For timber and wood product companies that have operated under the EU Timber Regulation for over a decade, the shift to the EU Deforestation Regulation represents both a familiar framework and a fundamentally new set of obligations. This guide breaks down exactly what you can carry forward, what must change, and how to plan your transition.
The EU Timber Regulation (Regulation (EU) No 995/2010) has been the cornerstone of the EU's efforts to combat illegal logging since its enforcement began in March 2013. It established a due diligence framework requiring operators placing timber and timber products on the EU market for the first time to exercise due diligence to minimise the risk of illegally harvested timber entering the supply chain.
The EU Deforestation Regulation (Regulation (EU) 2023/1115) replaces the EUTR entirely. When EUDR enforcement begins on 30 December 2026 for large operators and non-SME traders, the EUTR will be formally repealed. This is not a gradual phase-out — it is a clean regulatory replacement. From that date, the EUTR ceases to have legal effect, and all obligations shift to the EUDR framework.
For timber companies, this transition is both an advantage and a challenge. You have experience with due diligence systems, risk assessment, and supplier management. But the EUDR introduces requirements that go significantly beyond what the EUTR demanded, and companies that assume their existing systems are sufficient will find themselves exposed to serious compliance gaps.
The good news is that companies with mature EUTR compliance programmes have a strong foundation to build on. Several core elements of your existing system remain relevant under the EUDR.
The EUTR required operators to assess the risk of illegally harvested timber entering their supply chain using criteria such as the prevalence of illegal harvesting in the country of origin, the complexity of the supply chain, and the presence of third-party verification. The EUDR retains a risk-based approach, though the scope of what you are assessing risk against has expanded. Your existing methodology for evaluating country risk, supplier reliability, and supply chain complexity can serve as the starting point for your EUDR risk assessment — but it will need to be augmented with additional criteria, particularly around deforestation risk and geolocation verification.
If you have established relationships with suppliers who already provide documentation on species, origin, and legality, those relationships are valuable. The EUDR requires even more granular information from suppliers, but the communication channels, contractual frameworks, and trust you have built over years of EUTR compliance give you a significant head start. Your existing supplier questionnaires, audit protocols, and documentation templates can be adapted rather than rebuilt from scratch.
Companies that have designated compliance officers, established internal review processes, and maintained organised records under the EUTR can carry those organisational structures forward. The EUDR demands more from these structures, but the institutional knowledge and compliance culture you have developed are directly transferable.
Timber companies already understand the Harmonised System codes relevant to their products and the classification challenges that arise with processed wood products. This knowledge is directly applicable under the EUDR, which uses HS codes as part of the Due Diligence Statement submission process.
While the foundation is reusable, the EUDR introduces several requirements that represent a fundamental departure from the EUTR. These are not incremental adjustments — they are new obligations that require new systems, new data, and new processes.
This is the single biggest operational change for timber companies. The EUTR did not require geolocation data. The EUDR requires precise geographic coordinates for every plot of land where the timber was produced. For plots smaller than four hectares, a single latitude/longitude point is sufficient. For plots of four hectares or larger, you must provide polygon boundaries that delineate the plot perimeter. All coordinates must be in WGS84 format with at least six decimal places of precision, submitted as GeoJSON.
For timber supply chains, this means working with forest concession holders, logging companies, and plantation operators to obtain GPS coordinates or polygon data for every harvesting area. In many cases, this data has never been collected systematically, and building the infrastructure to capture, validate, and transmit it will require significant investment in both technology and supplier engagement.
The EUDR requires that products are verified as deforestation-free — meaning the land on which they were produced was not subject to deforestation after 31 December 2020. The primary mechanism for verifying this is satellite imagery analysis. Operators must be able to demonstrate, through satellite data or equivalent evidence, that the geolocation coordinates provided correspond to land that has not been deforested since the cutoff date.
Under the EUTR, there was no requirement for satellite monitoring. Companies relied on documentation, certifications, and supplier declarations. Under the EUDR, satellite verification becomes a core component of the due diligence process. This means either building internal capacity to analyse satellite imagery or partnering with a technology provider that can perform this verification at scale.
The EUTR required operators to maintain due diligence systems internally and make them available to competent authorities upon request. The EUDR introduces a mandatory submission requirement: before placing any product on the EU market, operators must submit a Due Diligence Statement (DDS) through the EU Information System, which is built on the European Commission's TRACES NT platform.
The DDS must include product descriptions, HS codes, quantities, country of production, geolocation data, supplier information, and the conclusion of your risk assessment. Upon submission, you receive a reference number that must accompany the product through the supply chain. This is a fundamentally different compliance model — moving from a "maintain and show on request" approach to a "submit before placing on market" requirement.
If your company handles commodities beyond timber — for example, if you trade in products that contain palm oil, soya, cocoa, coffee, rubber, or cattle-derived materials — you must now apply EUDR due diligence to those products as well. The EUTR applied only to timber and timber products. The EUDR covers seven commodity groups and their derived products. Companies that have diversified their product portfolios need to assess whether any of their non-timber products fall within the EUDR's scope.
The EUTR required operators to keep records of their due diligence for five years. The EUDR maintains a five-year retention period but applies it to a much broader set of documentation, including geolocation data, satellite verification records, DDS submissions and reference numbers, risk assessment documentation, and all correspondence with suppliers related to compliance. Given the volume of geolocation and satellite data involved, companies need to ensure their document management systems can handle the increased storage and retrieval requirements.
Under the EUTR, operators could delegate certain due diligence functions to recognised Monitoring Organisations (MOs). These organisations were formally recognised by the European Commission and could provide due diligence systems that operators could use to fulfil their obligations. The EUDR eliminates the concept of Monitoring Organisations entirely. While operators can still use third-party service providers, consultants, and technology platforms to support their compliance efforts, they cannot delegate legal responsibility. The operator remains fully liable for the accuracy and completeness of their due diligence, regardless of who performed the underlying analysis.
Use this numbered checklist to plan and track your transition from EUTR to EUDR compliance. Each item represents a concrete action that should be completed before enforcement begins on 30 December 2026.
The transition from EUTR to EUDR is not something that can be accomplished in the final weeks before enforcement. Companies should plan their transition across several phases:
Complete your gap analysis, inventory your products, and begin supplier engagement on geolocation data. Evaluate technology solutions for satellite monitoring and DDS submission. Register for the EU Information System. This is the phase for understanding the full scope of what needs to change and making strategic decisions about how to address each gap.
Deploy your geolocation data collection processes, integrate satellite monitoring into your due diligence workflow, and begin test submissions through the EU Information System. Update supplier contracts and train your compliance team. This is the phase for building and testing the operational systems that will support ongoing compliance.
Conduct dry runs of the full compliance process. Resolve any remaining issues with data quality, system integration, or supplier cooperation. Ensure all documentation is in order and all staff are trained. By 30 December 2026, your EUDR compliance system should be fully operational and tested.
Once EUDR enforcement begins, the EUTR ceases to have legal effect. All products placed on the EU market from this date forward must comply with the EUDR. There is no grace period, no transitional arrangement, and no option to continue operating under the EUTR framework. Products that were placed on the market before the enforcement date under valid EUTR due diligence remain compliant, but any new market placement must meet EUDR requirements.
Companies in the timber and wood products sector are uniquely positioned in the EUDR transition. You have over a decade of experience with due diligence systems, risk assessment, and regulatory compliance under the EUTR. You understand the concept of placing products on the market, the role of operators and traders, and the importance of supply chain transparency.
But this experience also creates a risk: the assumption that your existing systems are "close enough" to EUDR compliance. They are not. The geolocation requirement alone represents a fundamental change in how supply chain data is collected and verified. The satellite monitoring requirement introduces a technology dimension that most timber companies have never had to manage. And the DDS submission requirement transforms compliance from a private, internal process into a public, auditable declaration.
The companies that treat this transition as a strategic priority — investing in the right technology, engaging suppliers early, and building robust new processes — will not only achieve compliance but will strengthen their competitive position in a market that increasingly values transparency and sustainability.
Sources: This article draws on the full text of the EU Timber Regulation (EU) No 995/2010, the EU Deforestation Regulation (EU) 2023/1115, and the European Commission's EUDR implementation guidance.
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