Following an announcement last year, DEFRA have introduced new regulations for the sale and supply of firewood for domestic use, with effect from 1 May 2021.
The new regulations are aimed at reducing the emissions from the burning of damp wood. A new certification body, “Woodsure Ltd”, has been set up and in future those selling or supplying domestic wood fuel will need to register and also certify that their wood is labelled and has moisture content of below 20%. Small suppliers (less than 600 cubic meters in the year to 1 May 2021) will enjoy a 12-month period of grace before implementation. The rules will apply to:
- Firewood in single retail bags
- Firewood supplied as a bulk delivery in loose volumes of less than 2 cubic metres
- Wood briquettes in single retail bags
- Wood briquettes supplied as a bulk delivery in loose volumes of less than 2 cubic metres
Businesses supplying loads of over 2 cubic meters (a large trailer or tipper load) only need provide customers with appropriate burning advice as follows:
“This wood is not suitable for burning until it has been dried. You should not burn wood until it has a moisture content of 20% or less.
Wet wood contains moisture which creates smoke and harmful particulates when burnt. As well as being harmful to your health and the environment, this can damage your stove and chimney and is an inefficient way to heat your home. Dry it in a sunny, well-aired space for at least two years, keeping rain off in the winter.
Radial cracks and bark that comes off easily suggests wood that is ready for burning. Test the wood when you think it is ready for burning, ideally with a moisture meter. First calibrate the meter and then measure a freshly split surface to get the best reading.”
The registration form runs to four pages and requires the submission of a sample and details of turnover, sources, processes and sales outlets, along with a range of fees which include an initial fee of £122.40 and annual fees of between £519 and £2,833, depending on sales pattern and volume. Enforcement will be applied by local authorities who will be empowered to charge fines of up to £300 with further penalties available through the courts. There will be annual audits, and it seems unlikely that most small scale farm operations will wish to register.
Whilst no doubt well intentioned, it is difficult to see what positive effect the new rules will achieve. Larger scale rural users of firewood will continue to buy their logs, wet or dry, by the tipper load. Smaller and predominantly urban users will continue to buy dry logs from the garage, supermarket of garden centre. It seems that those caught by the changes will be mainly casual users who pick up logs at the farm gate (or whilst out walking) and their contribution to particulate levels are not likely to be national significant.
More to the point, there is a danger that these changes may criminalise unwitting suppliers, who have always sold a few logs from the farm gate, or even those letting holiday cottage who supply “a first basket of logs” free of charge. From a tax and accountancy perspective, from 1 May cash sales of firewood will potentially become “proceeds of crime”.
So, small scale firewood sales are almost entirely in cash. In future advertising may bring in a visit from trading standards officers, and declaring it in the accounts may result in a referral to the National Crime Agency. Most suppliers would probably regard the rules as pointless and irritating. It is hard to think of a better way of encouraging businesses down a slippery slope into the black economy.*The views expressed are the author's and not ICAEW's.