Publication date: 14 July 2025

Combatting illegal logging

We are now over four months into Australia's reformed illegal logging laws (Illegal Logging Prohibition Act 2012 (Act) and the Illegal Logging Prohibition Rules 2024 (Rules)) that came into effect early this year. A reminder that the department offers a range of guidance and resources on our website to help you understand your due diligence obligations.

As part of our continued education and guidance efforts during this early implementation period, we have outlined below some common scenarios relating to non-compliance with the laws.

We encourage all regulated entities to review their systems and practices against these points to ensure they are meeting their obligations under the reforms.

Common contraventions

• Due Diligence System (DDS) issues 
  Some entities are found to have either have no DDS in place, are relying upon a Chain of Custody manual or are using a DDS that is inadequate. You must have a DDS system in place before importing regulated timber products or processing a raw log that sets out how the due diligence requirements of the Rules will be met.
• Requirement for information and documents (RFID) notice issues
  Failure to respond to a RFID notice or to provide the information and documents requested in the notice. Please be aware that the department send notices via registered post and email, using the contact details listed in the Australian Business Register.
• Information gathering issues
  Failure to collect all the required information before importing or processing their product/s, or reliance upon confirmation statements that information previously provided has not changed. If certain information cannot be obtained, the importer or processor must keep records that demonstrate that the information was not reasonably practicable to obtain. Information gathering is required to be undertaken upon each instance of importation/raw log processing.
• Risk assessment issues 
  Failure to undertake adequate risk assessments. The department is finding that some risk assessments are being undertaken against a supplier and/or do not consider all of the prescribed risk factors. Risk assessments must be undertaken on the specific product/s being imported/raw logs processed and written records must be kept that demonstrate the assessment occurred before import/raw log processing.
• Risk factor issues 
  Failure to undertake adequate research to fully evaluate associated risk factors. You must consider all relevant risk factors and conduct additional research where necessary when determining the risk of your product/s being illegally logged. Your written risk assessment must demonstrate that all of the prescribed risk factors have been considered to a reasonable standard.
• Exception operation
  There is misunderstanding about the risk assessment exception. The exception does not apply to information gathering or determining that the product or raw log is certified. It also cannot be applied to part of or a component of a product. If any information about the product/raw log has changed, then the whole product/raw log is no longer eligible for the exception pathway.
• Certified products/logs
  When undertaking due diligence on certified product/s, common issues include: 

1.     not downloading/using the PEFC/FSC database to obtain the timestamped record

2.     failing to assess certification in accordance with the CoC framework

3.     assuming supplier certification automatically means product/raw log certification 

4.     relying on incomplete or out-of-scope sales/delivery records or nil certification claims.

You must verify the certification per the Rules for each import/processing. Please also be mindful that you cannot use certification as the sole indicator of timber legality.

• Retrospectively created or altered documents
  Please do not create or alter any documents (e.g. risk assessment records, DDS, database downloads with removed timestamps) after importing/processing or after receiving a RFID. This breaches our illegal logging legislation and may constitute providing false or misleading information under the Act and the Criminal Code Act 1995 (e.g. forgery). If you are unsure, please reach out to the department.

For assistance or further information, please visit our Illegal Logging Compliance webpage or contact us directly at illegallogging@aff.gov.au.

Help us spread the word! Please share our illegal logging subscription details with those you think would benefit.

Further information

• See the department's illegal logging website for information and resources
• Email the department's compliance branch
• Call the department during business hours (8.30 am to 5.30 pm) on 1800 657 313 or +61 2 6272 3933 outside Australia