The EU Deforestation Regulation (EUDR) replaces the EU Timber Regulation (EUTR) with a fundamentally broader and more demanding compliance framework. If your business operated under EUTR, here is everything you need to know about what has changed — and what you need to do next.
The EU Timber Regulation — formally Regulation (EU) No 995/2010 — entered into force on 3 March 2013. It was the European Union's first major attempt to combat illegal logging by regulating the timber products placed on the EU market. The regulation applied exclusively to timber and timber products, covering items such as solid wood, plywood, pulp, paper, and certain wooden furniture.
Under the EUTR, operators — defined as entities first placing timber products on the EU market — were required to exercise due diligence to minimise the risk that the timber they traded was illegally harvested. The regulation established a three-step due diligence system:
A distinctive feature of the EUTR was the role of Monitoring Organisations (MOs). These were private entities recognised by the European Commission that could provide operators with pre-built due diligence systems. Operators could use an MO's system instead of developing their own, effectively outsourcing part of their compliance obligation. Recognised MOs included organisations like NEPCon (now Preferred by Nature) and several national timber trade federations.
Enforcement was handled by Competent Authorities designated by each EU Member State. These authorities were responsible for conducting checks on operators and, where necessary, imposing penalties. However, the level of enforcement varied significantly across Member States, and penalties were generally modest — often limited to fines of a few thousand euros, with criminal prosecution being rare.
Despite being a pioneering piece of legislation, the EUTR had several well-documented limitations that undermined its effectiveness:
The European Commission concluded that a more comprehensive regulation was needed — one that addressed deforestation directly, covered all major deforestation-linked commodities, and established a standardised, technology-enabled compliance framework.
The EU Deforestation Regulation — Regulation (EU) 2023/1115 — was adopted on 31 May 2023 and will apply from 30 December 2024 for large operators and from 30 June 2025 for SMEs (with the application dates subsequently extended by 12 months to 30 December 2026 and 30 June 2027 respectively). It represents a fundamental overhaul of the EU's approach to deforestation-linked trade. Here are the key changes:
The EUTR covered only timber. The EUDR covers seven commodity groups: cattle, cocoa, coffee, oil palm, rubber, soya, and wood. For each commodity, the regulation also covers a wide range of derived products — from leather and chocolate to biodiesel and furniture. The full list is set out in Annex I of the regulation and references Combined Nomenclature (CN) codes.
This is the single most significant change. Under the EUTR, the only requirement was that timber be legally harvested. Under the EUDR, products must be both legally produced and deforestation-free. The cut-off date is 31 December 2020: products must not have been produced on land that was forest before that date and has since been converted to agricultural use. This applies regardless of whether the deforestation was legal under local law.
Operators must provide the geographic coordinates of all plots of land where the commodity was produced. For plots under 4 hectares, a single latitude/longitude point is sufficient. For plots of 4 hectares or more, the full polygon boundary must be provided. Coordinates must be in WGS84 format with at least six decimal places of precision. This requirement enables satellite-based verification of deforestation-free status.
The EUDR explicitly anticipates the use of satellite monitoring to verify that production plots have not been deforested. The European Commission will use Copernicus satellite data and other Earth observation tools to cross-check the geolocation data submitted by operators. This is a capability that simply did not exist under the EUTR framework.
Under the EUTR, compliance was documented internally. Under the EUDR, operators must submit a Due Diligence Statement (DDS) through the EU's centralised information system, built on the TRACES NT platform. Each DDS receives a unique reference number that must accompany the product through the supply chain. This creates a standardised, auditable compliance trail.
The EUDR introduces significantly stronger penalties. Member States must ensure that fines are proportionate to the environmental damage and the value of the products concerned, with a maximum of at least 4% of the operator's total annual EU-wide turnover. Additional penalties can include confiscation of products, exclusion from public procurement, and temporary prohibition from placing products on the market. This is a dramatic increase from the EUTR, where fines were often in the low thousands of euros.
The EUDR eliminates the concept of Monitoring Organisations entirely. Operators are directly and solely responsible for conducting their own due diligence. While they may use third-party tools and services to assist them, they cannot delegate their legal responsibility to an external organisation. This closes the compliance gap that existed under the EUTR.
The EUDR introduces a country risk benchmarking system that classifies countries (or sub-national regions) as low, standard, or high risk based on their deforestation rates, governance, and enforcement capacity. Operators sourcing from low-risk countries benefit from simplified due diligence requirements, while those sourcing from high-risk countries face enhanced scrutiny and higher check rates by competent authorities.
| Aspect | EUTR (Regulation 995/2010) | EUDR (Regulation 2023/1115) |
|---|---|---|
| Commodities covered | Timber and timber products only | 7 commodities: cattle, cocoa, coffee, oil palm, rubber, soya, wood — plus derived products |
| Core requirement | Legality of harvest | Deforestation-free AND legally produced |
| Cut-off date | None | 31 December 2020 |
| Geolocation | Not required | Mandatory — GPS point or polygon boundary |
| Satellite verification | Not used | Copernicus and Earth observation data |
| Reporting system | Internal documentation only | Centralised EU Information System (TRACES NT) |
| Monitoring Organisations | Recognised MOs could provide due diligence systems | Eliminated — direct operator responsibility |
| Maximum penalties | Varied by Member State; generally low fines | At least 4% of annual EU-wide turnover |
| Country risk classification | No formal system | Low / Standard / High risk benchmarking |
| Scope of actors | Operators placing timber on EU market | Operators and traders for all 7 commodities |
If your business previously operated under the EUTR, the transition to the EUDR requires significant operational changes. The EUDR is not simply an update to the EUTR — it is a fundamentally different regulatory framework with broader scope, stricter requirements, and stronger enforcement. Here is what you need to address:
Your existing EUTR due diligence system will not be sufficient for EUDR compliance. At a minimum, you need to:
The EUTR allowed operators to rely on Monitoring Organisations and general risk assessments. The EUDR requires plot-level traceability. For timber companies, this means:
The EUDR's Annex I covers a broader range of wood-derived products than the EUTR did. If your business deals in products such as printed paper, wooden furniture, charcoal, or wood-based panels, verify that all of these are covered by your compliance programme.
Under the EUTR, enforcement was often light and inconsistent. The EUDR mandates that competent authorities check a minimum percentage of operators and products each year, with higher check rates for products from high-risk countries. Penalties of up to 4% of annual EU-wide turnover mean that non-compliance carries serious financial risk. Companies should treat EUDR compliance as a board-level priority, not just an operational task.
The geolocation, satellite verification, and DDS submission requirements of the EUDR are inherently technology-dependent. Manual processes that may have been adequate under the EUTR will not scale to meet EUDR requirements. Companies should evaluate compliance technology solutions that can automate geolocation data collection, satellite-based deforestation screening, risk assessment, and DDS generation.
The EUDR's application dates have been extended by 12 months from the original schedule. Large operators must comply by 30 December 2026, while SMEs have until 30 June 2027. The EUTR will be formally repealed once the EUDR fully applies. During the transition period, companies should be working to build their EUDR compliance systems and processes, as the regulation's requirements — particularly around geolocation data collection and supply chain mapping — take significant time to implement.
Sources: This article draws on the official texts of Regulation (EU) 2023/1115 (EUDR), Regulation (EU) No 995/2010 (EUTR), and the European Commission's EUDR implementation page.
See how Plotwiser's AI-powered solution handles your entire due diligence pipeline — from satellite verification to DDS generation.
