No illegal tropical timber for the German navy!

Myanmar: logs on trucks Logs on trucks in Myanmar (© EIAimage)
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The German navy is currently refurbishing its iconic tall ship, the Gorch Fock – teak from Myanmar is to be used as deck planking, even though the timber was sourced from illegal rainforest clear-cutting. This is a clear violation of the law, yet the German government sees no cause for action.

Call to action

To: The German federal government: ministries of defense, agriculture and the environment

“The German navy is refurbishing the Gorch Fock with teak from rainforest clear-cutting. The German government must enforce its laws on timber imports strictly.”

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According to investigations by the World Wildlife Fund (WWF) and the German public broadcaster ARD, several tons of teak sourced from illegal rainforest clearing were purchased for the German navy. The timber is intended as deck planking for its flagship, the Gorch Fock, a sailing ship used for officer training. The tall ship is currently being refurbished for €135 million.

The reactions of the Ministry of Defense to the accusations were sadly revealing: First it claimed that the teak was legally sourced from plantations, and that the relevant laws had been meticulously observed when importing the timber.

Later it conceded that it is virtually impossible to import timber legally from Myanmar, which means that the teak came from illegal deforestation.

Finally, the ministry stated that the timber had already been delivered, and so it might as well be used to refurbish the Gorch Fock. The authorities do not intend to confiscate the timber and prosecute those responsible.

The German government is thus blatantly violating the European Union Timber Regulation (EUTR) and the German Timber Trade Safeguards Act, under which importing timber from illegal sources is a criminal act. Furthermore, the German government’s procurement regulations state that German authorities may only use wood that has been certified as sustainably produced.

Please speak out to ensure that the freshly refurbished pride of the German navy and Germany’s ambassador on the world’s oceans does not set sail with illegal tropical timber in its decks, and that those responsible are prosecuted.

Germany likes to cast itself as an environmental leader, so tell the government to enforce the laws it currently has on the books. Let’s make sure that illegal timber disappears from the market – not only on paper, but also in practice.


Illegal timber – a billion-dollar business

In its study Green Carbon, Black Trade: Illegal Logging, Tax Fraud and Laundering in the World’s Tropical Forests, the international police organization Interpol estimates that 15 to 30 percent of the timber on the world market is logged illegally. In some countries, including Myanmar, Indonesia, the Democratic Republic of Congo and Brazil, the share is much higher, ranging up to 80 percent.

This puts the market value of illegally logged and traded timber at between $30 and $100 billion per year. Organized gangs, corrupt officials and politicians are involved in the worldwide illegal timber business, while international banks help launder the money and move it around the globe.

European Union Timber Regulation (EUTR)

After decades of investigation and documentation work by environmental and human rights organizations, the EU and its member states finally took action against timber trafficking. The EU Timber Regulation (EUTR) came into force on 3 March 2013. In Germany, the Timber Trade Safeguards Act (Holzhandels-Sicherungs-Gesetz) took effect on 11 June 2011.

Due diligence is thus required of companies importing timber and wood products from outside the EU to ensure that the imported goods originate from legitimate sources. The German Agriculture and Nutrition Office (BLE), which is responsible for reviewing the relevant documents, receives support from the customs authorities.

Sluggish implementation and shortcomings

The EU Timber Regulation has numerous shortcomings and omissions, however: many wood products such as charcoal, paper and print products are not covered at all. In addition, the legislation only applies to the first importer into the EU. Once the timber is in the single market, it is not subject to any additional checks. Furthermore, full implementation of the regulation by EU member states is very slow, cooperation between authorities is often lacking, and generally, only a few spot checks are actually made.

According to the BLE, around 27,000 companies imported wood products worth €2.7 billion directly into Germany in 2017 alone. However, only a fraction of the import documents submitted by the companies are checked. According to the BLE, there were a mere 218 audits in 2017, and irregularities were discovered in more than three-quarters of those cases. In addition, half of the companies are insufficiently informed – or completely unaware – of the existing laws on wood imports.

Any administrative offenses found can be subject to fines if they are committed intentionally or negligently. How often and to what extent fines were imposed is not known, however. The risk of being caught importing illegal timber is apparently very low. Penalties are rarely imposed and are negligible compared to the value of timber imports.

Illegal logging is not a trivial offense

The few publicly known cases of illegal timber imports have been uncovered by environmental organizations. In one case – the import of tropical wengé wood from the Congo – the confiscated wood is to be auctioned after years of proceedings. In effect, this amounts to the laundering of illegal goods and dumping them onto the market. The location and time of the auction is being kept under wraps by the authorities to prevent disruptions by environmental activists.

In the case of the luxury yacht “A”, which was built in a German shipyard, the authorities dropped the ball completely. The legal origin of the teak used there could not be documented, yet the ship was launched and is now in operation. By the look of it, the German government intends to proceed in the same way with the Gorch Fock.

Confusion of responsibilities and lack of political will

The German government likes to portray itself as being at the leading edge of global environmental protection. This was also the case in early October at the Thünen Institute in Hamburg, where the simultaneous fifth anniversaries of the European Union Timber Regulation (EUTR) and the Thünen Centre of Competence on the Origin of Timber was celebrated. 

The German Ministry of Agriculture had invited experts from the EU member states, the European Commission and the United States to an international conference on the timber trade and forest conservation on the 8th and 9th of October 2018.

While the implementation in Germany and other EU member states has since made clear progress, the uniform application of the regulations within the EU remains a challenge and leads to distortions of competition, according to one of the conclusions.

In Spain, for example, the responsibility for monitoring timber imports is distributed between the central government in Madrid and the 19 autonomous regional governments – a state of affairs that prompted sighs of exasperation from the conference participants. The German government also seems to lack the political will to actually enforce existing laws, as the case of the Gorch Fock shows.

Questionable reasoning

The German Ministry of Defense and the Agriculture and Nutrition Office (BLE) have been going out of their way to deceive the public with a succession of bogus arguments:

The decision to refurbish the deck of the Gorch Fock is said to have been made in 2016, whereupon the timber was to have been ordered from the timber trade. The teak had allegedly been imported between 2015 and 2017. It was not until 11 June 2018 that the BLE imposed an import ban on teak from Myanmar in a press release.

In actual fact, the EU Timber Regulation (EUTR) came into force on 3 March 2013. The German Timber Trade Safeguards Act (Holzhandels-Sicherungs-Gesetz) had been in effect since 11 June 2011.

The teak supplied came from rainforest logging in Myanmar – not plantations. The lack of legal security of teak imports from Myanmar has been known and documented for many years, making the exact time of logging and import into Germany irrelevant.

In its press release of 11 June 2018, the BLE wrote that:

- according to current findings, it is apparently not possible to import timber from Myanmar into the EU in compliance with EUTR

- none of the documentation submitted to the BLE before the 2016 ban on logging imposed by Myanmar could be deemed satisfactory

- the BLE has no legal information on deliveries of timber harvested after the resumption of logging (from April 2017), and that

- according to a 2013 report by the United Nations Office on Drugs and Crime (UNODC), the proportion of illegally harvested timber in Myanmar is estimated at up to 80 percent; in its most recent report, UNODC speaks of illegal and corrupt structures in timber harvesting and trade in Myanmar.

Further information:

Environmental Investigation Agency: Crime and corruption of Myanmar’s illegal teak trade goes to the heart of government

Environmental Investigation Agency: “Scandalous” – German MP cites Myanmar teak exposé to tackle Navy over using stolen goods

Frontier Myanmar: Myanma Timber Enterprise "not worried" about EIA corruption report

Please also sign our petition speaking out against tropical timber imports from Vietnam


To: The German federal government: ministries of defense, agriculture and the environment

Ladies and Gentlemen,

According to research by the World Wildlife Fund and the German public broadcaster ARD, several tons of teak from apparently illegal rainforest clear-cutting in Myanmar is to be used for refurbish the German navy’s training vessel, the tall ship Gorch Fock.

The German government is thus blatantly violating the European Union Timber Regulation (EUTR) and the German Timber Trade Safeguards Act, under which the import of timber from illegal sources is a criminal act. Furthermore, the German government’s procurement regulations require German authorities to use only sustainably produced wood.

We therefore call on you to:

– confiscate the teak from Myanmar and destroy it, as is customary with trafficked goods

– ensure that the German Agriculture and Nutrition Office (BLE) and customs authorities responsible for checking timber imports are adequately equipped and staffed to check all timber imports and to stop, confiscate and vigorously prosecute unlawful timber imports

– strengthen the Timber Trade Safeguards Act in order to keep the German market free of timber imports from illegal sources.

Yours faithfully,