Dejan Jasnic · Co-founder & Compliance Lead, Trusty · 20+ years anti-fraud & compliance · ACFE Swiss Chapter Board
For timber businesses, EUDR is not simply a renamed EUTR.
It changes both the scope of the law and the evidence businesses need to collect.
to EUDR, in one place
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EUDR vs EUTR at a glance
EUTR | EUDR | |
|---|---|---|
Legislation | Regulation (EU) No 995/2010 | Regulation (EU) 2023/1115 |
Main focus | Illegal timber | Deforestation, forest degradation and legality |
Commodities | Timber and timber products | Cattle, cocoa, coffee, oil palm, rubber, soya, wood + relevant derived products |
Geolocation | Not an equivalent plot-level requirement | Required for relevant production plots |
Deforestation cut-off | No equivalent | 31 December 2020 |
Due diligence | Yes | Yes, with expanded data/risk requirements |
DDS in EU system | No equivalent | Yes, where required |
Status | Being replaced | Successor regime |
What did the EUTR require?
The EU Timber Regulation was designed to prevent illegally harvested timber and timber products from being placed on the EU market.
Operators placing timber on the EU market had to exercise due diligence.
The system focused primarily on legality: companies needed information about timber and suppliers, had to assess the risk of illegal harvesting and mitigate non-negligible risks.
EUDR retains the concept of due diligence but adds a much broader environmental objective.
What does EUDR add?
1. Deforestation-free requirements
Under EUDR, legality alone is not enough.
Covered products must also satisfy the Regulation’s deforestation-free requirements.
For wood, the Regulation also addresses forest degradation.
This creates a fundamental change:
EUTR: Was the timber legally harvested?
EUDR: Is the product legal and does it meet the Regulation’s deforestation/forest-degradation conditions?
2. A 31 December 2020 cut-off date
EUDR introduces a specific deforestation cut-off.
Relevant commodities generally must have been produced on land that has not been subject to deforestation after 31 December 2020.
For wood, the forest-degradation requirements also reference this date.
That means historical land-use information becomes part of compliance.
3. Plot-level geolocation
One of the biggest operational differences is geolocation.
EUDR information requirements include the geolocation of plots where relevant commodities were produced.
For plots larger than four hectares used for production of relevant commodities other than cattle, this generally means polygons rather than a single point.
This creates an entirely new data challenge for many timber supply chains.
A supplier name and country of harvest are no longer necessarily enough.
4. More commodities
EUTR concerned timber.
EUDR covers seven commodity groups:
- cattle;
- cocoa;
- coffee;
- oil palm;
- rubber;
- soya; and
- wood.
It also applies to specified derived products listed in Annex I.
That transforms what was largely a timber legality regime into a much broader commodity and supply-chain regulation.
5. Deforestation risk assessment
EUDR risk assessment goes beyond illegal harvesting.
Relevant considerations can include:
- country risk;
- presence of forests;
- prevalence of deforestation or forest degradation;
- Indigenous Peoples;
- substantiated claims;
- supply-chain complexity;
- risk of circumvention;
- reliability of documents;
- certification or third-party verified information.
The result must support a conclusion of no or negligible risk before a product subject to full due diligence can proceed.
6. Due diligence statements and digital compliance
EUDR also introduces a more formal digital compliance architecture.
All operators submit a due diligence statement through the EU’s EUDR Information System before placing relevant products on the market or exporting them; micro and small primary operators may instead submit a one-time simplified declaration.
This makes compliance much more transaction- and data-driven than the previous timber regime.
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When does EUDR replace EUTR?
Under the current consolidated EUDR, the EUTR is repealed with effect from 30 December 2026.
However, transitional provisions matter.
The EUTR can continue to apply until 31 December 2029 to certain timber and timber products that were produced before 29 June 2023 and are placed on the market from 30 December 2026.
So businesses should not assume there is one simple date after which every timber product automatically switches from EUTR to EUDR.
The production date and circumstances matter.
What about small timber companies?
The revised EUDR applies from 30 December 2026 to operators, and to downstream operators and traders of any size.
Micro and small operators established as such by 31 December 2024, and natural persons, have until 30 June 2027, except for timber products listed in the Annex to the EU Timber Regulation.
However, the extension does not work the same way for products already covered by the EUTR.
Businesses dealing with timber should therefore check the specific transitional provisions rather than assuming the general small-business extension applies to every timber product.
Does EUTR compliance make you EUDR compliant?
No.
An existing EUTR due diligence system can provide a useful foundation.
Companies already accustomed to:
- supplier due diligence;
- legality checks;
- risk assessment;
- risk mitigation;
- documentation;
are starting from a better position.
But EUDR introduces additional requirements, particularly around deforestation, forest degradation, geolocation and the digital compliance process.
An EUTR system therefore needs to be upgraded, not simply renamed.
What should timber companies change?
For businesses moving from EUTR to EUDR, the biggest practical shift is likely to be data.
A useful readiness checklist is:
Product scope
Map products against the EUDR’s Annex I CN codes.
Supplier data
Identify who can provide the required production information.
Geolocation
Collect and validate plot coordinates or polygons where required.
Deforestation checks
Connect production locations with evidence addressing the 31 December 2020 cut-off.
Legality
Maintain and update existing legality controls.
Risk assessment
Expand EUTR-style risk assessments to the broader EUDR criteria.
Documentation
Create a traceable link between products, suppliers, plots, evidence and applicable DDS/reference information.
EUTR experience is valuable, but it isn't enough
Companies with mature EUTR systems have an advantage.
They already understand the logic of supply-chain due diligence.
But EUDR turns that process into something considerably more granular.
The compliance chain increasingly looks like:
product → supplier → commodity → country → plot → coordinates → production date → deforestation evidence → legality → risk assessment → DDS/reference
Managing those connections manually becomes difficult as supplier and shipment volumes grow.
Frequently asked questions
Yes. Regulation (EU) 2023/1115 repeals the EUTR, subject to transitional provisions for certain timber produced before 29 June 2023.
Under the current consolidated Regulation, EUTR is repealed from 30 December 2026.
Yes. It covers cattle, cocoa, coffee, oil palm, rubber, soya and wood, as well as specified derived products.
Yes. Relevant products must comply with relevant legislation in the country of production in addition to satisfying the deforestation-free requirement.
Yes, as a foundation. But it will generally need additional processes for EUDR requirements such as geolocation, deforestation/forest-degradation assessment and EUDR-specific information management.
No. Certification can support due diligence, but it does not automatically satisfy EUDR requirements.
The bottom line
EUDR takes the due diligence concept familiar from EUTR and expands it considerably.
The biggest change can be summarized simply:
EUTR focused on whether timber was legal. EUDR asks whether covered products are legal, deforestation-free and supported by the required traceability and due diligence evidence.
For timber companies, preparing for EUDR therefore means preserving what worked under EUTR while adding the location, environmental and transaction-level data the new regime requires. EUDR Passport collects that data per product profile and files the due diligence statement for you.
External sources: Consolidated Regulation (EU) 2023/1115; European Commission EUDR Guidance.
Related reading: where EUDR and CSRD requirements overlap, whether you are an operator or a trader under EUDR, and what the 30 June 2027 deadline means for small businesses.
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30 DECEMBER 2026
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