EUDR Timber Traceability and Compliance Data

The EU Deforestation Regulation covers wood and specified derived products listed under Combined Nomenclature and Harmonised System codes in the operative Annex I.

Products in scope include many forms of timber, wood-based panels, pulp, paper, furniture and other wooden articles. Coverage must be checked against the applicable Annex I code rather than assumed from a product’s commercial name or the fact that it contains wood.

EUDR applies from 30 December 2026 to large and medium-sized operators and to micro and small operators already covered by the former EU Timber Regulation. It applies from 30 June 2027 to most other micro and small operators.

Special transitional provisions apply to older timber stocks. The applicable regime can depend on when the timber was harvested or produced, when it was placed on the market and whether the product was covered by the former EU Timber Regulation. Businesses holding timber harvested before 29 June 2023, or products manufactured from older timber, should assess those dates against the specific EUTR-to-EUDR transition rules.

Wood products must not originate from land subject to deforestation after 31 December 2020. For timber, operators must also establish that the wood was harvested without inducing forest degradation as defined by the Regulation. This is a separate timber-specific element of the EUDR deforestation-free test.

A natural disturbance does not, by itself, establish either compliance or non-compliance. Commission guidance recognises that forest land can remain classified as forest where it is temporarily unstocked because of a forest-management practice or natural disaster and is expected to regenerate. Operators should document the previous forest type, disturbance, harvesting activity and expected regeneration so they can demonstrate that the harvesting itself did not induce forest degradation.

Relevant products must also have been produced in accordance with the relevant legislation of the country of production.

Operators responsible for due diligence must collect the information required under Article 9, including product, quantity, country-of-production and supply-chain information.

For wood products, records must include the common name and full scientific name of the relevant tree species. Operators must obtain the geolocation of all plots from which the wood originated and the relevant production or harvest date or time range.

They must also retain sufficiently conclusive and verifiable evidence that the timber is deforestation-free and legally produced.

The 2025 amendment and the Commission’s 2026 implementation package simplified responsibilities across the supply chain.

Operators remain responsible for conducting the applicable due diligence and submitting a due diligence statement before placing relevant timber products on the EU market or exporting them.

Qualifying micro and small primary operators established in low-risk countries may submit a one-time simplified declaration instead of a due diligence statement. They must still collect the required information and maintain an appropriate compliance framework. Additional action may be required where they become aware of information indicating a non-negligible risk.

Downstream operators and traders do not generally repeat the upstream due-diligence exercise or submit a new due diligence statement. They must retain required supplier, customer and declaration-reference information and provide it to competent authorities when requested. Additional notification or verification requirements apply where new information or substantiated concerns indicate possible non-compliance. Non-SME downstream operators and traders also have Information System registration requirements.

The precise responsibility depends on the product, activity, organisation size and position in the supply chain.