EUDR questions and answers

It also applies to timber from the EU. The EUDR is not an import regulation: it concerns the first placing on the EU market, subsequent making available and export. A forest owner who sells harvested timber is an operator.

Yes. Crossing a border is not a condition. The Union market also includes a domestic commercial transaction.

The determining factor is the customs classification in Annex I to the EUDR, as amended. For wood, the scope includes specified CN/HS entries in Chapter 44, pulp and paper in Chapters 47 and 48 subject to stated exclusions, selected wooden seats and furniture, and prefabricated buildings of wood. Several entries are marked “ex”, meaning that only the part described in Annex I is covered.

No. The correct customs classification must be established. If the customs code is not in Annex I, the product does not fall under the EUDR, for example musical instruments, wooden toys or wood-plastic composites. For entries marked “ex”, only the part of the entry described in the Annex falls under the EUDR. For composite products, obligations apply only to the wood component.

Typical examples outside the EUDR scope include printed books and other products not listed in Annex I; waste as defined by EU waste law; used and second-hand products where Annex I expressly excludes them; products made entirely from material that has completed its life cycle and would otherwise have become waste; packaging material used exclusively to support, protect or carry another product and presented with that product; samples and products used for examination, analysis or testing; and products made from bamboo, rattan or other materials that are not covered by the relevant Annex I entries. The exact CN/HS classification and the wording of Annex I, including any “ex” limitation, are always decisive.

Yes. Sawdust and wood chips produced during sawing fall under customs code 4401 and remain within the scope of the EUDR. A manufacturing by-product is not automatically waste. An exception applies to chips or sawdust used exclusively as packaging material to support, protect or transport another product.

A product made exclusively from material that has completed its life cycle and would otherwise have become waste, for example wood from demolition of a building, does not fall under the EUDR. If the product also contains new wood, that part remains within scope. The exemption does not automatically apply to manufacturing by-products.

It depends on their use. New pallets, crates and packaging under customs code 4415 that you place on the market as goods in their own right are within scope – even if they are reusable. Packaging that serves exclusively to support, protect or carry another product and is presented with that product is excluded from scope (Delegated Regulation (EU) 2026/2102, applicable from 18 September 2026). Used and second-hand pallets and packaging are outside the scope.

No. The Regulation has no minimum quantity. Even a small proportion of virgin fibres in a recycled product must be covered.

Two conditions must be met. Timber must not originate from land subject to deforestation after 31 December 2020, and harvesting after that date must not cause forest degradation within the meaning of the Regulation’s definition.

The basic application date for timber and timber products is 30 December 2026. Under Article 38(3), the deferral to 30 June 2027 applies only to operators that are natural persons or micro- or small undertakings and that were established as such by 31 December 2024, and only for products that were not already covered by the Annex to the former EUTR. For timber and timber products already covered by the EUTR Annex — including fuel wood, roundwood, sawnwood, veneers, plywood, specified wood-based panels, pulp, paper and specified wooden furniture — the application date is therefore 30 December 2026 even for micro and small operators. Downstream operators and traders do not benefit from the Article 38(3) deferral; their applicable EUDR obligations start on 30 December 2026, subject to the transitional rules for products that were already placed on the market during a valid transitional period. Products newly added to Annex I by Commission Delegated Regulation (EU) 2026/2102 become subject to the EUDR from 30 December 2027.

No. Both roundwood and fuel wood are among the products already listed in the Annex to the former EUTR Regulation, and their date is 30 December 2026 regardless of the size of the undertaking. The June 2027 deferral does not apply to them.

It does not qualify for the Article 38(3) deferral to 30 June 2027. For products already within the EUDR scope and subject to the general application date, the relevant date is therefore 30 December 2026. A separate product-specific date applies to products newly added to Annex I by Commission Delegated Regulation (EU) 2026/2102: those newly added products become subject to the EUDR from 30 December 2027.

Where the products fell under the former EUTR Regulation, the EUTR applies to them until 31 December 2029. From 31 December 2029, the EUDR applies to everything. For old stocks, it is therefore important to be able to demonstrate the date of production and origin.

The date of first placing on the market is decisive, not the date of harvesting or purchase. Goods placed on the EU market before 30 December 2026 may continue to be sold and processed without a statement or reference number; a statement cannot and need not be submitted retrospectively. Goods purchased now but placed on the market only after that date must fully comply with the EUDR, including geolocation and a statement.

Yes, if you can demonstrate for each batch that it was either placed on the market before 30 December 2026 or is covered by a statement. You pass on to the customer the reference numbers for the parts that have them.

An operator first places a product on the market or exports it, typically a forest owner selling their own timber or an importer. A downstream operator manufactures another relevant product exclusively from products already covered by a statement (Art. 2(15b)); what matters is whether a new product is created – typically when the CN customs code changes. A trader is any person in the supply chain other than an operator or a downstream operator who makes the product available on the market (Art. 2(17)) – typically reselling it without making a new product from it. One company may have different roles in different goods flows.

No, if the input timber has already been covered upstream by a due diligence statement (DDS) or a simplified declaration. You are a downstream operator: you do not carry out a new due diligence process and do not submit your own DDS merely because you process that already-covered input. You must keep the required information on your direct suppliers and customers for at least five years. If you are the first downstream operator buying directly from an operator or a micro or small primary operator, you must also collect and keep the DDS reference number or the simplified declaration identifier passed to you. Only non-SME downstream operators must register in the EUDR Information System.

No. A trader does not submit its own DDS or simplified declaration for relevant products already covered upstream. It must keep the required information on its direct business partners for at least five years. If it is the first trader buying directly from an operator or a micro or small primary operator, it must also collect and keep the DDS reference number or simplified declaration identifier passed to it. Only non-SME traders must register in the EUDR Information System.

No. Obligations are triggered only after harvesting. The operator becomes the person who acquires ownership of the logs by the act of harvesting. Depending on the wording of the contract, this may be the forest owner, the harvesting company or the buyer.

No. Without supply on the market, that is, without transfer of ownership, no obligations arise. This also applies to a person producing fuel wood for their own consumption. They become an operator only when they sell the timber.

No. The contract concerns a service, not a supply of timber, and ownership of the timber does not pass to the sawmill.

No, until ownership passes to a third party. This also applies, for example, to a timber auction where a buyer is found only later.

On import you are an operator: before the customs declaration you must have submitted a due diligence statement and have a reference number available. A producer outside the EU that itself places its own production on the EU market and qualifies as a micro or small primary operator from a low-risk country may submit a simplified declaration for its own role, provided it has the required EORI number and access to the Information System. This does not replace the importer's own due diligence and DDS or the obligations of the first EU-established operator under Art. 7. If you sell the imported timber on unprocessed, you communicate the reference number to the relevant downstream operators and traders that are your direct customers (Art. 4(7)). For a new relevant product you manufacture exclusively from already-covered inputs, you are a downstream operator: you do not submit a new statement and do not pass the number on further.

Yes. Release for free circulation is always considered placing on the market, regardless of subsequent use.

Not simply because they are small. A micro or small primary operator must be a natural person or a micro or small undertaking, be established in a country classified as low risk, and place on the market or export relevant products that it has itself grown, harvested, obtained from or raised on relevant plots of land, or, for cattle, on establishments located in that country. Ownership of the land is not itself a condition.

Only for products all of whose inputs already subject to the EUDR are covered by a due diligence statement or a simplified declaration (Art. 2(15b)). Timber demonstrably placed on the market before the EUDR started to apply (transitional period) and material outside the scope of the EUDR do not count. If a product also contains other uncovered timber, you are an operator for it: you exercise due diligence (simplified, where the conditions of Art. 13 are met) and submit your own statement. If you do not know the origin of the uncovered timber, submitting a statement alone does not solve this – you must first obtain information on the origin. One company may therefore hold different roles for different consignments.

No. Directive 2013/34/EU allows Member States to raise the financial thresholds for small enterprises up to EUR 7.5 million balance sheet total and EUR 15 million turnover, but the EUDR refers only to the basic thresholds of the Directive both for the definition of a micro or small primary operator (Art. 2(15a)) and for the deferral to 30 June 2027 (Art. 38(3)). The basic thresholds therefore apply: micro-enterprise up to 10 employees, EUR 0.9 million turnover and EUR 0.45 million balance sheet total; small enterprise up to 50 employees, EUR 10 million turnover and EUR 5 million balance sheet total. An undertaking falls into a category if it does not exceed at least two of the three criteria. A category change after exceeding or ceasing to exceed the thresholds takes effect only after two consecutive financial years (Art. 3(10) of the Directive). For a micro or small primary operator, even an undertaking above the overall thresholds may demonstrate that the parts of its balance sheet total, net turnover and average number of employees relating to relevant commodities and products do not exceed at least two of the three criteria; it must be able to document this allocation.

Not everyone must register in the same way. The EUDR Information System is a specialised online tool of the TRACES platform. Operators that submit due diligence statements (DDS), micro or small primary operators that submit simplified declarations, authorised representatives, and non-SME downstream operators and non-SME traders must be identifiable in the system as required for their role. SME downstream operators and SME traders do not have to register merely for those roles. Carriers, warehouse keepers, customs declarants without their own EUDR role and consumers likewise do not register merely for those activities. A company that is not required to register may still have record-keeping and other EUDR obligations.

No. The EUDR has no approval procedure in which a company sends forestry documents and obtains permission to conduct business. Registration is merely identification of the entity and obtaining access to the system. Compliance of individual consignments is ensured by due diligence and submission of a statement, not by registration itself.

First, outside the system, map your goods flows, determine the CN/HS code and EUDR role for each flow, and obtain an EORI number where required for import or export. A responsible person then creates access through EU Login and signs in to the EUDR Information System, a specialised online tool of the TRACES platform. Check whether the entity already exists and request access if it does; otherwise create the appropriate entity profile and verify the legal name, address and identifiers. The process should first be tested in the training/acceptance environment, where submissions have no legal effect. For API or web-service use, activate the relevant access and authentication credentials and test them first in the training environment.

There is no single mandatory “registration package” when creating an account. You do not need to upload a title deed, forest management plan, harvesting permit, FSC or PEFC certificate, parcel GeoJSON, invoices or stand photographs at registration. These documents are important as evidence during due diligence and inspections, but are not submitted when the account is created. However, the system or competent authority may request information needed to verify the entity’s identity.

There is no single rule requiring every company to register by 30 December 2026 regardless of activity. An operator must have working access before submitting its first DDS, which must be submitted before placing a relevant product on the market or exporting it. A micro or small primary operator must have submitted the required simplified declaration and obtained its declaration identifier before its first relevant placing on the market or export, unless the Member State makes the required information available in the Information System under Article 4a(4). A non-SME downstream operator or non-SME trader must register before its first relevant activity after the applicable date. In practice, access should be created and tested earlier, especially where an API connection is used.

Each legal person that has an EUDR role requiring registration must be identifiable separately in the Information System; one entity profile cannot simply represent an entire corporate group as a single legal person. An authorised representative may, however, submit DDSs or simplified declarations on behalf of several group companies where the legal conditions are met. Responsibility for compliance remains with the represented operator.

Yes. An authorised representative may be anyone established in the EU — a forestry association, consultancy firm or your customer. Under Art. 6(3) a natural person or micro-enterprise may also mandate the next entity in the chain (their customer), provided it is not a natural person or micro-enterprise. The representative needs a written mandate that you must be able to provide at the authority’s request, their own access and role in the system, and the submission must contain the correct identification details of the represented operator. The authorisation does not transfer responsibility: the represented operator remains responsible for product compliance and the accuracy of the information in the statement. It is not possible to submit one collective statement for all association members; the representative submits a separate statement for each. An authorised representative under the EUDR is not the same as a customs representative.

No. A medium-sized enterprise is an SME under Directive 2013/34/EU. Registration in the information system (Art. 5(2)) and verification of due diligence in case of a substantiated concern (Art. 5(6)) apply only to downstream operators and traders that are not SMEs, i.e. large enterprises. Keeping supplier and customer records for five years and the duty to inform in case of a risk of non-compliance (Art. 5(5)) apply to all sizes.

A due diligence statement (DDS) is submitted in the EUDR Information System before an operator places a relevant product on the market or exports it. For imports, the DDS reference number must be available for the customs declaration before release for free circulation. After the required risk profiling, the Information System assigns a reference number to the DDS and an associated verification number.

No. A micro or small primary operator submits a one-time simplified declaration before placing relevant products on the market or exporting them, unless the required information is made available to the Information System by the Member State under Article 4a(4). The Information System assigns a declaration identifier. The information may be updated following major changes. The operator remains responsible for compliance of the relevant products.

Not necessarily. For a micro or small primary operator, the geolocation required by Article 9(1)(d) may be replaced by the postal address of all plots of land or, where applicable, the postal address of the establishment from which the relevant commodities were produced. This derogation is specific to the simplified regime.

No. A single DDS can cover multiple physical batches or shipments where all legal requirements are met and due diligence has been carried out for all products covered. Once the quantity covered by the DDS has been used, a new DDS is required for additional quantities. The same DDS reference number may therefore be used in several customs declarations where the legal requirements are respected.

Yes, an authorised representative, for example a forestry association, roundwood trader, sawmill or harvesting company. The authorisation must be in writing and responsibility remains with the operator. The representative submits a separate statement for each member; combining several members into one statement is not possible. A natural person or micro-enterprise may also mandate their customer, provided the customer is not a natural person or micro-enterprise (Art. 6(3)). A different situation arises where the association buys standing timber and becomes the owner of the wood by the act of harvesting – then the association itself is the operator and submits its own statement.

A supplier established outside the EU can submit a DDS only where it is itself acting as the operator placing the relevant product on the EU market, for example by importing it under the customs procedure ‘release for free circulation’, and it has the required EORI number and access to the Information System. If such a supplier is a micro or small primary operator from a low-risk country placing its own production on the market, it may submit a simplified declaration instead of a DDS. If you are the EU importer placing the product on the market, you remain the operator and must carry out your own due diligence and submit your own DDS.

Yes, if all information required by Annex III is available in a database or system that exists under Union or Member State law. In that case the micro or small primary operator does not submit the simplified declaration itself and the Member State makes the information available in the information system (Art. 4a(4)). You may nevertheless place the relevant products on the market or export them only after a declaration identifier has been assigned. Check with the competent authority whether this option is available in your Member State; until it is, you submit the simplified declaration yourself or through an authorised representative.

No. An operator must communicate the DDS reference number to downstream operators and traders further down the supply chain; where applicable, a micro or small primary operator communicates the simplified declaration identifier. The EUDR does not generally require forest coordinates, legality documents or tree-species data to be passed downstream merely for traceability. A verification number is a separate security credential used in the Information System and is not the identifier that Article 4(7) requires to be communicated down the supply chain.

No. This is a common misconception. Geolocation is the operator’s obligation. A downstream operator and trader have a much narrower obligation: to keep identification details of their direct business partners and, in the specified case, the reference number.

Not with every one. A DDS reference number or simplified declaration identifier is required where your direct supplier is an operator or a micro or small primary operator (forest owner, importer). You do not have to actively investigate whether your supplier has that role. If you know that they do and you are their first customer, however, you must hold the number or identifier before you further place the product on the market, make it available or export it (Art. 5(1) and (3)) and keep it for at least five years. No reference number is required from a trader or a downstream operator.

No. The operator or micro or small primary operator communicates the DDS reference number or simplified declaration identifier to the relevant downstream operators and traders further down the supply chain. The first downstream operator or trader must collect and keep it, but downstream operators and traders do not have a general obligation to pass those numbers or identifiers further down the chain.

No. Such requirements have no basis in the Regulation. Only passing on the reference number where required is mandatory.

Not necessarily. A downstream operator exporting relevant products that are already covered by an upstream DDS or simplified declaration is not required to submit a new DDS merely because of the export. Customs formalities must use the applicable TARIC documentation/certificate code for the situation. The downstream operator's record-keeping obligations continue to apply.

Full upstream due diligence is not repeated if you can demonstrate that the relevant products, or all relevant products contained in them, were previously placed on the EU market and were already subject to the EUDR. In that case, the re-importer is treated as a downstream operator. For customs, upstream reference number(s) received from the supplier can be used; where none were passed on, Commission guidance provides for the conventional reference number 22EU2222222222 for this re-import situation.

A description of the product with both the common and full scientific name of the tree species, quantity, country of production, geolocation of all plots, date or period of harvesting, identification details of supplier and customer, and evidence that the timber is deforestation-free and harvested in accordance with the laws of the country of production.

For a plot of up to and including 4 hectares, one point is sufficient. For a plot larger than 4 hectares, a polygon with sufficient points to describe its perimeter is required. Each plot is stated separately: it is not permitted to join several plots into one polygon or to state a larger surrounding area. Coordinates are given in WGS84 to at least six decimal places.

Land within a single property under the law of the country of production.

Yes, if all sources are known and compliant. In that case, the operator states the geolocation of all plots. Mixing compliant material with material of unknown origin is not permitted.

No. Low risk is not an exemption. Information including geolocation is always collected and the product must meet the requirements of the Regulation. Only risk assessment and risk mitigation are omitted. If specific information about risk or circumvention of the rules emerges, you must move to full due diligence.

No. The Regulation does not prescribe a specific verification method or service.

No. Deforestation is the active conversion of forest to other land use, especially agricultural land, after 31 December 2020. A natural disturbance or subsequent sanitary harvesting does not cause degradation within the meaning of the Regulation. However, the operator bears the burden of proof concerning the purpose of harvesting.

No. The Regulation defines deforestation as conversion of forest to agricultural use. Conversion for roads, renewable energy sources or fire prevention is not deforestation within the meaning of the EUDR.

No. Voluntary certification does not replace due diligence or a statement and does not create a simplified regime. However, information from certification schemes may be useful supporting evidence in risk assessment.

Not for the EUDR as a whole. Timber with a valid FLEGT licence is considered to meet the legality requirement, but it does not replace the deforestation-free requirement, geolocation or submission of a statement.

At least five years. An operator retains due diligence documentation, while a downstream operator and trader keep records of business partners. It must be provided to the competent authority on request.

The current EU benchmarking classifies Belarus, Myanmar, the Democratic People’s Republic of Korea and the Russian Federation as high risk. Countries listed as low risk include all EU Member States as well as, among many others, the United Kingdom, the United States, Canada, Ukraine and China. Countries not listed as low or high risk are standard risk. The classification affects the due-diligence regime and the intensity of competent-authority checks and should always be checked against the current Commission country-classification list.

Member States must introduce fines with a maximum amount of at least 4 per cent of annual EU-wide turnover, confiscation of goods and revenues, exclusion from public procurement and public funding for up to 12 months, and, for serious or repeated infringements, a temporary prohibition on trading. The Commission publishes entities that have been finally sanctioned. Specific rates and the competent inspection authority differ between Member States.

The information, explanations, overviews and other content provided in this EUDR section are exclusively informational and supportive in nature. They do not constitute a legal, professional or binding opinion and may not be regarded as a guarantee of compliance with obligations under Regulation (EU) 2023/1115 (EUDR) or related legislation.

The same limitations apply to outputs generated by this application, in particular geolocation data, GeoJSON exports, completed or pre-completed forms, documents, and indicative assessment of roles and dates. These outputs are a basis for further processing by the user; generating them does not fulfil the due diligence obligation or the obligation to submit a statement. The economic operator alone bears responsibility for the content and accuracy of the statement submitted to the European Union Information System.

Map materials, cadastral and forestry data originate from third parties, in particular national geodetic and forestry institutions, and are provided in the state in which they were received from them. The displayed property boundaries are informative and do not replace binding data of the relevant cadastral or forestry authority.

The EUDR Regulation applies in individual Member States together with national rules, which differ particularly in the designation of the competent authority, penalties and documentation requirements. The content of this section may not cover these national differences in full.

The content of this section is available in several language versions. Translation of technical and legal terms may result in inaccuracies, loss of nuances of meaning, or a language version not being updated at the same time as the others. The binding text of legislation is always only the text published in the Official Journal of the European Union or, as applicable, in the official collection of laws of the relevant Member State.

The EUDR legal framework is continually developing and may be amended or supplemented by legal acts of the European Union, guidance from the European Commission, or decisions of competent authorities or courts. There may therefore be a time gap between a change in legal or methodological requirements and an update of this content.

DREVARI.SK, s.r.o., to the fullest extent permitted by applicable law, does not warrant that the information in this section is at every moment complete, error-free or up to date, or suitable for the user’s particular situation.

The user is responsible for verifying the current obligations that apply to their activities, products and supply chain. For decisions with legal or commercial consequences, we recommend verifying information in current official European Union sources and, where necessary, consulting the competent authority or a qualified professional.

More detailed terms for use of this section and limitations of liability are also set out in the official Terms of Use of this application.

The content of this section is current as at 13 October 2026.