The EUDR for the timber industry: what forest owners, sawmills, timber traders, furniture and paper makers must do by 30 December 2026

In brief

Wood is the commodity where the EUDR leaves the least room. For everything that was already covered by the annex of the old EU Timber Regulation, 30 December 2026 applies to every company size. The 18-person sawmill, the timber merchant with three staff and the forest owner with 40 hectares have the same date as the corporation. The deferral to June 2027 exists only for small operators and only for wood products outside the EUTR annex, such as charcoal, tool handles, kitchen boards and seats.

At the same time no other commodity has as many reliefs. Germany is a low-risk country, so the risk assessment falls away for domestic wood. Forest owners who harvest and sell themselves as natural persons, micro or small enterprises are micro or small primary operators and submit a one-off simplified declaration, optionally with a postal address instead of geodata. Forestry associations can act as operators for their members' timber. And according to the Commission guidelines, wood placed on the market before 30 December 2026 stays under the Timber Regulation together with everything made only from it; nobody needs a due diligence statement for that.

The obligations are distributed along the chain: anyone who harvests or imports wood is an operator and declares. Anyone who makes sawn timber, panels, furniture or paper from declared wood is a downstream operator and only collects supplier and customer data, the numbers only when buying from an operator. Anyone who trades is a trader; large traders register and verify on concern. Furniture makers with imported solid wood and EU particleboard hold both roles at once.

What needs doing by 30 December fits into four steps: check CN codes against the new Annex I, determine the role per sourcing route, ask suppliers and forest owners for reference or identification numbers, apply for information system access and submit the first statement before the first sale of 2027.

Why wood has the hardest deadline

Regulation (EU) 2023/1115 replaces the EU Timber Regulation (EU) No 995/2010, and it is precisely from this succession that wood's special position follows. Article 38(3) grants operators that are natural persons, micro or small enterprises established as such by 31 December 2024 the deferral to 30 June 2027, "except as regards the products covered by the Annex to Regulation (EU) No 995/2010". Anyone importing, placing on the market or exporting these products has 30 December 2026 regardless of size.

The EUTR annex covers the core of the industry: fuel wood and chips (4401), roundwood (4403), railway sleepers, sawn timber, veneer, profiled wood, particleboard, fibreboard, plywood, densified wood, frames, cases and pallets, cooperage (4406 to 4416), builders' joinery and carpentry (4418), pulp and paper of Chapters 47 and 48, wooden furniture of headings 9403 30 to 9403 60 and 9403 91, and prefabricated buildings of wood (9406 10). Outside the EUTR annex, and therefore with deferral for small operators, are charcoal (4402), hoopwood and poles (4404), wood wool and wood flour (4405), tools, handles and shafts (4417), tableware and kitchenware (4419), marquetry and ornaments (4420), other articles of wood (4421) and seats (ex 9401).

For the industry that means: practically every business working with roundwood, sawn timber, panels, packaging wood, paper or case furniture is due on 30 December 2026. The deferral helps the wood turner, the charcoal maker and the chair maker only where they are operators themselves, not the sawmill.

The hard deadline has a reason that is at the same time the biggest relief: for wood the Timber Regulation with due diligence and authority controls has existed since 2013. Anyone who complied with it already knows supplier records, legality evidence and risk assessment. What is new is geolocation, deforestation-free status as a second criterion and the statement in the information system.

Existing stock: which regulation applies when

The most important question of the first months is not how to submit a due diligence statement, but for which wood one is needed at all. The Commission answered it for the products in the EUTR annex in the guidelines of July 2026 in a table every timber business should know.

Wood harvested before 29 June 2023 is subject to the Timber Regulation if it was placed on the market before 30 December 2026, and likewise if it is placed on the market between 30 December 2026 and 30 December 2029. Only from 31 December 2029 does the EUDR apply to such wood. In Germany the EntwaldungsMG continues the EUTR regime for this wood until the end of 2029.

Wood harvested from 29 June 2023 is subject to the Timber Regulation if it was placed on the market before 30 December 2026, and to the EUDR if it is placed on the market from 30 December 2026.

What matters is the consequence for the downstream stages. The guidelines answer the question expressly for paper: if a paper product is placed on the market from 30 December 2026 whose wood was harvested and placed on the market between 29 June 2023 and 30 December 2026, the wood and the product must comply with the Timber Regulation; a due diligence statement is not required, because such statements are only demanded for products that fall under the EUDR. What applies to paper applies equally to sawn timber, panels and furniture: roundwood a sawmill bought in November 2026 can be sold as sawn timber in March 2027 without a statement, and the particleboard made from that sawn timber in autumn 2027 as well.

This is the switch that decides the workload of the first months. Anyone who documents their stock and supply contracts at the turn of the year, with delivery date and origin, can dispense with the statement for existing stock and the derived products made only from it and only has to comply with the Timber Regulation, which for processors and traders means being able to name suppliers and customers, but neither geodata nor deforestation-free status. Anyone who cannot separate the stock must apply the EUDR to everything from 30 December, because the evidence is missing.

Which wood products are covered

Since 18 September 2026 Annex I applies in the version of Delegated Regulation (EU) 2026/2102. For wood the recast replaced all 21 headings of Chapter 44 individually and gave each an "ex", replaced the blanket entry for pulp and paper with "ex 47 wood pulp" and "ex 48 paper and paperboard", narrowed the seats of heading ex 9401 to six subheadings with wooden frames and removed vehicle and aircraft seats, and recast the entries for furniture parts (ex 9403 91) and prefabricated buildings (ex 9406 10). Printed products of Chapter 49 were already removed by the amending regulation of December 2025.

Three exclusions, which the annex attaches to the relevant wood headings, decide in practice whether a product is covered:

Used and second-hand products are not covered. The repaired exchange pallet, reclaimed timber from demolition, used furniture: outside.

Waste and recovered products are not covered. Waste paper as the paper mill's raw material, recycled chips for particleboard, sawmill residues that are waste within the meaning of the Waste Framework Directive: outside. Products consisting entirely of such material can be declared on import with code Y133.

Packing material in use is not covered. The pallet under the machine, the crate around the engine, the dunnage in the container are no longer relevant products from the moment of use. The same pallet, traded empty, is a product of heading 4415 and covered.

Added to this is note 4 to Annex I: bamboo, rattan, reed, osier and cereal straw are not wood. And samples, specimens and test goods are excluded.

The classification matters in practice at three points where the CN code changes. Roundwood (4403) becomes sawn timber (4407), sawn timber becomes particleboard (4410), a window (4418) or a pallet (4415); the board becomes furniture (9403). Every change of code is a manufacturing step, and whoever carries it out places a new relevant product on the market. Whether a statement is needed for it depends solely on whether the upstream stage was already declared. How the new Annex I is structured and how to check your own articles against it is in E4 Annex I and CN codes.

The timber chain and its roles

The EUDR distributes obligations by position in the supply chain, and in no industry is the chain longer than for wood. From the forest to the furniture store the raw material changes hands five or six times and changes its CN code three or four times. The rule is simple: the operator is whoever harvests or imports the wood; downstream is whoever makes something new from declared wood; the trader is whoever passes it on unchanged.

The forest owner. Anyone who cuts wood from their own forest and sells it places it on the market for the first time and is an operator. In Germany they are almost always a micro or small primary operator: natural person, micro or small enterprise, low-risk country, harvested themselves, placed directly on the market. Their obligation is the one-off simplified declaration in the information system, with a postal address instead of geolocation and an annual estimated quantity instead of individual quantities. They receive an identification number and pass it to their buyers. The explanatory memorandum of the EntwaldungsMG counts around 770,000 forestry holdings, of which 430,000 are organised in 3,490 forestry associations, and assumes that almost all count as micro or small primary operators.

A micro or small primary operator can also be someone who exceeds the size thresholds overall but demonstrates that the wood-related part stays below them for at least two of the three criteria balance sheet total, turnover and staff. That is the opening for municipalities with a town forest, for industrial companies with a works forest and for farms where forestry is a sideline. State forest enterprises, the federal forest service and large private forest administrations, by contrast, are operators with full obligations: a due diligence statement per sale or period, with geolocation of the harvest areas, but without risk assessment and mitigation because of the low country risk.

The forestry association. Forestry associations that market their members' timber are, under the draft General Administrative Regulation, operators themselves if they place the wood on the market or export it. The explanatory memorandum names this expressly as a relief: the association submits one due diligence statement or simplified declaration for its members' annual harvest instead of every holding declaring individually. For members who sell their wood through the association, that is the simplest route. Anyone who additionally sells at roadside to a sawmill declares those quantities themselves.

The self-harvester and standing timber sales. Standing trees do not fall under the Regulation. Anyone who buys timber standing and harvests it themselves places the felled wood on the market and is the operator, not the forest owner. The Commission FAQ ties this to the contractual arrangement: the operator is whoever places the felled wood on the market in the EU or exports it. Sawmills with their own harvesting and forestry contractors felling on their own account are therefore operators for this wood, with geolocation of the harvest areas. Whether a small sawmill counts as a micro or small primary operator for wood it harvests itself depends on the definition, which turns on harvesting oneself, not on ownership of the forest; this question should be clarified with the BLE before the first felling.

The sawmill. If it buys roundwood that a forest owner, an association or a state enterprise has already declared, it is a downstream operator for the sawn timber. As an SME it collects the identity of its suppliers and customers and the reference or identification numbers of the declarations, keeps them for five years and submits no statement of its own. As a non-SME it additionally registers in the information system and verifies, on reasoned concern, whether due diligence was exercised upstream. If it imports roundwood or sawn timber from third countries, it is an operator for that with due diligence, simplified for low-risk countries.

Panel, paper and pulp mill. The same logic one stage later. Particleboard from declared German sawn timber and recycled chips makes the mill a downstream operator; pulp from Brazil makes the paper mill an operator with full due diligence for a eucalyptus plantation at the other end of the world.

Furniture and joinery manufacturers. Windows, doors, stairs, case furniture, seats with wooden frames and prefabricated houses are relevant products. Anyone who only processes declared EU material is downstream. Anyone who imports solid wood, veneer or components from third countries is an operator for those parts. Both at once is the normal case.

Trade. Timber merchants, DIY stores, furniture stores and online retailers are traders unless they import themselves. SMEs collect and store; non-SMEs register and verify on concern. The importer in retail, such as the furniture store with own brands from Vietnam, is an operator for those goods because it appears as importer in the customs declaration.

The printer is the exception in the chain. Books, newspapers and printed matter have not been relevant products since December 2025. A printer buys paper that someone else placed on the market and sells a product outside the annex. It has no role under the Regulation as long as it does not trade in unprinted paper.

Six businesses, six answers

The forest owner with 40 hectares in the Sauerland. Natural person, sells spruce and beech through the forestry association and occasionally at roadside to the sawmill in the next village. For the association's quantities the association is the operator if it places the wood on the market itself, otherwise it declares for him as authorised representative; for direct sales he is himself a micro or small primary operator: one-off simplified declaration, postal address, annual estimated quantity, identification number to the sawmill. Deadline 30 December 2026, because roundwood is in the EUTR annex.

The sawmill, 18 staff, 4 million euros turnover. Buys roundwood from the state forest, the association and private forests, sells sawn timber to carpenters and exports squared timber to Switzerland. For roundwood with a reference or identification number it is a downstream operator and only collects; for the export to Switzerland it needs neither a statement of its own nor numbers in the export declaration. If it additionally buys a lot standing and harvests itself, it is an operator for that wood with a statement and geolocation. Deadline 30 December 2026 for everything.

The timber importer with tropical hardwood from Brazil. 60 staff, imports ipe decking and plywood. Operator, standard risk: full due diligence with geolocation of the harvest areas as polygons, legality evidence from the country of production, risk assessment against the criteria of Article 10 and risk mitigation, for example through audits or additional evidence. Statement before release for free circulation, reference number with C716 in the customs declaration. Deadline 30 December 2026.

The furniture maker with 300 staff. Case furniture from EU particleboard, table tops from imported oak from the USA, chairs with beech frames from Romania. Three sourcing routes, three roles: downstream for the particleboard, operator for the oak (the USA is a low-risk country, so simplified due diligence, but a statement with geolocation), downstream for the Romanian frames; it receives a reference number only if the supplier is itself an operator. Registered as a non-SME, verification duty on concern, annual report. Deadline 30 December 2026.

The paper mill. Sources pulp from Scandinavia and Brazil plus waste paper. Downstream for Scandinavian pulp made from declared wood, operator with full due diligence for Brazilian pulp, outside the Regulation for waste paper. Paper made only from pulp that was placed on the market before 30 December 2026 needs no statement according to the guidelines. Deadline 30 December 2026.

The furniture retailer with 2,000 staff. Sells furniture from German and European manufacturers and imports own brands from Vietnam. For the purchased furniture a non-SME trader: registration, collecting data on suppliers and business customers, reference numbers only from suppliers that are operators, verification on reasoned concern, no statement of its own. For the own brands an operator with due diligence back to the plantation, full unless the wood comes only from low-risk countries such as Vietnam. Deadline 30 December 2026. How to determine the role systematically per sourcing route is shown in E3 Operator or trader.

Geolocation in the forest

For operators who harvest or import wood, geolocation is the part that requires the most preparation. Required are the coordinates of all plots on which the wood was harvested, with latitude and longitude to at least six decimal places. Up to four hectares a point is enough; above that a polygon enclosing the area is mandatory. Added to this is the harvest period, which must be in the records.

Which area. What is to be declared is the harvest area, not the forestry enterprise and not the cadastral parcel. A forest holding of 300 hectares from which a lot of 8 hectares was felled is declared with the polygon of those 8 hectares. For thinning over larger areas, the thinned area is the area of production. Anyone who declares the whole enterprise as a precaution takes responsibility for the whole enterprise: any deforestation or forest degradation on a declared plot makes the entire product non-marketable.

Where the data comes from. In German forestry enterprises compartment and sub-compartment boundaries exist as shapefiles or GeoJSON in the forest management plan; harvest areas can be cut from them. The state forest administrations keep forest areas in their geodata holdings, cadastral data supplies the parcels. For imports the polygons come from the supplier, at best from their forest management system, at worst hand-drawn on a map. Both must be converted into the format of the information system (GeoJSON) and checked against satellite imagery.

The relief for micro or small primary operators. Under Article 4a(5) they may give a postal address instead of the geolocation, provided it corresponds unambiguously to the location of the plots. The draft administrative regulation specifies for Germany: the postal address of the holding or, if there is no holding, the home address, together with a national identification number, suffices for allocating the plots. The allocation is done by the authorities using existing administrative data. For small private forests that settles the geodata question as soon as the regulation is in force; until then it is a draft.

What deforestation and forest degradation mean in the forest. Deforestation is the conversion of forest to agricultural use after 31 December 2020. Forest degradation is the structural change of forest cover through conversion of primary forest or naturally regenerating forest into plantation forest or other wooded land, and of primary forest into planted forest. Normal forestry is neither: thinning, clear-cutting with reforestation, salvage logging after storm or bark beetle and natural regeneration are neither deforestation nor forest degradation. Conversion for a road, a solar park or housing is also not deforestation within the meaning of the Regulation, because it is not agricultural; it does, however, need the forest-law conversion permit, otherwise legality is missing. Under the AVV draft the Länder authorities concentrate their supervision on precisely these points: conversion to agricultural land after 2020, placing on the market without a declaration, breaches of the rules on forest conservation and management.

Species and legality. For wood, Article 9 requires the full scientific name of the species, genus and species, for every wood contained in the product. For plywood and furniture that is several species. Legality covers the law of the country of production on harvesting, land use, environmental and forest protection, taxes, duties, labour law, human rights and the consent of indigenous peoples. For Germany that means the federal and state forest acts, nature conservation law and the permits for felling and conversion. For imports it requires the documents of the country of production: harvesting permits, transport documents, export licences. FLEGT licences, currently from Indonesia, count under Article 10(3) as evidence of legality, not of deforestation-free status. FSC and PEFC certificates are an aid in the risk assessment but replace neither geodata nor one's own check.

Country benchmarking and imported wood

The Commission sorts the countries of production into three risk categories, and for wood that makes the difference between an afternoon's task and a project.

Low risk applies to all EU Member States and, among others, the USA, Canada, the United Kingdom, Norway and Switzerland. For wood from there, simplified due diligence under Article 13 applies: collect information, geolocation, legality evidence, but no risk assessment and no risk mitigation, provided there are no indications of complexity, circumvention or mixing. Scandinavian sawn timber, Canadian softwood and American oak fall into this group. Authority control rate: one percent of operators.

Standard risk applies to many tropical timber countries of South America, Africa and Southeast Asia, including Brazil and Indonesia. Here full due diligence is required: risk assessment against the criteria of Article 10 including corruption, conflict situation, rights of indigenous peoples and complexity of the supply chain, documented and reviewed annually, plus risk mitigation until the risk is negligible. Control rate three percent.

High risk applies to Russia, Belarus, Myanmar and North Korea. Control rate nine percent. For wood from Russia and Belarus the question is practically answered anyway, because EU sanctions have prohibited imports since 2022. The classification becomes relevant with mixing: plywood or pellets in which wood of unclear origin might be processed carry the risk of the riskiest possible origin.

For the risk assessment at standard risk, a practice developed under the Timber Regulation that continues under the EUDR: the supplier's concession and harvesting permit, evidence of the transport chain from felling to port, matching the species with the customs documents, checking the region against reports of illegal logging and land conflicts, and in case of doubt an on-site audit or laboratory species identification. What is new is that the area itself is checked against satellite imagery after the cut-off date; that requires the polygons.

Due diligence in practice: three types of business

The sawmill with domestic roundwood. The effort lies almost entirely in data capture, not in assessment. Each supplier is classified once: the state forest and large private forests deliver reference numbers per statement, the association delivers the number of its statement for the annual harvest, the micro or small primary operator delivers their identification number, which applies to all their deliveries. The numbers are filed per delivery with quantity, species and date, for five years. Where the mill harvests itself, its own statement is added: polygon of the harvest area, species, quantity, simplified due diligence, statement in the information system before the first sale. One statement can cover several deliveries for up to one year, so a roundwood contract with a forest owner over the season can be mapped with one statement.

The importer. Here due diligence is a process per supplier and region of origin: supplier assessment with legality documents, polygons of the harvest areas, satellite check, risk assessment under Article 10 with a documented result, risk mitigation where necessary, and only then the statement. It must be in the system before release for free circulation, with lead time, because the authority can reject until the reference number is issued. Aggregated statements bundle many reference numbers into one for customs and customers. The difficulty is rarely the submission but the quality of supplier data: polygons that show the concession instead of the harvest area, species names as trade names instead of botanical, harvest periods that do not match the delivery date.

The processor with mixed sources. Furniture and joinery manufacturers need the role per article and component. In the ERP that is an attribute per material: declared with a number, to be declared oneself, outside. Outgoing articles are linked to their incoming materials so that in a check it is traceable for every piece of furniture which statements it consists of. As a non-SME, registration is added, verification on reasoned concern, the due diligence system under Article 12 with annual review and the public annual report. Everything on the statement itself is in E2 Due diligence statement, on the number and its passing on in E1 Reference number.

Customs: exports to Switzerland, the United Kingdom and Norway

The Regulation applies to exports as to imports, and the timber industry exports a great deal to countries that are not EU members. The operator makes the reference number available to the customs authorities before export; eight-digit CN codes are used in the export declaration. A sawmill that makes sawn timber from declared roundwood and exports it is downstream at export as well and gives neither a due diligence statement of its own nor reference numbers; Article 26(4) does not apply to that export. For wood from the transitional period, that is existing stock under the switch above, the conventional reference number 99EU9999999999 is used. Returned goods from a Swiss customer are duty-free under customs law but a re-import for the Regulation, for which the earlier placing on the market must be demonstrated. All cases with codes and a decision tree are in E6 Export and re-import and the Glossary TARIC codes.

Controls: BLE, the Länder and the laboratory

Germany divides supervision. The Federal Office for Agriculture and Food controls import, export, processing and trade, that is, importers, sawmills, panel mills, furniture makers and traders, and works with customs. The authorities competent under state law, as a rule the forest administrations, supervise domestic primary production: forest owners, forestry associations and self-harvesters. They receive from the BLE the due diligence statements and simplified declarations of their state territory and submit their first control plan by 1 March 2027.

The AVV draft describes a supervision that is meant to remain manageable for small private forests: risk-based, wherever possible within existing forest supervision, without additional data collection or on-site inspection if administrative data clarify the facts and there is no suspicion. The focus is on conversion to agricultural land after 2020, sale without a declaration and breaches of forest law.

For imported wood the control remains as the Timber Regulation introduced it, with one additional tool: the BLE has species and origin determined in the laboratory, through wood anatomy, DNA and isotopes, and compares the declared areas with satellite images. Anyone who declares meranti as "tropical hardwood" or a concession as a harvest area stands out there. In case of non-compliance the authority orders corrective action, can have the goods withdrawn from the market and imposes penalties; under the draft EntwaldungsMG fines reach up to four percent of annual turnover, intent is a criminal offence, and sales bans and blocking of system access for up to one year are added. What the act regulates overall is in E12 EUDR guide.

Roadmap to 30 December 2026 for timber businesses

By the end of September: classification. Check all articles with CN code against the new Annex I and flag whether they are in the EUTR annex. Determine the role per sourcing route: harvest, import, declared EU material, trade. Document stock and running contracts so that existing stock can be separated from new wood.

October: suppliers and forest. Write to forest owners and associations and ask for identification or reference numbers, with a note on the simplified declaration and the postal address. Request polygons, species names and legality documents from import suppliers; with overseas suppliers that takes eight to twelve weeks. Anyone harvesting themselves extracts the harvest areas from the forest management plan. Apply for information system access.

November: processes and test. Record the due diligence system under Article 12 in writing, briefly for micro or small primary operators, in detail for importers. Document the risk assessment per standard-risk supplier. Submit test statements in the system. Brief the customs agent on codes, reference numbers and the conventional number for existing stock.

December: first statements. Declare the first sales and imports of 2027 with lead time, for running roundwood contracts with validity of up to one year. Reference numbers on delivery notes and invoices, forest owners' identification numbers in the ERP. Check inspection readiness: can I say for every pack of sawn timber which statement it comes from?

Seven misconceptions from the industry

"We are PEFC-certified, so the EUDR is dealt with." Certificates are an aid in the risk assessment. They replace neither geolocation, statement nor responsibility.

"German wood is exempt." It is wood from a low-risk country, with simplified due diligence. It still needs a statement and a number.

"As a small sawmill we have until June 2027." Not for products in the EUTR annex, and sawn timber is in it.

"Pallets are packaging and therefore out." Only in use. Pallets traded empty are products of heading 4415.

"The printer has to submit a due diligence statement." Printed products were removed in December 2025. The printer has no role.

"The association declares for us, whoever we sell to." Only for the wood the association places on the market. Direct roadside sales stay with the forest owner.

"We need a statement for existing stock from January." According to the guidelines, wood placed on the market before 30 December 2026 stays under the Timber Regulation with the derived products made only from it. Documenting is enough.

How Polygon One maps the timber chain

Polygon One captures harvest areas and logging sites as polygons, from forest management shapefiles as well as from supplier input through a portal that forest owners and overseas suppliers use without an account of their own. Every area is checked against satellite imagery for deforestation and forest degradation after the cut-off date, every delivery is filed with species, harvest period and legality evidence. The role is kept per article and supplier, so that a sawmill can see which roundwood lots need their own statements and which only a number. Statements go out through the connection to the information system, aggregated statements bundle the annual harvest, and reference numbers come back to the order.

What the software does not do: determine your role in law, judge the legality of a felling or sign the assurance in the statement. If you would like to see what your timber chain looks like in this structure, book a demo or read on at the EUDR module product page.

Download the EUDR Timber Compass 2026

Four pages for forestry, purchasing and compliance: the existing-stock switch with the deadlines, the CN headings with the EUTR flag, the six scenarios and the roadmap with the rules on geolocation in the forest.

• Download: EUDR Timber Compass 2026 (PDF)

Frequently asked questions

From when does the EUDR apply to wood?

From 30 December 2026 for all products in the annex of the EU Timber Regulation, regardless of company size. Only for wood products outside that annex do operators that are natural persons, micro or small enterprises have until 30 June 2027; downstream operators and traders do not.

Do I need geodata as a forest owner?

Not as a micro or small primary operator. You submit a one-off simplified declaration with a postal address; under the AVV draft the business or home address with a national identification number suffices. Large forestry enterprises declare the harvest areas as polygons.

Does a sawmill have to submit a due diligence statement?

Not for sawn timber from roundwood that was already declared; then it is downstream and collects the numbers. It needs a statement of its own for wood it harvests or imports itself.

What about wood already in the warehouse?

According to the Commission guidelines, wood placed on the market before 30 December 2026 stays under the Timber Regulation with all derived products made only from it. No due diligence statement is required for it; the separation from new wood must be documented.

Can the forestry association declare for its members?

Yes, for the wood it places on the market. It then counts as an operator and submits one statement for its members' annual harvest.

Who is the operator in a standing timber sale?

Whoever fells the wood and places it on the market. In a standing sale that is the buyer who harvests, not the forest owner.

Is an FSC or PEFC certificate enough?

No. Certificates are an aid in the risk assessment. Geolocation, statement and responsibility remain with the operator.

Are pallets and packaging wood covered?

Traded empty yes, as products of heading 4415. In use as packaging for another product no. Used pallets are excluded.

Is a printer affected?

No. Printed products have not been relevant products since the amending regulation of December 2025.

What country risk does wood from Scandinavia or North America have?

Low risk. Simplified due diligence applies, without risk assessment but with geolocation and a statement.

What do the authorities check in the German forest?

Under the AVV draft mainly three things: conversion of forest to agricultural land after 2020, sale without a declaration and breaches of forest law, wherever possible from existing administrative data and without on-site inspection.

What happens in case of infringements?

Under the draft EntwaldungsMG fines up to four percent of annual turnover, criminal offences for intent, sales bans and blocking of system access for up to one year.

Sources and status: Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650, Articles 1, 2, 4, 4a, 5, 8 to 13, 26, 29, 37, 38 and Annex I as amended by Delegated Regulation (EU) 2026/2102. Regulation (EU) No 995/2010, Annex. Commission guidelines, OJ C/2026/3896 of 20 July 2026. Commission FAQ on the EUDR, 5th edition, question 3.12. Draft German Deforestation and Forest Degradation Minimisation Act (cabinet 12 August 2026) with explanatory memorandum. Draft General Administrative Regulation (version of 21 July 2026), Sections 2, 3. Commission country benchmarking. As at 18 September 2026. This article is not legal advice.

Photos: Annie Spratt, Patrick Robert Doyle, Bernd Dittrich, all via Unsplash.