In March 2025, the European Commission published a communication on the hazard of circumvention of sanctions imposed on imports of Russian and Belarusian plywood, in peculiar in the case of birch plywood imported into the Union from China, Kazakhstan, Turkey and countries maintaining close commercial relations with Russia.
Wood and wood articles, including plywood, are prohibited from importing from Russia and Belarus. The European Commission is alerting that Russian and Belarusian birch plywood proceed to enter the Union through 3rd countries. The Commission so called on EU entrepreneurs to exercise due diligence.
The Communication from the European Commission was issued at the time erstwhile Polish importers of timber and timber-derived products are already fulfilling fresh documentation obligations on the basis of the amendment of the alleged Sanctions Act, which has been in force since 26 February 2025.
‘In circumstances of geopolitical change which require both national marketplace operators and global flexibility and adaptability, the transparency of the supply chain is simply a key origin of quality and accountability to customers. The transparency of the supply chain is besides the basis for sustainable improvement as it covers both environmental aspects and social work towards interior and external stakeholders. According to erstwhile experience, the deficiency of supplier verification systems during the period of economical crises caused a breakdown of the full supply chains which were hard to rebuild in subsequent years. Therefore, sound control and compliance with EU government is simply a warrant of stableness for all actors in the supply chain" – says Dr. Halina Brdulak, Prof. SGH, College of planet Economy, Chair of global Management of the SGH.
It is worth mentioning that, in accordance with Article 14d of the Sanctions Act, the addressees of the fresh obligations to paper the origin of timber and timber products are exclusively operators importing these goods from countries at hazard of participating in the circumvention of sanctions. In practice, peculiar risks arise from the import of birch plywood.
‘The Ministry of Finance indicates that regardless of the imported product as countries afraid by the hazard of circumvention, Kazakhstan, Kyrgyzstan and Armenia, which together with Russia and Belarus belong to the Eurasian economical Union, should be considered. This is in line with the guidelines of the European Commission. In addition, on the basis of the analysis of the flows of circumstantial commodities, MF has recognised China and Turkey as hazard countries for the supply of birch plywood, which is besides confirmed by the latest Communication from the European Commission. On the another hand, the Ministry listed Vietnam, Malaysia and Ukraine (excluding Russia's occupied areas) among countries not at hazard of circumventing sanctions.’ – explains Magdalena Chmielewski-Cholewa, partner at KDCP Chancellery, technological editor and co-author of the publication "Commercial sanctions in practice. Restrictions on trade with Russia and BelarusIt’s okay. ”
The discrimination between birch plywood and another wood products is crucial in that if there are concerns about circumventing sanctions with countries specified as China and Turkey, so in the case of plywood from another wood species, which have been bred practically always since in those countries, this hazard is marginal.
"The Ministry of Finance, which in consequence to business questions recommended the enforcement of fresh responsibilities in an appropriate way to the problem, deserves large approval. The indication that the request to paper origin from China or Turkey is to be precise in birch plywood shows applicable recognition of the subject and prevents the imposition of excessive formal obligations where this would not actually contribute to anti-abuse, but would only make unnecessary burdens on the part of importers and customs authorities." – comments Magdalena Chmielewski-Cholev.
In the light of the Communication from the European Commission, as well as the amendment of the Polish Sanctions Act, companies must adapt their import strategies and supplier verification processes. fresh regulations and EU guidelines require companies to adapt their operational strategies quickly.
"It should be agreed that, in principle, it is essential to seal all sanctioning provisions, due to the fact that from reports we know that sanctions are effectively circumvented in any cases. On the another hand, it should be said that sealing requirements are undoubtedly a major bureaucratic burden for all entities suspected by the Polish customs and taxation authorities of participating (intended or not) in the celebration of sanctions. But this besides applies to another industries. Therefore, the only thing the business community should reasonably request is that control authorities implement only the procedures and requirements that are indeed essential to prove the origin of the controlled product" – says Witold Michałek, vice president of BCC, BCC expert on economy, government and lobbying.
Full and Partners Agency
