If you import hardwood into the EU — sawn timber, decking, plywood, furniture, pulp, paper — the EU Deforestation Regulation (Regulation (EU) 2023/1115, "EUDR") is now part of your job. This guide is written for procurement and compliance teams who don't want to read 80 pages of legalese. It shows what to ask your suppliers for, how to organise the file, and how to file it. Examples assume timber from Indonesia, Malaysia and Cameroon — the most common origins in our network — but the logic is the same for any in-scope commodity.
- 30 Dec 2025 — large and medium operators must apply EUDR due diligence.
- 30 Jun 2026 — micro and small enterprises join.
- From day one, non-compliant goods can be seized and fined.
1. What the EUDR actually is
The EUDR replaces the older EU Timber Regulation (EUTR) and widens it. It says: a regulated commodity can only be placed on, or exported from, the EU market if it is deforestation-free, produced in line with the laws of the country of origin, and covered by a Due Diligence Statement (DDS) submitted to the EU information system before the goods clear customs.
Two ideas matter. "Deforestation-free" means no forest land converted after 31 December 2020. "Due diligence" means you, the operator, can demonstrate — with documents — exactly where the wood came from and why you believe it complies. Best efforts are not enough; you carry the burden of proof.
2. Who must comply, and when
The Regulation distinguishes two roles:
- Operators — the first company placing the commodity on the EU market. For importers, that's almost always you.
- Traders — anyone making the product available further down the chain. Non-SME traders also carry full due-diligence obligations; SME traders can rely on the upstream DDS reference number.
Application started on 30 December 2025 for non-SME operators and traders, and is extended to micro and small enterprises on 30 June 2026. There is no transition period for goods already on the water — the date of placing on the market is what counts.
3. The three pillars of due diligence
Collect species, quantity, country and region of harvest, geolocation, supplier identity, and legality evidence.
Score the risk of deforestation or illegality, taking into account country benchmarking, supplier track record and complexity of the supply chain.
Where risk is more than negligible, take measures (independent audits, additional documents, third-party verification) until risk is negligible.
Only when residual risk is negligible may you submit the DDS and place the goods on the market. The file must be kept for five years and made available to competent authorities on request.
4. Documents to collect from suppliers
Build a one-folder-per-shipment habit. For each shipment we recommend collecting:
| Document | What it proves |
|---|---|
| Commercial invoice & packing list | Identifies parties, HS code, quantity. |
| Bill of Lading / AWB | Proof of shipment and origin. |
| Phytosanitary certificate | Plant-health clearance; states species. |
| Harvest permit / concession licence | Legality at the harvest level (e.g. RKT or IPK in Indonesia). |
| V-Legal / FLEGT licence (Indonesia) | Country-issued legality assurance under SVLK. |
| FSC or PEFC chain-of-custody certificate | Optional, but strong risk-mitigation evidence. |
| Geolocation file (GeoJSON) | Coordinates of every harvest plot — mandatory under EUDR. |
| Supplier self-declaration | Signed statement on deforestation-free status post-2020. |
5. Geolocation: the rule that breaks pipelines
Article 9 of the EUDR is the one most suppliers stumble on. For every shipment, the operator must record the geolocation of all plots of land where the commodity was produced. For plots smaller than four hectares, a point coordinate (latitude + longitude, ≥ 6 decimal places) is enough. Larger plots must be described as polygons.
Ask suppliers for a single GeoJSON file per
shipment. The EU's TRACES NT system accepts it directly,
and it can be opened in QGIS, Google Earth or any GIS
tool to spot-check overlap with WRI / Global Forest Watch
deforestation alerts.
If your supplier has never produced geolocation data, expect a 4–8 week ramp-up: training concession staff to log coordinates, cleaning historical records, and reconciling them with harvest permits. Plan procurement contracts accordingly.
6. V-Legal, FLEGT and country risk
Indonesia is the only country with an operational FLEGT VPA with the EU. Timber shipped with a V-Legal / FLEGT licence is presumed legal under the EUTR and remains the gold standard for legality evidence under EUDR. It does not replace the deforestation-free requirement or geolocation, but it does substantially lower the legality leg of your risk assessment.
For other origins (Malaysia, Cameroon, Brazil) lean on:
- FSC or PEFC chain-of-custody certificates;
- National permits (Cameroon TLTV, Malaysia MYTLAS, Brazil DOF);
- Country risk benchmarking once the Commission publishes the EUDR list (standard / low / high risk).
Until benchmarking is published, treat every country as "standard" and run full due diligence. Don't assume your country is low risk because suppliers say so.
7. Filing a Due Diligence Statement
The DDS is the moment of truth. You submit it through the EU's TRACES NT Information System before the goods are placed on the market. The system issues a DDS reference number and a verification number. Customs links those numbers to the import declaration via the EU Single Window for Customs (EU CSW-CERTEX).
- Create your operator profile in TRACES NT.
- Upload geolocation, supplier data and product details.
- Confirm risk assessment and mitigation are documented.
- Submit the DDS and store the reference number with the shipping file.
- Pass the DDS reference downstream to your traders.
Errors in TRACES NT submissions are the most common cause of hold-ups. Validate geolocation files locally before upload, and keep one team member trained on the system rather than rotating responsibility shipment-by-shipment.
8. The 10-minute pre-shipment checklist
- HS code, species (scientific name) and volume confirmed in writing.
- Country and sub-national region of harvest documented.
- Geolocation file (GeoJSON) attached, with coordinates ≥ 6 decimals.
- Harvest permit numbers traced back to the concession.
- V-Legal / FLEGT licence on file for Indonesian timber.
- Supplier self-declaration on deforestation-free post-2020 status signed.
- Independent risk-mitigation evidence (audit, FSC/PEFC) attached where needed.
- DDS submitted in TRACES NT and reference number stored.
- DDS reference shared with downstream traders.
- Full file archived for 5 years.
Frequently asked questions
Who has to comply with the EUDR?
Any operator placing in-scope commodities (including timber, wood products, furniture, pulp and paper) on the EU market, and any trader making them available downstream. Non-SME operators began applying due diligence on 30 December 2025; micro and small enterprises follow on 30 June 2026.
What documents do I need from my supplier?
At minimum: HS code, scientific species name, country and sub-national region of harvest, geolocation coordinates of each plot, harvest date or period, supplier identity, and legality evidence (e.g. harvest permits, V-Legal/FLEGT licence for Indonesian timber, CITES if applicable).
Does a FLEGT licence replace EUDR due diligence?
No. FLEGT-licensed Indonesian timber is presumed legal under the EU Timber Regulation, but EUDR adds a deforestation-free requirement. You still need geolocation data and a full Due Diligence Statement (DDS) — the FLEGT licence is strong legality evidence inside that file.
What are the penalties for non-compliance?
Up to 4% of EU-wide annual turnover, confiscation of the goods and revenues, temporary exclusion from public procurement, and a temporary ban from placing products on the EU market.
What is a DDS reference number?
When you submit a Due Diligence Statement in the EU's TRACES NT Information System, you receive a DDS reference and verification number. Downstream traders cite that number on their own DDS instead of repeating the full due diligence.
How GTH helps
EUDR documentation, attached to every quote.
Sellers on Green Trade Hardwood publish V-Legal / FLEGT, geolocation and harvest evidence at the listing level, so buyers receive a pre-assembled compliance pack with every RFQ — ready for risk assessment and TRACES NT submission.