should not be seen as an exhaustive list of issues to consider.

Table 2: Assessing risk against a state specific guideline
Step one – Determine if a SSG is applicable to the product you are importing


Check that your product is covered by a SSG. The SSGs are published on our Guidance Materials and Resources page.

Step Two – Assess the information you have gathered against the SSG


Compare the information you have gathered in the information gathering step of the due diligence process against the SSG for completeness and consistency.

Gather any additional information or documentation specified in the SSG.

Common problems and solutions

If your supplier is unable to provide you with documentation, the SSG may provide guidance on the type of documents available, the issuing authority, and how to obtain copies of the documents.

You are not required to obtain all of the documents detailed in the SSG, only those that are reasonably practicable to obtain. However, you will need to obtain enough information to support a reasonable assessment of risk using the SSG risk assessment method.

Questions to consider:

Have you checked the information, or obtained the documents that the SSG suggests are available to support legality of harvest?

Does the information you have gathered correlate with the information and documentation contained in the SSG?

Step Three – Identify and assess risk


Using all of the information and documents you have collected, come to a conclusion as to whether the raw logs you are processing are likely to include illegally logged timber.

In coming to your conclusion, you need to consider any other information that may indicate whether the raw log has been illegally harvested (including general information you have already obtained).

Common problems and solutions

While every effort is made to ensure that SSGs are up to date, they reflect forestry laws at a point in time and may not capture recent developments.

Questions to consider:

Are the documents collected genuine and have they been generated by the appropriate government entity or other body?

Are there any inconsistent or missing documents?

Is the timber the subject of a logging ban or restriction?

Has there been any media articles, third party reports, or government statements that would bring the legality of your product(s) into question?

Is there any other information you know or ought to know, that would call into question the legality of the product(s)?

Step Four – Determine your risk assessment outcome


Once you have completed the steps above, you should be able to determine if the raw log is likely to have been illegally harvested.

If you have concluded the risk to be low, you have completed your risk assessment and can process the raw log.

Common problems and solutions

If your risk assessment process has concluded the risk to be greater than low you need to further mitigate the risk. This is explained in greater detail in Step 4 of the due diligence process.

Option 3C - Using the regulated risk factors

The Regulation establishes a series of risk factors that can be used to assess the risk that the raw log you are processing has been illegally harvested. These risk factors have been identified by the government as being useful indicators of legality and should help you to undertake an informed risk assessment process.

This method can be used for raw logs from any source or background. In many situations, this method may also provide the simplest way of conducting your risk assessment.

The regulated risk factors method requires you to evaluate the information you have gathered in Step 2 of the due diligence process and then assesses the risk against the factors outlined in Table 3.

Table 3: Assessing risk against the regulated risk factors
Risk Factor

(reason for your low, medium, high)

1. What is the prevalence of illegal logging in the area in which the logs are harvested?


The most important thing to be mindful of when considering this factor is that you know where your logs are being sourced from. An indicator that something isn’t right might be that your supplier is unable to identify where the logs came from.

2. What is the prevalence of illegal harvesting of the species of the log in the area it is derived?


Try to determine the species of timber you are processing. Indicators that something isn’t right might be that the species doesn’t grow in the area your supplier says it does or that the species is listed as ‘vulnerable’ or ‘threatened’ under State or Commonwealth legislation.

3. Do you know any other information that may indicate whether the logs were illegally logged?


This factor requires you to consider any additional information that you may be privy to that indicates the timber was illegally logged. Indicators that something isn’t right might be:

  • potentially forged, inconsistent or missing documents
  • the supplier is known to deal with illegally logged timber
  • goods being sold significantly below the market rate
  • appropriate taxes are not included in the price
  • cash only, or lower price for goods without paperwork
  • asked to pay a bribe
  • unable to get rational answers to questions.


DocumentPagesFile size
Risk assessment te​mplate PDF1241 KB
Risk assessment template DOCX122 KB

If you have difficulty accessing these files, please visit web accessibility.

Step 4 – Risk mitigation

Risk mitigation is required when you have undertaken a risk assessment and determined the risk to be anything higher than low. This indicates that your raw logs may have been illegally harvested.

How you mitigate the risk is up to you. However your mitigation efforts need to be adequate and proportionate to the identified risk. This could include, but is not limited to, asking for additional evidence or information from your supplier; asking your supplier for a certified alternative; visiting your supplier to learn more about their supply chains; or instigating a regular audit process. Ultimately, you may need to consider requesting lower risk logs, or even changing suppliers.

Once you are satisfied that you have mitigated the risk to a low level, you must document the steps you have taken and keep records showing how your actions reduced the risk that your raw log was illegally harvested.

If you are unable to mitigate the risk adequately, you should not process the raw log. If you do process the log and it is later found to have been illegally harvested, you could face serious penalties.

Step 5 – Maintain Records

The Regulation requires you to maintain records covering all steps and elements of the due diligence process. Records can be kept digitally or on paper and must be maintained for at least five years.

You need to keep records that clearly set out:

  • your due diligence system
  • the information gathered about a regulated timber product
  • your risk assessment process and conclusion
  • any supplementary risk mitigation activities undertaken.

Your records may be assessed as part of the department’s compliance assessment process. Further information about the department’s compliance assessment process is on the Illegal Logging Compliance page.

More information

We are here to help you comply with Australia’s illegal logging laws. These webpages provide a range of resources and guidance to better understand your obligations under the laws.

You can also contact us for further information on how the laws operate and if they affect you:

  • phone during business hours on 1800 900 090 or if outside of Australia +61 2 6272 3933
  • email illegal logging
  • subscribe to the illegal logging mailing list to receive new information or guidance materials and details on upcoming information events.