EUDR: the European Commission's guide new compliance for companies in the timber sector and reminder of the Thursday, March 13th webinar

This official document clarifies the regulatory requirements and the steps to be followed to ensure the traceability of wood and wood products. LCB and ATIBT have joined forces to publish , a FAQ detailing the obligations of all players, please feel free to read or reread  it.

Reminder: we are also organizing a Q&A workshop on EUDR, on Thursday March 13 at 2pm. The event will be in French, but we can arrange simultaneous translation. You can register via this link. 

• Who is affected and what are the obligations?

The EUDR imposes obligations due diligence on companies that place wood and wood products on the European market.

The new EC guide identifies three profiles of players, distinguishing between upstream operators and exporters, downstream operators and traders:

• Upstream operators (foresters, importers, sawyers) and end-users (exporters)

The first marketers or exporters, must verify the legal and sustainable origin (non-deforestation and non-degradation) of the wood, collect precise GPS coordinates of the plots, and file a Due Diligence Declaration (DDR) via the EU platform. Large companies must also appoint an EUDR officer within their company, evaluate their due diligence procedures annually and publish a public report.

• Downstream operators (manufacturers, processors) and retailers (distributors, resellers)

Downstream operators transform wood into finished products and place them on the EU market.

Traders sell wooden products already placed on the marketEU .

The regulation makes a distinction between the obligations of SMEs and non-SMEs. To find out which thresholds apply to your company's size, please refer to our FAQ p6 and 7, or to the EC's "SME" information sheet.

• Non-SMEs

 Downstream operators and non-SME traders must ensure that their suppliers have properly exercised their due diligence obligations, and retain evidence of due diligence already submitted upstream. They must also retrieve reference numbers their due diligence declaration and register on the platform EC  (the information system). They must also appoint an EUDR officer in their company, evaluate their due diligence procedures annually and publish a public report.

• SMEs

Downstream operators and SME traders do not have a due diligence obligation or a due diligence declaration. However, they will have to keep a register of suppliers and check that products purchased comply. You will find all the information you need on the EC's ."SME" fact sheet

• Enhanced wood traceability

A central element of the regulation is the requirement for strict traceability:

- Plots > 4 ha: precise GPS polygons required.

- Plots ≤ 4 ha: One GPS point is sufficient. 

- Accepted file format: GeoJSON.

• Contents of Due Diligence Declarations (DDR)

Information required (EUDR Annex 2) :

• Descriptive data on the operator and the products concerned.
• Country of production of wood or wood by-products.
• Geolocation of plots where raw materials were harvested.
• Reference numbers of existing due diligence declarations (if applicable).

Optimization and duplication avoidance :

• Information from an existing due diligence declaration can be reused.
• If an upstream declaration already contains the geolocation, you can refer to it without having to it.re-enter

• Declarations of Due Diligence for several lots
• Simplification of obligations:
  A single due diligence declaration (DDR) can cover several lots or shipments (truck, boat, etc.) to reduce the administrative burden for operators.

Mandatory conditions:
The operator or trader non-SME must certify that :

• Due diligence has been carried out on all the products concerned.
• No risk or only a negligible risk has been identified concerning compliance with requirements EUDR (Article 3, points a and b).
• It assumes responsibility for the conformity of declared products (Article 4(3) EUDR).

Precautions and limitations :

• The accumulation of batches under the same declaration can increase the risk of non-compliance.
• A new declaration must be filed as soon as the quantity covered by the initial declaration is reached. (FAQ 5.19).

• Customs declarations and due diligence

Obligation for operators upstream or exporting :
Any operator importing products or exporting covered by the EUDR must also complete a customs declaration. This applies to both import and export procedures.

Due diligence declaration (DDR) reference number :

• Before finalizing a customs declaration, the operator must obtain a reference numberdue diligence declaration .
• This number is generated after the RFI has been submitted to the EU information system.
• It must be included in the customs declaration for each product concerned.

Use of the same number for several batches :

• If an RD covers several shipments/batches, the same reference number can be reused for several customs declarations.
• This is permitted as long as all EUDR legal requirements are met (FAQ 5.19, 5.20).

• Timetable and implementation

December 30, 2025 → Application for medium-sized and large companies

June 30, 2026 → Application for small and micro businesses

See our latest article

• Penalties for non-compliance
• Fines of up to 4% of sales
• Seizure non-conforming products
• Temporary suspension of business operations
• Suspension of public procurement
• Possible criminal conviction of the manager
• Best practices for simplified compliance

The guide encourages companies to :

- Anticipate the collection of GPS data from their supplies.
- Automate the declaration process via ERP solutions connected to the EU platform.
- Rely on certifications (FSC, PEFC) to demonstrate traceability, although they do not replace due diligence.

 Take action now!

Companies must actively prepare for these new requirements. LCB and ATIBT remain mobilized to help their members anticipate these changes and comply effectively with the EUDR.

Read the full guide from the European Commission:

Link to the official document