This checklist provides a 27-point framework for timber operators and traders to assess readiness for the EU Deforestation Regulation. It covers the full supply chain from forest concession or plantation through processing and export, addressing species identification, harvest-level geolocation, and the distinction between selective logging and deforestation that is central to timber compliance.
This checklist is distinct from the EUDR timber legality verification template, which focuses narrowly on the legal production requirement. This checklist addresses the full due diligence obligation including deforestation-free verification, geolocation, risk assessment, and traceability across the entire supply chain.
Completing this checklist does not constitute compliance. The EUDR requires operators to exercise due diligence and file a Due Diligence Statement substantiated by evidence. This checklist helps identify where your evidence chain has gaps before a competent authority finds them.
What is the EUDR timber compliance obligation?
Regulation 2023/1115 prohibits placing on or exporting from the EU market commodities that are not deforestation-free or were not legally produced. Wood and wood products (HS codes 4403-4421, covering wood in the rough, sawn timber, panels, and manufactured wood products) are among the seven covered commodity groups.
For timber, the supply chain spans 3-4 tiers: forest concession or plantation to sawmill, sawmill to secondary processing, processor to exporter, exporter to EU importer. The critical distinction is between selective logging — harvesting individual trees within a standing forest — and deforestation, defined using the FAO definition as conversion of forest to non-forest land use. Selective logging may be deforestation-free; clear-cutting for replanting may not be. The operator filing the DDS bears the full burden of proof under Article 4.
FLEGT licences address legality only. They do not verify deforestation-free status and do not replace EUDR due diligence.
What this template covers
Sourcing and geolocation (Articles 9(1)(a), 9(1)(d), 9(1)(e))
- All harvest areas identified and geolocated in WGS84 (EPSG:4326) at 6-decimal precision
- Geolocation recorded at harvest compartment level — not just concession boundary; polygon boundaries captured for the specific area harvested
- Geolocation data includes collection timestamp, device metadata, and collector identity — not just raw coordinates
- Each harvest area linked to a concession holder, plantation owner, or community forest manager with tenure documentation on file
- Scientific species name recorded for each timber product (Article 9(1)(a)) — trade names alone are insufficient
- CITES-listed species identified and applicable CITES permits obtained and on file
- Harvest date recorded for each consignment to verify production against the December 31, 2020 deforestation cutoff
Risk assessment (Article 10)
- Country risk classification confirmed for each origin (standard, low, or high risk) using current EU benchmarking
- Deforestation screening performed using satellite imagery anchored to the December 31, 2020 baseline — distinguishing selective logging from land-use conversion
- Independent deforestation alert systems cross-referenced for each harvest area (e.g., Global Forest Watch, JRC Tropical Moist Forest monitoring)
- Risk assessment methodology documented: data sources, resolution, thresholds, and decision criteria recorded
- Where concerns identified: risk mitigation measures documented and implemented before DDS filing (Article 10(2))
- Origin-specific risks documented — conflict timber, illegal logging prevalence, and governance capacity assessed for each source country
Legality verification (Article 9(1)(e))
- Relevant legislation of the country of production identified (forestry laws, concession regulations, environmental protections, labour laws, tax obligations, indigenous and community rights including FPIC)
- Legal compliance evidence collected or supplier attestation obtained with supporting documentation for each origin
- Concession licence or plantation permit verified as current, with harvest volumes within licensed limits
- Where applicable: FLEGT licence on file, with acknowledgement that it addresses legality only and does not satisfy the deforestation-free requirement
- For CITES species: export and import permits verified as valid and consistent with harvest documentation
Processing and traceability (Articles 4, 9)
- Sawmill intake documented — each log or batch linked to the specific harvest compartment and concession of origin
- Species verification performed at processing — visual or laboratory identification confirming species matches harvest documentation
- Volume conversion documented at each processing stage (log to sawn timber, sawn to panel or finished product) with yield factors recorded
- Batch or lot identifiers maintained from harvest through processing and export with traceability links at each transfer
- No mass balance applied — the EUDR prohibits mass balance; physical segregation or identity preservation required
Documentation and filing (Articles 4, 9, 12)
- DDS prepared with all required fields under Article 4(2) before the product is placed on the EU market
- All supporting evidence archived and retrievable for the mandatory 5-year retention period (Article 12)
- Evidence chain auditable end-to-end: competent authority can trace from filed DDS to individual harvest compartment through each processing stage
- DDS reference number obtained from the EU Information System and linked to shipment and customs documentation
How to use this template
Step 1 — Map your supply chain. Document every tier from harvest area to EU market entry: concessions or plantations, sawmills, secondary processors, exporters, and the EU importer. For timber, start by distinguishing concession harvesting from plantation sourcing — the evidence requirements differ fundamentally.
Step 2 — Work through each section. Mark items complete only when documentary evidence exists — not when a process is planned or verbally confirmed.
Step 3 — Close gaps before filing. Prioritise species identification and harvest-compartment geolocation, as these cannot be reconstructed after timber leaves the forest.
Step 4 — Review quarterly. New harvest areas, concession renewals, and risk reclassifications require reassessment.
How to implement this in your organisation
Assign ownership. Your compliance officer or sustainability manager owns this checklist and is accountable for its completeness. Procurement and forestry teams contribute harvest-level evidence; the export manager reviews the assembled package before DDS filing.
Set the review cadence. Verify species identification evidence at each processing stage where species substitution is possible — sawmill intake, secondary processing, and export packaging. Conduct a full checklist reassessment quarterly and immediately when triggered by a new harvest area, a concession renewal, or a country risk reclassification by the European Commission.
Define your escalation path. Any gap identified during review halts DDS preparation for the affected consignment until the gap is closed. The responsible team member escalates unresolved gaps to the export manager within 48 hours, with a documented explanation of the gap and a proposed remediation timeline.
Connect to existing workflows. Integrate harvest-compartment geolocation capture and species documentation into your supplier onboarding process so evidence is collected before the first log delivery. Link species verification checks to your existing QC procedures at sawmill intake and secondary processing, and attach completed checklist evidence to export documentation packages alongside CITES permits and commercial invoices.
Who needs this template
- Timber exporters assembling DDS evidence packages for EU-bound consignments
- Processors documenting species verification, volume conversion, and batch traceability through sawmill and secondary processing
- Compliance officers auditing evidence chains across multi-tier timber supply chains before DDS filing
- EU importers verifying upstream evidence meets the standard for a defensible Due Diligence Statement
FAQ
Does a FLEGT licence satisfy EUDR due diligence requirements?
No. FLEGT licences verify legal production but do not address the deforestation-free requirement. A FLEGT licence may support the legality component of your due diligence but cannot replace geolocation, deforestation screening, or DDS filing.
How does the EUDR distinguish selective logging from deforestation?
The EUDR uses the FAO definition: conversion of forest to agricultural or other non-forest land use. Selective logging — harvesting individual trees while the forest remains — is not deforestation. However, operators must demonstrate the harvested area remains forested. Clear-cutting, even if replanted, may constitute deforestation if the land use changes. Satellite imagery comparing pre- and post-harvest canopy cover is essential evidence.
Why does the EUDR require the scientific species name?
Article 9(1)(a) requires the scientific name. Trade names are ambiguous — one trade name may cover multiple species with different conservation statuses. Scientific names enable competent authorities to verify CITES status and check origin plausibility.
Does completing this checklist mean I am EUDR compliant?
No. This checklist helps identify evidence gaps. Completing every item means you have documented your evidence chain — it does not certify compliance, guarantee a successful regulatory review, or substitute for independent legal counsel. Operators must exercise due diligence and substantiate their DDS with evidence a competent authority can verify.
Timber supply chains involve species-level identification requirements, the selective-logging-versus-deforestation distinction, and multi-stage processing conversions that make traceability uniquely challenging among EUDR-covered commodities. A checklist identifies gaps — a platform closes them. Book a demo to see how ResourceLedger provides evidence-grade traceability from harvest compartment to EU port of entry.