The EU Deforestation Regulation applies to timber and wood products from 30 December 2026, and operators placing them on or exporting them from the EU market must file a due diligence statement proving the wood is deforestation-free, legally produced, and traceable to the plot of land it came from.
Timber is treated differently from the other six commodities in one important respect: micro and small enterprises in the timber sector face the same December 2026 date as large companies, while their equivalents in other sectors have until 30 June 2027. On 4 May 2026 the European Commission confirmed there will be no third postponement.
This article covers what EUDR asks of timber operators, why small timber businesses do not get the extra six months, and exactly what geolocation data a compliant due diligence statement requires down to coordinate precision and file format.
It explains which parts of the obligation depend on field records you may not currently be capturing, sets out a preparation sequence for the months remaining, and is explicit about where field data capture ends and statement filing begins.
Key takeaways
- EUDR applies to timber and wood products from 30 December 2026 for large and medium operators, and for micro and small enterprises in the timber sector.
- Micro and small operators outside the timber sector keep a deferred date of 30 June 2027, so most small timber businesses do not benefit from that extension.
- The European Commission confirmed on 4 May 2026 that there will be no further delay.
- Geolocation must be given as latitude and longitude in decimal degrees to at least six decimal places, submitted in GeoJSON format to the EU Information System.
- Plots larger than four hectares require polygon geometry describing the perimeter, not a single point.
- The cut-off date is 31 December 2020: wood from land deforested or degraded after that date cannot be placed on the EU market.
- Penalties include fines of at least 4 per cent of annual EU turnover, confiscation of products and revenues, and exclusion from public procurement.Â
What the EU Deforestation Regulation Requires From Timber Operators
EUDR requires any operator placing timber or wood products on the EU market, or exporting them from it, to prove three things and file a due diligence statement recording that proof. The regulation entered into force in June 2023 and covers seven commodities: cattle, cocoa, coffee, palm oil, rubber, soy and wood, along with a wide range of derived products.
For the timber sector it replaces the EU Timber Regulation, and what changes operationally is what now counts as evidence.
The three conditions every timber product must meet
A product must be deforestation-free, legally produced, and covered by a due diligence statement. Deforestation-free is defined against a fixed cut-off: wood produced on land deforested or degraded after 31 December 2020 cannot be placed on the EU market.
For timber specifically, forest degradation has its own meaning, covering the conversion of primary or naturally regenerating forest into plantation forest or other wooded land where that conversion is induced by harvesting. Damage from storms, fire or pests does not count.
Why EUDR is stricter than the EU Timber Regulation it replaces
The EUTR relied on due diligence systems that, in practice, often accepted paperwork at face value. EUDR asks for coordinates. An operator must identify the specific plot of land where the wood was produced and give that location to an authority that will compare it against satellite forest cover data. Paperwork asserting legality is no longer enough on its own, because the location claim is now independently checkable.
What happens if you cannot produce the evidence
Member states set their own penalties, and the regulation sets a floor. Fines must reach at least 4 per cent of annual EU turnover, proportionate to the environmental damage and the value of the products, alongside confiscation of the products and of revenues from selling them, and temporary exclusion from public procurement and public funding. Competent authorities can carry out checks without warning.
The December 2026 EUDR Deadline and Why Small Timber Operators Do Not Get an Extension
EUDR has been postponed twice, so many operators are expecting a third delay. That expectation is now wrong.
A second point gets widely misreported alongside it: the six-month extension granted to small businesses does not reach the timber sector.Â
Together the two change how much time a small sawmill or timber trader has left.
The confirmed EUDR application dates for timber
Who | Application date | Notes |
Large and medium operators and traders | 30 December 2026 | Confirmed, no further postponement |
Micro and small enterprises in the timber sector | 30 December 2026 | Same date as large companies |
Micro and small operators outside the timber sector | 30 June 2027 | The six-month deferral does not extend to timber |
The Commission published its simplification package on 4 May 2026 and confirmed the 30 December 2026 application date without further delay.Â
Legal analysis of the package read the signal as political as much as legal. The date stands firm for large and medium companies and for micro and small enterprises in the timber sector, while micro and small operators outside timber keep 30 June 2027, and operators who took a wait-and-see position were advised to treat the package as the final state of play.
Why timber is treated differently from the other commodities
The amending regulation does not spell out a rationale, though the history points to one. The EU Timber Regulation imposed due diligence obligations on the sector years before EUDR existed, so timber businesses of every size were already expected to have systems running.
Whether that holds for any given small operator depends on how thorough its EUTR compliance was. Operators who treated the EUTR as a paperwork exercise have considerably more to do than the timeline suggests.
What the simplification package changed and what it did not
The Commission estimates that simplification measures introduced since June 2023 will reduce annual compliance costs by roughly 75 per cent against the original framework, while core due diligence obligations remain fully in place.
The package also clarified that due diligence obligations attach to individual legal entities and not to corporate groups. Each entity qualifying as an operator maintains its own account in the Information System, and a European Court of Justice judgment of 13 November 2025 found that a subsidiary pointing to a management system held at parent company level was not sufficient for compliance. Forestry groups running several legal entities cannot rely on a single group-level system to cover all of them.
What Geolocation Data an EUDR Due Diligence Statement Requires
Geolocation is the requirement that separates EUDR from everything that came before it, and the technical specification is precise enough that getting it approximately right is the same as getting it wrong. The rules below apply to every plot of land that produced wood entering a given consignment.
Coordinate precision and format
Geolocation means latitude and longitude in decimal degrees to at least six decimal places. Six decimals resolves to roughly a tenth of a metre at the equator, which is well beyond what a consumer handset delivers unaided, though the requirement governs the format of the recorded value, not a guaranteed accuracy in the field. Submissions go to the EU Information System in GeoJSON, using the WGS84 coordinate reference system.
When you need a polygon instead of a point
Plots larger than four hectares producing commodities other than cattle must be described using polygons, meaning enough boundary coordinates to describe the perimeter of the plot. Plots under four hectares may use either a polygon or a single point.
This is the distinction that catches forestry operators. Each polygon describes one plot of land, and where a product draws on several plots, several polygons go into the same due diligence statement.
Four hectares is a small area in forestry terms. Most harvest blocks, compartments and management units exceed it comfortably, so for the majority of timber operations the polygon requirement is the default rather than the exception. Any plan built around dropping a pin at each site will not produce a compliant statement.
What the coordinates are checked against
Authorities compare submitted geolocation against satellite forest cover data, with the Joint Research Centre’s 2020 forest cover map serving as the reference point for the cut-off date.
The regulation anticipates that operators will use European space programme services including EGNOS, Galileo and Copernicus to obtain the positioning precision a compliant polygon depends on. Records supporting a due diligence statement, including geolocation files, risk assessments and supplier details, must be retained for at least five years.
The Field Data Problem Behind an EUDR Due Diligence Statement
Filing a due diligence statement is an office task, but almost all of the data in it is collected in the forest, at a landing, or at a mill gate. That is where most operators find their exposure.
Geolocation gets the attention; the five problems below are less obvious and just as capable of stopping a submission.
Step 1: Establish which role your business holds under EUDR
Obligations differ for operators, downstream operators and traders, and the simplification package added the downstream operator category with lighter duties. Determine your role for each product line before designing anything, and remember that the assessment applies to each legal entity separately, not to the group.
Step 2: Map every plot of land supplying you
This is the longest task and it should start first. For each supplier and each source, identify the plots, their areas, and whether each exceeds four hectares. Plots above that threshold need polygon geometry, and obtaining boundaries from a supplier who has never been asked for them takes several rounds of correspondence.
Step 3: Decide who captures the polygons and to what standard
Either your suppliers produce boundary data, or you send someone to walk it, or you derive it from existing forest management mapping. Each route needs a defined standard covering coordinate precision, format and who signs off. Ambiguity here produces inconsistent files that fail validation at submission.
Step 4: Build the supporting evidence record around each plot
Harvest permits, tenure documentation, species and volume records, supplier declarations and verification visit reports all attach to plots. Structure this so that a query about one plot returns everything relevant to it, because that is how an authority request will arrive.
Step 5: Set up verification visits as a documented routine
Spot checks on higher-risk suppliers should be recorded with their own location, date, author and photographs. A verification programme that produces no record counts for little when an authority asks how you satisfied yourself about a supplier.
Step 6: Register in the Information System and test a submission
Registration and a trial statement will surface data-format problems while there is still time to fix them. The Commission has been upgrading the system through 2026, adding a simplified declaration format for micro and small primary operators and voluntary grouping of statement reference numbers, so check the current state before assuming an earlier workflow still applies.
Step 7: Fix retention and retrieval before the deadline, not after
Five years of records have to be stored somewhere they can be found by plot, supplier and date. Deciding that now is far easier than restructuring it after a year of collection.
A note on what is still being decided The draft Delegated Act on product scope, which proposes changes to the list of covered products in Annex I, went out for public consultation closing 1 June 2026. Two Commission databases are also due before the application date, one listing relevant legislation in countries of production and one covering certification schemes. Check the current position on both before finalising scope decisions. |
Where VerusTrust Forms Fits in EUDR Preparation, and Where It Does Not
Being precise about scope matters more here than in most product sections, because the EUDR software market contains a lot of claims that do not hold up against what the regulation actually asks for.
VerusTrust Forms is a field data collection platform with optional blockchain verification. For EUDR it covers capture and export, meaning the plot geometry itself, the legality documentation around it, and the verification records showing you checked what a supplier told you.
What it does not do is file the statement, and that boundary is clearer stated up front than buried in a feature list.
What Forms does and does not do Forms captures the data and produces the files. It does not submit them. Due diligence statements are filed to the EU Information System, and none of that submission happens inside Forms. Everything up to that point is covered, from submission-ready plot geometry through to the legality documentation, supplier declarations, harvest and handoff records and verification visit reports that support it. |
Polygon capture for plots above four hectares
Forms supports GPS data collection with point, line and polygon geospatial fields inside any form, so a crew can walk a plot boundary and record it as polygon geometry alongside the rest of the record.
Coordinates come from the device hardware receiver in a structured field an administrator can make mandatory before submission.
That covers the EUDR rule requiring polygons above four hectares without a separate GIS deployment or a dedicated GPS unit.
Boundary capture works offline too, which matters because plot perimeters get walked in exactly the places with no coverage. The submission queues on the device and syncs on return.
Polygon data then exports as GeoJSON in WGS84, the format and projection the EU Information System expects, so no conversion step is needed between capture and submission.
Structured supplier declaration and legality forms
Build the declaration you send suppliers as a structured form with constrained fields, so what comes back is consistent and comparable across every supplier instead of arriving as free text in a dozen formats. The drag-and-drop form builder and advanced field types make that easy, and require no technical know-how.
Verification visit records with location and photographs
When someone visits a supplier or a harvest site to check what was declared, the record of that visit carries its own coordinates, timestamp, author and photographs. This is what shows a verification programme happened and did not merely exist on paper.Â
Using the Forms mobile app with offline mode, visits get recorded offline and sync on return, so poor coverage at a supplier site does not cost you the record.Â
Attribution across suppliers, contractors and staff
Where suppliers submit, procurement reviews and compliance approves, permissions keep it clear who asserted what. Since EUDR obligations attach to individual legal entities, knowing which entity and which person produced a record matters.
VerusTrust Forms allows setting user roles and permissions, making it easy to keep all of that in order.
Tamper-evident records for the claims most likely to be challenged
A cryptographic hash of each submission can be anchored to a public blockchain while the data stays encrypted on your account, so you can show a record has not changed since it was captured. Anchoring proves integrity, not accuracy: it says nothing about whether the declaration was truthful.Â
Verustrust Forms offers blockchain verification and smart contracts on every plan, making it easier than ever to create tamper-evident, public records of your submissions.
To learn more, refer to our guide to blockchain traceability.
Retrieval and export across a five-year retention window
Records stay searchable by site, supplier and date. Plot geometry exports as GeoJSON for the statement itself, and the surrounding evidence exports to standard spreadsheet formats such as XLSX for compiling an authority response or handing a file to whoever submits on your behalf. See the submission dashboard and Microsoft Azure hosting and security for data residency options.
Moreover, teams already running structured field inspections have a head start here, because the same discipline applies here as in our article on forestry BMP compliance and digital field inspections.
Operators who have worked through EU agricultural subsidy compliance will recognise the pattern as well: a European compliance regime asking for verifiable, located field data on a fixed timetable.
Start Building Your EUDR Evidence Base Today
The deadline is fixed, the Commission has said there will be no third extension, and small timber operators are on the same date as everyone else.
Plot mapping and supplier engagement have the longest lead times, so those two decide whether the rest of the work fits in the months available. Everything else can be built alongside them.
Build your supplier declaration and verification visit forms on the free plan, or talk to our team about capturing plot boundaries and supplier evidence in one record and exporting geometry ready for submission.
EUDR Timber Compliance: Frequently Asked Questions
The questions below cover the points most often misunderstood about how EUDR applies to timber, particularly around dates, geolocation format, and who carries the obligation.
When does EUDR apply to timber and wood products?
EUDR applies to timber from 30 December 2026 for large and medium operators and traders, and for micro and small enterprises in the timber sector. Micro and small operators outside the timber sector have until 30 June 2027. The Commission confirmed in May 2026 that there will be no further delay.
Do small timber companies get the EUDR extension to June 2027?
Generally no. The deferred date of 30 June 2027 applies to micro and small operators outside the timber sector. Micro and small enterprises in the timber sector are on the 30 December 2026 date, because the sector was already regulated under the EU Timber Regulation.
What geolocation does an EUDR due diligence statement need?
Latitude and longitude in decimal degrees to at least six decimal places, submitted in GeoJSON format. Plots larger than four hectares require polygon geometry describing the perimeter. Plots under four hectares may use a single point.
What is the EUDR cut-off date?
31 December 2020. Wood produced on land that was deforested or subject to forest degradation after that date cannot be placed on the EU market or exported from it, regardless of whether the harvest was legal under national law.
What are the penalties for EUDR non-compliance?
Member states set penalties, with fines of at least 4 per cent of annual EU turnover, confiscation of the products and of revenues from them, and temporary exclusion from public procurement and public funding. Authorities can conduct checks without warning.
How long must EUDR records be kept?
At least five years from the date the product was placed on the market, and they must be produced to competent authorities on request. That covers geolocation files, risk assessments and supplier documentation.
Does EUDR apply to timber harvested inside the EU?
Yes. EUDR applies to products produced within the EU as well as imports. What matters is whether the land of origin has been free of deforestation since the cut-off date, not which country it is in.