Is the ban leaking? Birch plywood after the EU's Nov-2021 duty and Jul-2022 embargo on Russia

Trade-flow companion to the price wedge (R72). DUAL-SCORE / alternative-track — never folded into any Tier-1 exposure score. The wedge measures scarcity; this desk measures the other half: is the control actually holding, or is the restricted trade re-entering the buyer by another door? Research, not investment advice. Circumvention is INFERRED from the structure of the flows plus public regulatory records, never asserted as evasion of any particular consignment — except where a regulator has already adjudicated it, which on this route it has.

Verdict

Between 2019 and 2021 Russia shipped the EU 710,807 → 800,396 tonnes of plywood a year on the tariff line that contains birch. Kazakhstan and Georgia shipped nothing at all — not a small number, no rows in Eurostat Comext. By 2025 the Russian line reads 65 tonnes, 0.008% of its 2021 level, and Kazakhstan, Georgia, Türkiye, China and Uzbekistan between them hold 43% of what the EU still buys from outside the bloc.

This case earns its place in the corpus for three reasons, none of them about wood.

One: it is the corpus's second externally-graded detector result, and the first where a single instrument convicts *both* modes at once. Commission Implementing Regulation (EU) 2024/1287 (13 May 2024) found the same flow to be simultaneously mode A (transhipment of Russian plywood through intermediaries) and mode C⁻ (assembly/completion from Russian logs and veneer that fails the Article 13(2) substantial-processing tests). Every prior row in the register had to pick one. The regulator did not have to pick, and neither should the detector.

Two: the Commission published the volume-implausibility test as a number, using its own capacity estimate as the denominator. Recital (56): EU-bound shipments in the reporting period exceeded domestic production in both countries — Türkiye shipped 33,832 m³ against production of 17–20 thousand m³ (169–199% of what it could make), Kazakhstan 97,068 m³ against ~69 thousand m³ (141%). That is Layer 1 of this desk's detector, computed by a regulator, on a route the detector was not fitted to.

Three: the flow moved to a country nobody charged, exactly as the hardwood-plywood case predicted it would. Georgia went from 0 → 20,527 t of EU-bound birch plywood while charged Kazakhstan fell −73% from its peak. The petition-perimeter rule — the enforcement perimeter is set by who a petitioner names, not by where the detector points — was written from a US Commerce proceeding on a different commodity in a different decade. It reproduced here, out of sample, in a different jurisdiction, under a different legal instrument.

The control — four instruments, three of them dated after the leak started

One detail in 2024/1287's footnote 4 is a detector finding in its own right: birch plywood sat inside the undifferentiated CN 4412 33 00 until 1 Jan 2022, when it got TARIC code 4412 33 10 10, and from 1 Sep 2022 its own CN8 line 4412 33 10. The EU cut a dedicated tariff line for the controlled good two months after imposing the duty. A new tariff split is an announcement-time signal — it is a regulator telling you it intends to watch a flow it previously could not see. It also means any pre-2022 comparison on this route is a code-change comparison, not a like-for-like one, and is labelled as such below.

Layer 1 — the buyer line (Eurostat Comext, EU-27 imports, tonnes)

Source: Eurostat Comext dataset DS-045409 ("EU trade since 1988 by HS2-4-6 and CN8"), reporter EU27_2020, flow 1 (import), indicator QUANTITY_IN_100KG, converted to tonnes. Free, no key. Query form: https://ec.europa.eu/eurostat/api/comext/dissemination/statistics/1.0/data/DS-045409?format=JSON&freq=A&reporter=EU27_2020&partner=<ISO>&product=<CN8>&flow=1&indicators=QUANTITY_IN_100KG&time=<year>

Pre-control baseline — CN 4412 33 00 (broader: all plywood ≤6 mm plies with a non-coniferous, non-tropical outer ply. Birch is not separable at this code):

— means no rows returned, i.e. Comext reports no trade, not a small or suppressed number. Kazakhstan and Georgia shipped the EU nothing on the broader code, which is the strongest form the implausibility test can take: they cannot have been quietly present under a category that also contains everything else.

Post-control — CN 4412 33 10 (birch-specific, from 1 Sep 2022):

Read the 2021→2022 Russia step as a code change plus a half-year of embargo, not as a clean −48%: 800,396 t is all non-tropical plywood for a full year, 417,648 t is birch only across a year whose second half was prohibited. The step that is clean is 2022→2023: 417,648 → 95 tonnes. The direct door shut.

Ukraine is the honest headline and is not laundering. At 46.2% of extra-EU birch plywood in 2025 it is now the EU's largest outside source, and Ukraine is a genuine large-scale birch producer whose line was already 76–89 kt/yr before any control. That is substitution by a real producer, and it is what a control working as intended looks like. The signal is in the countries whose baseline was zero.

The same test, adjudicated (Commission Impl. Reg. 2024/1287, Table 1, m³)

The Commission's own reconstruction, using a different dataset and a reporting period running 1 Jul 2022 – 30 Jun 2023 ("RP"), is an independent check on the table above:

Different units, different period boundaries, same shape — and Comext's calendar-2023 Kazakh figure (94,985 t) lands within 3% of the Commission's RP figure (97,068 m³) by coincidence of density, which is not a validation and should not be read as one. The validation is directional: two independent reconstructions both show a zero baseline becoming a top-three origin in eighteen months.

Recital (43), verbatim in substance: imports from Kazakhstan started in April 2022 — five months after the duty, three months before the embargo. Recital (61) turns that into the causal finding: the change of pattern predates the sanctions, so sanctions cannot be its explanation.

Layer 1b — the input line (UN Comtrade mirror, tonnes)

The mode-C diagnostic: read what goes into the surger, not what comes out. Because Russia suspended customs publication in Apr-2022, every Russian figure below is mirror data — the partner's reported imports from Russia. Source: UN Comtrade free public preview API (comtradeapi.un.org/public/v1/preview/C/A/HS), annual, HS.

Kazakhstan's purchases from Russia vs. its EU-bound shipments:

In 2023 Kazakhstan bought from Russia almost exactly what it sold the EU. The veneer line is the assembly tell: 267 → 8,523 → 10,050 t, a 38× step in one year, which is what a completion operation looks like in customs data as distinct from pure relabelling. Both are present, which is why the Commission charged both.

Georgia — the door nobody closed:

Georgia's purchases of Russian plywood rose 36× off a 604 t base, and by 2025 its EU-bound birch shipments are 107% covered by Russian-origin purchases alone — before counting any logs or veneer. Georgia was named in neither 2023/1649 nor 2024/1287.

China — the largest surger, closed by an unrelated instrument:

China is a genuine plywood producer at enormous scale, so the ~0%-capacity test is defeated lawfully here, exactly as it was for Singapore on semiconductor equipment. The ratio above is therefore a sufficiency statement and nothing more: China imported enough Russian birch plywood in 2024 to cover its entire EU-bound birch line twice over. It does not establish that those molecules are the same molecules, and no free dataset can.

Layer 2 — the ownership tell: Y, adjudicated, counterparty unnamed

Nine companies filed exemption claims — five in Kazakhstan (Favorit LLP, QazFanCom LLP, Semipalatinsk Wood Processing LLP, Severnyi Fanernyi Kombinat LLP, VFP LLP) and four in Türkiye (Intur Construction Tourism and Forest, Murat Şahin Orman Ürünleri, Petek Kontrplak San ve Tic A.Ş., Saglamlar Orman Tarim Urunleri San. Ve. Tic. AS.). Five filed so deficiently that the Commission applied facts-available under Article 18. Of the four actually assessed — three Kazakh, one Turkish — all four exemption requests were rejected (recital 215).

What the record establishes, hop by hop:

• An unreported Russian related party. Recital (146): at verification, Severnyi

Fanernyi Kombinat LLP "did not report its related company in Russia. The company was reported as an unrelated log supplier." No questionnaire was filed for it. The Commission further found SFK had misreported the origin of Russian logs as Kazakh in sampled transactions, and treated this as supplying false and misleading information that significantly impeded the investigation.

• Money moving beyond the goods. Recital (149): SFK's accounts with the related

company showed "financial transactions beyond the log purchases," explained by the company as advance payments and not verifiable.

• A related importer inside the EU, incorporated to catch the flow. Recital (61):

SFK "set up a related importer in the Union in April 2022" — five months after the duty, three months before the embargo. The chain was built for the duty, not the sanctions.

• Links asserted at country level. Recital (58): in Kazakhstan, circumvention "was

facilitated by the geographical proximity to Russia, and the fact that companies had links to Russian producers of birch plywood or of the input materials."

• Certificates of origin as a traded commodity. Same recital: Kazakh certificates

of origin were, according to two exporting producers, "traded and misused" for plywood of Russian origin. This is a distinct and transferable tell — the laundering input is not the material, it is the paperwork, and it has a market.

Labelled gap: the public text of 2024/1287 never names SFK's Russian related company, and no free corporate registry search performed for this case resolved it. The ownership hop is established by the regulator, not by us, and one end of it is redacted. That is materially weaker than the antimony chain (Guangxi Youngsun → Thai Unipet → Youngsun & Essen), where every node has a name. It is recorded as Y — adjudicated, counterparty unnamed, and should never be quoted as a named chain.

The Article 13(2) arithmetic, on a named company

The one Turkish producer that cooperated fully, Intur Construction Tourism and Forest, supplies the case's only fully quantified transformation test (recitals 206–214):

• Birch veneer, its main input, was all purchased from Russia;
• Over 75% of total input-material value was Russian → the 60% parts-value

threshold of Art. 13(2)(b) is met;

• Value added during the operation was below 25% of manufacturing cost → the

second limb is met;

• Exports to the EU: nil in 2019, [2,000–3,000] m³ in the RP, undercutting Union

prices by more than 37%.

That is mode C⁻ stated as a number, on a named legal entity, by the authority with subpoena power — the thing this desk can normally only estimate.

Did it work? Yes, on the two doors that were charged

Retroactive collection to the 21 Aug 2023 registration date is what gives the Kazakh and Turkish numbers their bite: an importer who kept shipping through the investigation owed duty on everything already landed. Charged doors close. The uncharged door is the only line still rising.

The China column carries a rule the corpus did not have: a door can be closed by an instrument that was never aimed at it. China was never a respondent in the birch anti-circumvention case. What hit it was an ordinary Article 5 dumping proceeding on hardwood plywood — initiated 11 Oct 2024 on a complaint from the Greenwood Consortium, provisional duty from 10 Jun 2025 (Reg. (EU) 2025/1139), definitive 86.8% for all other companies (43.3% for Pizhou Jiangshan Wood Co., Ltd) from 20 Nov 2025 (Reg. (EU) 2025/2333) — whose product scope expressly covers CN 4412 33 10, the birch line. China's EU-bound birch shipments fell −68% across 2025, consistent with the provisional duty landing mid-year. For a buyer running an origin screen, this is the awkward implication: the instrument that closes your exposure may be filed by a different petitioner, on a different product definition, in a different proceeding. Screening by proceeding misses it; screening by tariff line catches it.

Transmission chain

`` Russian birch (logs / veneer / finished panels) │ ├─ 2019–2021: direct to EU, 710–800 kt/yr, 44–52% of the EU's outside supply │ ├─ 9 Nov 2021 AD duty 15.8% ─────────────┐ ├─ 10 Jul 2022 import ban (Annex XXI) ────┤ direct line → 95 t by 2023 │ │ ├─ Apr 2022 ▸ KAZAKHSTAN ──────────────────┤ mode A: transhipment via intermediaries, │ (zero baseline; certificates of │ mixed with local product │ origin traded; SFK's Russian │ mode C⁻: assembly from Russian logs │ parent reported as "unrelated") │ + veneer, 60%/25% tests failed │ │ → CHARGED 13 May 2024, −73% from peak ├─ 2022 ▸ TÜRKIYE ─────────────────────────┤ Intur: 100% Russian veneer, │ │ >75% input value, <25% value added │ │ → CHARGED 13 May 2024, −36% ├─ 2022 ▸ CHINA ───────────────────────────┤ genuine producer; 197% sufficiency 2024 │ │ → closed by an UNRELATED AD case, −68% └─ 2023 ▸ GEORGIA, UZBEKISTAN ─────────────┘ zero baseline; 107% sufficiency 2025 → NEVER CHARGED; Georgia still rising ↓ EU buyer books "origin: Georgia" ``

What this means for the Tier-1 blind spot

A Tier-1 exposure score built on declared country-of-origin would have recorded, for a 2023-vintage EU plywood buyer, zero Russia exposure and a diversified Central Asian supply base. The register's Layer-1 test flags the zero-baseline surge; the regulator's own capacity arithmetic converts it to a finding; Layer 2 supplies the mechanism. None of that reaches the Tier-1 score and none of it should — the divergence between the two is the product.

Three rules generalise off this route:

1. A new tariff split is an announcement-time signal. The EU carved birch out of CN 4412 33 00 on 1 Jan 2022, two months after the duty. When a regulator creates a line, it has decided to watch a flow — and it has simultaneously created the dataset that makes the flow auditable by anyone. Watch the CN/HS amendment calendar, not just the sanctions calendar. 2. The paperwork is the laundering input. "Certificates of origin were traded and misused" describes a market in documents, not in goods. No volume test detects a forged certificate on a genuine consignment; only the input-line ratio does, and only in aggregate. 3. The perimeter lags the flow by one hop, in every jurisdiction. The petition-perimeter rule was derived from US Commerce practice on Chinese hardwood plywood. It holds identically under EU Article 13, where the applicant (the Woodstock Consortium) named Kazakhstan and Türkiye and the Commission investigated Kazakhstan and Türkiye. Georgia's ratio was as high or higher and Georgia was not in the request. For a buyer, the corollary is unchanged and counter-intuitive: a newly-charged origin is the safest origin.

Caveats — read these before quoting anything above

• Inference, not proof, except where marked. The Kazakh and Turkish findings are

adjudicated by the European Commission. The Georgia and China findings are ours, unadjudicated, and are sufficiency ratios — they establish that enough Russian-origin material entered those countries to account for their EU-bound shipments, not that any particular consignment was Russian. No individual shipment, importer or exporter named here is asserted to have broken any law beyond what a regulator has already found.

• Code-change discontinuity. 2019–2021 figures are CN 4412 33 00, which contains

birch plus other non-tropical species; 2022–2025 figures are CN 4412 33 10, birch only. The two blocks are not a continuous series and the Russia 2021→2022 step must not be quoted as a percentage move.

• The input line is an upper bound. Comtrade codes 441233 / 440395 / 440396 /

440890 are HS6 and cannot isolate birch. Every "Russian input" figure is therefore larger than the true birch flow, which biases every sufficiency ratio upward. Ratios near 100% should be read as "of the same order," not as a tight fit.

• Mirror data throughout. Russia stopped publishing customs data in Apr-2022;

every Russian figure post-2021 is a partner's reported import.

• Two aggregates in the source data are internally inconsistent and are not used

above: Georgia's reported world-total 441233 imports (16,683 t in 2023) are below its reported imports from Russia alone (19,856 t), and Türkiye's 2025 world total reads 0 against 69,113 t from Russia. Where the WORLD row contradicts the RU row we quote the RU row and flag it; Türkiye's input line is not reconstructable from mirror data at all, which is why Türkiye's input figures here come from the Commission's Table 3 rather than from Comtrade.

• The Commission's Tables 1–3 cite Comext and Global Trade Atlas. GTA is a

subscription dataset; it is quoted here only as it appears inside the published Regulation, which is a primary legal source. No subscription data was accessed.

• One ownership node is redacted. SFK's Russian related company is established by

the Commission but unnamed in the public text. Do not infer a name.

• Register-state, not world-state. The four birch-plywood instruments

(2021/1930, 2022/576, 2023/1649, 2024/1287) and the two China plywood instruments (2025/1139, 2025/2333) are cited directly from EUR-Lex and are not rows in the IPTM register. This case is anchored to the nearest filed EU–Russia instrument; their absence from the register means "not tracked," not "does not exist."

• 2025 Comext data was retrieved from a dataset last updated 2026-08-14 and is

treated as complete; if Eurostat revises 2025 the Georgia trend line should be re-checked before it is quoted.

Sources

• Commission Implementing Regulation (EU) 2021/1930 of 9 Nov 2021 — definitive AD duty, birch plywood from Russia. <http://data.europa.eu/eli/reg_impl/2021/1930/oj>
• Council Regulation (EU) 2022/576 of 8 Apr 2022, Annex XXI — import ban on Russian wood. <http://data.europa.eu/eli/reg/2022/576/oj>
• Commission Implementing Regulation (EU) 2023/1649 of 21 Aug 2023 — initiation + registration. <https://eur-lex.europa.eu/eli/reg_impl/2023/1649/oj/eng>
• Commission Implementing Regulation (EU) 2024/1287 of 13 May 2024 — extension to Kazakhstan and Türkiye; recitals 40–71, 90–93, 146–151, 206–215; Tables 1–3. <http://data.europa.eu/eli/reg_impl/2024/1287/oj>
• Commission Implementing Regulation (EU) 2025/1139 of 10 Jun 2025 — provisional AD duty, hardwood plywood from China.
• Commission Implementing Regulation (EU) 2025/2333 of 19 Nov 2025 — definitive AD duty 86.8% / 43.3%, hardwood plywood from China; scope covers CN 4412 33 10. <http://data.europa.eu/eli/reg_impl/2025/2333/oj>
• Eurostat Comext DS-045409, reporter EU27_2020, products 44123300 / 44123310, flow 1, indicator QUANTITY_IN_100KG, 2019–2025. Free API, query form given above.
• UN Comtrade free public preview API, annual HS, reporters Kazakhstan (398), Türkiye (792), China (156), Georgia (268); commodities 441233, 440395, 440396, 440890; flow M. Committed artifact for the KZ/TR/CN legs: data/intelligence/birch-plywood-circumvention.json (fetcher: scripts/py/iptm/fetch_birch_plywood_circumvention.py). The Georgia leg and the Comext series in this case were pulled ad hoc and are not yet in that artifact.