Guidance

Framework for evaluating Category B evidence (5th edition)

Updated 26 November 2025

1. Purpose

This guidance document provides practical advice to direct and indirect suppliers to the UK government on how to demonstrate compliance, other than through Category A evidence, with the criteria set out in the UK government’s Timber Procurement Policy Definition of Legal and Sustainable and introduces the concept of Category B evidence. The Framework presents 2 Checklists which suppliers should use when submitting Category B evidence of legal and sustainable evidence for a UK government supply, including:

• Checklist 1 – supply chain information (confirming which forests the product originates from)
• Checklist 2 – forest source information for sustainability (confirming the forests of harvest meet the criteria for Sustainable)

This document should be used in conjunction with 3 other documents:

• Timber Procurement Advice Note
• Practical guide to forest source information
• Practical guide to supply chain information

This Category B Framework may be a useful reference document for public procurement experts. Step-by-step guidance on how to assess Category A evidence is provided in the Checklist for checking category A evidence.

2. Introduction to the framework

2.1 The UK government TPP requirements

Only timber and wood-derived products originating from an independently verifiable legal and sustainable source (which can include from a licensed Forest Law Enforcement, Governance and Trade (FLEGT) partner) will be demanded for use on the government estate – appropriate documentation will be required to prove it.

As an alternative to demanding timber and wood-derived products from a legal and sustainable source, Contracting Authorities can demand ‘recycled’ timber. The Government Buying Standards (GBS) set out easy to use product specifications for public procurers across a range of sectors including construction, furniture and paper and require timber and wood derived products to be purchased in accordance with the TPP. In developing the GBS, resource efficiency including quantities of scarce materials used and recycled content is carefully considered and recycled content encouraged.

If requested by Contracting Authorities, contractors are required to provide evidence that their timber and wood-derived products comply with the technical specifications. If requested by the Government Authority, independent verification that the contract requirements are met must be provided.

The provision of evidence is based on meeting the government’s definitions for ‘legal’ and ‘sustainable’.

Two types of evidence are accepted:

1. Contractors can choose to use forest certification schemes (Category A evidence). A list of assessed certification schemes that currently meet the government’s requirements can also be found at Timber Procurement Policy (TPP): prove legality and sustainability, and a practical guide to checking certificate validity can be found at Checklist for checking Category A evidence. Acceptable schemes must ensure that at least 70% (by volume or weight) is from a sustainable source.

2. Alternatively, contractors can choose to use some other sufficiently robust form of assurance (Category B evidence) that the source is sustainable. Sources can be accepted provided that at least 70% (by volume or weight) is from a sustainable source.

2.2 The TPP and the UK Timber Regulations (UKTR)

This section provides general information only about how the UKTR relates to the TPP. The contents of this document and any attachments (“information”) are provided to the intended recipient for general information purposes and are not intended as a substitute for obtaining advice from a lawyer, accountant or other professional advisor. While we believe the information provided is accurate at the date of writing, it is provided on an “as is” basis without any representations or warranties as to its accuracy, suitability for any particular purpose or use as the basis of making any decision. To the fullest extent permitted by law we exclude all liability to you or any third party in respect of any reliance placed in, or other use made, of such information.

Within the UK government’s TPP, ‘legal’ sources are defined as “harvested in accordance with the applicable legislation in the country of harvest”. This definition is the same as given in the UKTR.

Evidence related to both management of the forest and the chain of custody is required under the TPP, using Category A or Category B evidence. Both categories require equally credible evidence of legality (as well as sustainability).

However, the UKTR requires that operators exercise due diligence when placing timber or timber products on the market, and the due diligence system must include a risk assessment. Except in cases where the risk identified in the risk assessment is negligible, risk mitigation procedures must be carried out to minimise the risk. Where a product is within the scope of the UKTR, the intent of the TPP in combatting illegal logging may be achieved through compliance with the UKTR.

2.2.1. Products within the scope of the UKTR

Contracting Authorities should remind Contractors of the importance of complying with all relevant legal requirements, including the UKTR.

The requirement for contractors to supply evidence of timber and wood derived products from a sustainable forest source also remains.

2.2.2. Who can help me comply with the UKTR?

As mentioned above, where timber and wood-derived products are covered by the UKTR, suppliers and Contracting Authorities must ensure their own compliance. You can find guidance on compliance at Regulations: timber and FLEGT licences. The UK enforcement authority, the Office for Products and Safety Standards (OPSS) can be contacted for further information at OPSS.enquiries@businessandtrade.gov.uk.

Contractors might also consider contacting their trade association who may be able to offer support and advice.

2.2.3. Products outside the scope of the UKTR

It should be noted that recycled timber and timber products are excluded from the scope of the UKTR, in order to encourage the use of such products.

For government procurement the most significant products outside of UKTR scope include seats (for example, office chairs and sofas), printed brochures, calendars, pencils and fencing panels. These product types may be processed in other countries where there is a variable risk of using potentially illegally harvested wood.

It is possible that the product scope of the UKTR may be expanded, in line with an acknowledgement made in the European Commission’s review of the EUTR, published 18th February 2016 (when the UK was part of the European Union). It was acknowledged that some stakeholders considered product coverage to be incomplete, and the Commission indicated that, subject to an impact assessment of the various available options, the product scope may be expanded.

Note that the EUTR will be repealed when the EU Regulation on deforestation-free products (or EU Deforestation Regulation – EUDR) enters into application. The EUDR includes timber products within its scope. For timber products produced before the entry into force of the EUDR on 29 June 2023, the EUTR will continue to apply until 31 December 2027. For other timber products produced after entry into force of the EUDR, the EUTR will be repealed when the EUDR enters into application. As of January 2025, this is scheduled to be on 30 December 2025 for large and medium companies and 30 June 2026 for micro and small enterprises.

2.2.4. Recommendations for products with Category B evidence

Where possible for seats and paper products the relevant Government Buying Standard should be followed. This includes working to maximise the reuse of products, or the proportion of recycled material used.

For products that are outside the scope of the UKTR, Contracting Authorities should remind Contractors that they must be able to provide evidence of legality (as well as sustainability) on request.

Where reuse or the use of recycled material cannot be achieved, for products with potentially complex supply chains such as seats, printed brochures, calendars, pencils and fencing panels, Contracting Authorities may wish to ask for independent third party verification of the forest source. Some Contractors may decide in this situation to source products with Category A evidence instead.

3. Assessment of Category B evidence

Category B evidence is all forms of credible evidence other than certification schemes. This type of evidence can vary greatly and needs to be judged on a case-by-case basis. This framework has been developed to provide support to both procurement staff and suppliers on the provision and assessment of Category B evidence.

The framework for assessing Category B evidence is in four parts, each of which is discussed below:

• section 4: Criteria for evaluating supply chain management requirements
• section 5: Criteria for evaluating forest management requirements
• section 6: Checklists for submitting Category B evidence
• section 7: Guidance documents

The criteria for assessing evidence are presented in sections 4 and 5. These outline the main factors that determine the adequacy of category B evidence, namely:

1. The requirements for information and evidence to demonstrate supply chain management which provides traceability from the forest source to the point of supply.
2. The requirements for information and evidence to demonstrate that forest management meets UK government requirements for sustainability.

Compliance with each criterion will be assessed as either ‘adequate’ or ‘not adequate’. Existing programmes and ad hoc evidence must achieve adequate compliance with every criterion in order to be acceptable.

Checklists have been developed to assist suppliers in providing all the information required in a format which can be systematically and consistently assessed by procurement staff.

Two checklists are provided:

• Checklist 1 – supply chain information
• Checklist 2 – forest source information for sustainability

Practical guides have been developed to provide background information to help both suppliers and procurement officers.

Two practical guides are available:

• TPP practical guides: Category B evidence, supply chain information
• TPP practical guides: Category B evidence, forest source information

4. Criteria for evaluating supply chain management requirements

Information on the supply chain should normally be supplied by completing Checklist 1 – supply chain information for each type of timber or wood product supplied. The criteria below relate to the information provided in the checklist.

TPP practical guides: Category B evidence, supply chain information provides detailed guidance on how to complete Checklist 1.

4.1 Guidance on interpretation

Criterion 1.1: Is the supply chain clearly described and complete from point of supply back to the forest source(s)?

Each stage in the supply chain from the forest source(s) through transport and processing needs to be included for each product being supplied.

If the project includes a number of different products (for example, flooring, window frames and construction timber) information is needed for each product.

If the product is a composite (for example, a cupboard mainly made of plywood with a solid timber door) the supply chain details must be provided for each component.

Criterion 1.2: Has an adequate mechanism for preventing uncontrolled mixing or substitution been described for each stage in the supply chain?

For each stage in the chain, it needs to be clear what controls are in place to make sure that there is no mixing or substitution – accidental or intentional – with material from other sources. There are a range of different mechanisms which may be used.

Criterion 1.3: Has information been provided on how the mechanisms in 1.2 are checked/verified and is the approach used adequate to confirm the mechanisms described are in place and functional?

For each stage it must be clear how the information on control has been verified. This might include a range of different approaches such as:

• statements from the organisation implementing the control (1st party checks)
• checks made by the supplier to government of their suppliers (2nd party verification)
• verification by an independent third party (3rd party audits)

Criterion 1.4: Is the evidence provided or available adequate to confirm information provided is accurate?

Suppliers can either supply copies of evidence, or describe where it is available.

Evidence provided might include:

• supplier declarations
• 2nd party verification reports
• 3rd party audit reports

Information on the location of important documents and how long they are kept.

All documents provided as evidence must be in English or with an English translation of relevant parts.

If there is any concern about the adequacy, robustness or veracity of the evidence provided then independent verification of the evidence will be required by the Government Authority. In these instances, independent verification must be undertaken by an individual or body whose organisation, systems and procedures conform to international standard ISO/IEC 17065:2012 or equivalent and who is accredited to audit against timber production standards by a national or international body whose organisation, systems and procedures conform to ISO/IEC17011:2017 or equivalent.

5. Criteria for evaluating forest management requirements

5.1 Introducing the requirements

Information on the forest source should normally be supplied by completing Checklist 2 – forest source information for sustainability for each type of timber or wood product supplied. Guidance on how to complete the checklist is provided below. Information on TPP compliance is also set out for Contracting Authorities and Contractors with products outside of the scope of the UKTR and where no evidence of sustainable source is available.

5.2 Guidance on criteria

The criteria below relate to the information provided in the checklist. TPP practical guides: Category B evidence, forest source information provides detailed guidance on how to complete Checklist 2.

5.3 Guidance on interpretation

Criterion 2.1: Is the information provided on the location of the forest source adequate?

The information provided about the supply chain should include the location of the forest or forests where the timber originated. The adequacy of the evidence provided should be assessed as part of the supply chain evaluation. This section deals with the level of detail.

For claims of sustainable sourcing, the information provided must be the forest management unit or units from which the timber was sourced.

Criterion 2.2: Is the information provided on the location of the forest source adequate? Has information on compliance been provided for each criterion in the relevant checklist?

For claims of sustainability, Checklist 2 must be completed for each forest source.

Criterion 2.3: Has information been provided on how compliance is checked/verified and is the approach used adequate to confirm the criteria are being met?

Mechanisms might include:

• 1st party checks
• 2nd party verification
• 3rd party audits

External programmes providing forest management support.

The type of mechanism which will be appropriate will depend on the type and location of the forest or forests or origin.

Criterion 2.4: Is evidence supplied or available to support the information provided and is it adequate?

This might include:

• supplier declarations
• 2nd party verification reports
• 3rd party audit reports

Supporting documentation may include official documentation such as permits or company documentation, but should not be provided without an accompanying Checklist.

All documents must be in English or with an English translation of relevant parts.

If there is any concern about the adequacy, robustness or veracity of the evidence provided then independent verification of the evidence will be required by the Government Authority. In these instances, independent verification must be undertaken by an individual or body whose organisation, systems and procedures conform to international standard ISO/IEC 17065:2012 or equivalent and who is accredited to audit against timber production standards by a national or international body whose organisation, systems and procedures conform to ISO/IEC17011:2017 or equivalent.